Fiat Money?

Once upon a time, hundreds of years ago, money had intrinsic value.  Coins were minted in gold or silver.  Money was then a physical item.  This money got its value from the worth of the bullion it represented.  If the coin said it was worth $1.00, then it had a dollar’s worth of gold in it.  This was straightforward.  But the weight of the coins was inconvenient for carrying around.

First the Knights Templar during the time of the Crusades, and then various governmental affiliates began to issue paper notes to the value of the gold or silver they kept in their vaults.  They promised they held gold or silver to the value of the notes they issued.  Those notes were said to be “backed” by gold or silver.  Not every country made sure their notes were backed by bullion.  Such currencies were very unstable and frequently collapsed.

In 1971 and 1972, the US and British governments moved away from backing their currencies with bullion.  Like other issuers of most modern paper currencies, they began to print money as needed.  The Eastern Caribbean dollar is a classic example of a currency that is not backed by gold or silver.  There is no requirement for the notes of the EC Central Bank to be backed by either bullion or foreign currency.

These unbacked currencies are said to be “fiat” currencies.  “Fiat” is a Latin word that can be translated as “let it be done”.  Our currency only has a value because the Eastern Caribbean Central Bank says it has that value.  The Central Bank simply said, “Let these bank notes we are issuing have the values we print on them.”  Unlike money backed by gold or silver, there is no real value to fiat money in itself.  Once everyone accepts the fiat of the Central Bank, all is in order.  Problems only arise when people begin to have doubts about the value of the currency.

One result of this fiat system is that currencies risk losing value due to inflation.  They even risk becoming worthless in the event of hyperinflation.  In some countries, when the people lose confidence in the value of their money, inflation can double in a single day.  There is then no acceptable medium of exchange.  People refuse to accept the currency, and all commerce collapses or turns back to barter.

Has the British colony of Anguilla found a way to issue fiat money?  I ask the question because over the past two years the Government of Anguilla (GoA) appears to have been printing money to meet the government’s every need to look good.  Its expenditure is not connected to how much money it can raise.  I am not sure that is legal or sensible.  Why have the Foreign and Commonwealth Development Office (the FCDO) and the Central Bank permitted this financially irresponsible state of affairs to develop unchecked?

Governments throughout the Caribbean region notoriously view their Social Security Fund as a cash cow to be raided at every emergency.  Anguilla is no different.  As part of the “banking resolution” back in 2016, our Fund took its first major hit.  Government borrowed over EC$200 million from our Social Security Fund to buy the two cash-strapped local banks.  I am not aware of any effort to repay any part of this borrowing.

In 2020, at the height of the recent pandemic, government raided the Fund again.  Contrary to the purpose of the Fund, government used it to pay unemployment benefits to every unemployed person in Anguilla who had not contributed to Social Security. or who had not contributed the required fifty weekly payments.  These monthly payments were at first EC$800.00 and then EC$1,000.00.  This freeness went on for over a year.  Social Security was encouraged to create a programme to pay the same unemployment assistance to persons who were social security contributors.  All these unlawful payments were, I understand, legalised after the event by having the House of Assembly approve them.

The Fund has now been sucked dry.  There are few alternative sources of ready money left for government to give away.

According to an article in The Anguillian Newspaper last week, a recently concluded Social Security conference saw the experts recommending that we increase contributions from 10% to 12% as the Social Security Fund has almost been depleted.  I am not surprised.

Starting in February 2022, the Russian/Ukrainian War resulted in sanctions and blockades.  The prices of goods skyrocketed.  The GST Act came into effect in mid-2022.  The result was further rising prices.  Inflation is sky rocketing in Anguilla.

To help with the rapidly rising cost of living during the past year, GoA is imitating the US and UK governments.  It has been issuing EC$500.00 food vouchers to every person over 70 years of age in Anguilla.  This money was not budgeted for.  Indeed, there was no public consultation on the need to give away money.  There was no discussion of the merits and demerits of giving the money to every 70-year-old in Anguilla.  There was no public discussion at all.  The news item on Radio Anguilla to the effect that GoA had taken the decision to grant this largesse caught us all by surprise.

GoA simply announced one day that every person in Anguilla over the age of 70 was entitled to go to the Inland Revenue Department (the IRD) and collect a voucher for EC$500.00.  The voucher could be presented in any grocery for food or liquor.  It was later announced that we could go back to the IRD and collect a second EC$500.00 voucher.  So, the total amount of the gift to each of the over-70s amounted to EC$1,000.00.

My guess is that there are about 1,000 persons over 70 years of age in Anguilla (local and ex-pat).  That means that these two unauthorized gifts must have cost about EC$1 million.  This money was not in the budget.  Perhaps this unauthorized expenditure from the Consolidated Fund was subsequently made lawful by an Act of the HoA.  That would be easy to do as the GoA controls the House (most of the members of the HoA are either cabinet ministers or junior ministers in the GoA.

