How does investment management and the regulation of financial institutions differ between the UK and the U.S.?
Baris: Each country has its own regulatory scheme, but the regulators all talk to each other. The result is that the regulatory structures borrow and learn from one another, although the structures are entirely different. Spangler: The U.S. market and the UK market are extraordinarily successful, but they have followed different paths and, as a consequence, there are differences in regulatory approach. The UK has been the primary international market for centuries, and its cross-border and international perspective informs just about every aspect of the rules, regulations and regulatory framework that govern its activities. In the U.S., by way of contrast, a single continent-wide economy has been the market. Regulation tends to be outward-looking in the UK; in the U.S. there has been, at least until recently, an internal focus. Baris: U.S. regulation derives from the needs of U.S. markets and the historical structure of the financial system, to be sure. But, U.S. securities regulation
