Topic: Banking Control Law in Saudi Arabia, shortcomings and development
Please add the new work to the same file I have been attached,,
Here is the final draft of my thesis, but it needs extra amendments and revises in formatting and in contents as well.
Please read the whole draft very well then please update the draft in contents according to the following comments:
1) Bank of England (‘BoE’) independence: There are a number of references throughout the thesis regarding the BoE’s independence. Do you mean control over certain key
central bank functions or just freedom from political interference? Can a central bank ever be wholly independent? Is independence relative and is it especially
important regarding certain key functions? For instance, on page 50 you refer to independence as being a very important attribute and seemingly define it by reference
to freedom from political interference, as you also do on pages 120 and 127. On page 25 you refer to the pre-independent BoE being subject to “political meddling” as
“a daily affair.”On page 51 you refer to the BoE being “completely independent”. On page 62 you refer to the BoE enjoying “full independence” and on page 63 it is
described as “a completely independent agency.” On page 64 you then describe this independence as being “essential to the maintenance of monetary stability.” On page
80 you describe the BoE as enjoying “almost complete independence.” Later central bank independence is linked to economic growth. All this needs to be addressed in an
early section that sets the position out clearly – how is central bank independence crucial and in what way?
Clarify the exact meaning of independence of the central bank in introduction (abstract) and other chapters then linking with the whole story.( I mean take the full
freedom for the central bank when practising their authorities in banking supervision such as licensing, inspection, issuing regulations related to their
jurisdictions. But these independence doesn’t meaning the central bank can work alone and without the fully coordination with the government as a major part on economy
of each country. Therefore, prevent the government to interfere on the central bank doesn’t agreed with the approach the central banks work without controlling and
coordination with the government. You have to mention to the appendix such as BCL 1966, and SAMA’s charter on the introduction to make the reader smoothly follow the
topics on the thesis.
2) You are not always consistent in your treatment of SAMA. On page 48 you refer to SAMA’s exemplary record as an autonomous institution and as being the best central
bank in the Middle East, yet elsewhere you criticise its lack of autonomy. On page 70 you refer to how well it managed the 2008 financial crisis, yet still do not
address in detail the rather poor track record the BoE and FSA had through ‘light-touch’ regulation in the run up to the crisis. The lack of autonomy that SAMA enjoyed
at the time does not seem to have impacted on the control of the crisis, yet on the same page you assert that this somehow demonstrates the need for SAMA to be granted
3) You mention the Wahhabis on page 34, without really explaining who they are. My understanding is that an important element of their teaching is that there should be
complete submission by a population to the secular authority, in the case of the KSA, to the monarchy. Does their (preeminent) view mean that SAMA must be subject to
ultimate control by ministerial appointees, who in turn owe allegiance to the Crown? You refer to Sharia law largely by reference to the prohibition on charging
interest, e.g. on page 18. Is there Qu’ran-based legal authority that might be used to argue for greater powers for SAMA? You refer to Allah being the owner of all
wealth and emphasise societal needs on page 33. This is very interesting. Might you not embed this point more centrally in your thesis as authority for your arguments?
On page 54 you revert back to a discussion of Sharia Law, posing the question as to whether it is an obstacle to reform, again linking the difficulties as being those
prohibiting SAMA from charging interest (riba). You also refer to the Banking control Law being not susceptible to amendment for fear of undermining Sharia law. But if
Sharia law has overarching societal goals then is this an element that might favour your arguments for reform? These aspects need to be addressed comprehensively in
one section and should be explored more fully, linking the points to your thesis.
4) Federal Reserve, the BoE (and growth): on page 73 you still seem to imply that the Federal Reserve is different from the BoE in that the former’s policy remit
includes fostering growth and employment. However, on page 84 you refer to the BoE’s central role as “ensuring that the economic policies of the UK government are
supported” and that “growth is fostered.” On the same page you again refer to its independence. To the extent that its policies are linked to overall government aims,
does this suggest that its independence is not wholly complete? As regards growth and the role of central banks, you link the two explicitly on page 97 and on pages 16
and 25 refer to the BoE as having achieved this as a consequence of its independence. On page 19 you assert that if SAMA is independent it “will achieve tremendous
growth” as has been the case in the UK and US. On page 110 you refer to the deregulation of the BoE as being the cause of London’s emergence “as the financial hub of
Europe.” Whilst you cite Mwenda as authority for this claim, as I have indicated before, this seems most unlikely. London largely achieved this pre-eminence due to
historical factors and the deregulation introduced by the Financial Services Act 1986.
5) Growth: on a number of occasions you refer to SAMA’s independence as being a necessary precursor to overall economic growth. You also refer to growth as being more
attainable if the law relating to riba is relaxed (page 55). As indicated above, elsewhere you refer to growth being the result of central bank independence and that
the UK’s growth is directly referable to the BoE’s independence. We have discussed this on a number of occasions before and I do not think the two necessarily relate.
China has a central bank that is manifestly not independent, yet China has achieved spectacular growth. Conversely, the ECB is supposed to be independent, yet the
eurozone has almost non-existent growth. We have also discussed the fact that the growth in the UK may indeed be buoyed up by the BoE and the UK government together
enjoying the degree of independence that has arisen from not being in the euro and so macro-economic circumstances may be crucial (not just central bank independence).
Your assertions need to be substantiated in more detail. On page 49 you refer to the bulk of economic activity being oil-driven and with oil at $40 a barrel, obviously
this will have a major impact on growth. This does indeed support your thesis and the need for diversification in the economy and this needs to be brought out more
6) BoE as your chosen model: We have discussed before the issue of why the BoE was chosen as your comparator (and also see paragraph 4 above). I have urged you to
substantiate your choice fully. The thesis still contains rather broad assertions, such as that on page 59: “The Bank of England is the model in which major central
banks have been based. It can therefore be taken as a model for other central banks including the SMA.” I still find your arguments in the early sections for choosing
the BoE rather weak
7) Structure: The thesis has evolved over time and inevitably there are some structural issues with chronology and repetition e.g. regarding the crash of 2008 on page
111, references to political meddling on page 116 and late definitions of SAMA (e.g. on page 122). You need to revisit the chapters, pulling the material together into
sections that contain the relevant themes separately, e.g. the role of a central bank, the nature and importance of central bank of independence, the crash of 2008 and
how it was addressed in the UK and KSA etc. You also refer to interviews that are going to take place in the methodology section, but my understanding is that these
have already taken place. However, you do not refer to them again in the thesis.
8) Corporate governance: this is referred to periodically (e.g. pages 14, 15) but is never satisfactorily incorporated into the thesis or fully related back to central
9) Page (40-231) Cooperate Governance, explain how that link to the thesis? Why?
10) Page (48) SAMA references add to the lists on that page.
11) Page (111) discusses the historical points and connecting to the related topics.
12) Reformatting the draft file by considering the introduction and conclusion as chapters, so chapter 1 will be the introductions with subtitles and headings, the
change the numbering of the chapters. At the end the conclusion will be chapter 6, so the total will be 6chpters on the whole draft.
12) Please highlighted any new words or changes on the revised draft to be easy to compare between the current and revised draft.
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