Subsequent authorisation of an illegal government payment (if that is what it was) is not the point.  When the budget was prepared, no thought was given to raising the money to make these gifts.  It was not a budgeted item.  It appears GoA was permitted by the FCDO to spend unlimited amounts of money that was not budgeted.  I suppose because they had done the same thing in the UK, they could hardly object.  I am not sure I approve.

The next unauthorized government giveaway was a surprise gift of two amounts of EC$500.00 paid to each household account with the electricity company (ANGLEC).  This money was deposited directly to ANGLEC.  Note that this handout was not limited to Anguillians.  Nor were the recipients required to be certified as “needy” of financial assistance.  Nor was it limited to persons aged over 70 years.  It was paid indiscriminately to all residential accounts at ANGLEC, foreign or local, retired or working, millionaire or indigent.  I am not sure I approve.

The gift was ours whether we wanted it or needed it.  We had no say in the granting of this largesse.  If we objected to it as being illegal and unnecessary in our case, we could do nothing about it.

It was not a budgeted expenditure.  It was not authorised by any Act of the HoA.  Nor was it a negligible sum of money.  There must be some 5,000 households in Anguilla.  The cost of this gift, according to my calculation, should amount roughly to EC$5 million.  In my view, not being paid to needy residents, it was a blatant case of vote-buying for the next general elections.  Will it work?

All the evidence is that Western economies are presently in an economic recession.  By next year, consumer confidence is forecast to collapse.  The UK and other major economies will go into a depression.  Unemployment will increase substantially.  The real value of wages is expected to fall by about 50%.  Tourism will temporarily dry up in Anguilla.  Hotel companies will collapse.  Fewer workers will be employed.  Poverty will spread over the island.  But there will be no more gifts of free money to bail us out.

And now we learned last week that GoA will be issuing another unauthorised EC$500.00 food voucher to all seniors, millionaire or otherwise, on the island.  This generous gifting could not happen without the express approval of the FCDO.  They must by law sign off on all major expenditure by GoA.  It is as if the FCDO have given GoA permission to print our own fiat money.  Otherwise, GoA could never find the wherewithal.

But what will the consequences of all this munificence be?  We suspect one of them will be increased taxation.  At the end of the day, the money must come from somewhere.  The ministers are not giving away their own money.  It is more likely than not the workers of this country who will have to pay for all the handouts to the seniors.

Cowrie shells were currency in certain parts of the world many years ago.  With inflation high and about to increase, and given the rate at which the dollar’s value is sinking, should we be thinking about converting our savings into cowrie shells before the end of the year?

ECCB Agreement Amendment

The ECCB (Amendment of Schedule) Order, 2016

[1]     Prior to the invention of our EC dollar in 1965, and since 1935, the name of our currency was the “BWI dollar”.  Then, our islands entered into the Eastern Caribbean Currency Agreement.  This established the Eastern Caribbean Currency Authority (ECCA), with headquarters in Barbados.  ECCA was authorised to issue the new EC dollar.  Barbados withdrew from the Currency Union in 1972.  Our governments decided to move ECCA’s headquarters to St Kitts.  Gradually, most of our countries became independent.  The name BWI dollar seemed obsolete.  The name was changed to the “EC dollar”.

The Agreement

[2]     In 1981, the Organisation of Eastern Caribbean States (the OECS) came into existence with the signing of the Treaty of Basseterre in St Kitts.  The following year, 1982, in Trinidad, most of our OECS governments^[1] signed the Eastern Caribbean Central Bank Agreement (the ECCB Agreement) bringing an end to the old ECCA.  The ECCB Agreement established the Eastern Caribbean Central Bank (the ECCB) with its headquarters in St Kitts.  Anguilla signed up and became a full member in 1987.

The Act

[3]     As every High School CAPE Law student knows, a treaty is not a law.  A treaty may be a source of a law.  A treaty or convention is an agreement which may be binding on governments among themselves, but it does not affect you or me.  To make it a part of the law of the country, an Act of parliament to that effect must be passed by the local legislature.

[4]     In 1983, though Anguilla was not yet a full member of the Currency Union, our House of Assembly passed the ECCB Agreement Act, 1983.^[2]   This enactment made the ECCB Agreement a part of our law. The Act is a very short one.  It consists of just 6 brief sections.  The bulk of the Act is taken up by the ECCB Agreement.  This is set out as a Schedule to the Act.  Section 2 of the Act provides that the Agreement is to have the force of law in Anguilla.

[5]     There is provision in the Agreement and in the Act for the members of the Currency Union to amend the Agreement.  Section 4 of the Act lays down the procedure to be followed.  The section says that, once the Agreement is amended by the governments, the Governor must bring the amendment into law in Anguilla by signing an Order published in the Official Gazette.  As the Constitution provides,^[3] once the Executive Council (Anguilla’s Cabinet) agrees to take a step, and the Governor is named in the relevant law as the official who must sign, then the Governor must sign it for and on behalf of the Government of Anguilla.  It is the act of the government, not a personal act of the Governor.

[6]     The senior policy making body of the ECCB consists of the Monetary Council.  This is made up of the eight Ministers of Finance of the participating governments.^[4]  Given this management structure, there is always a risk of paralysis.  An action that the ECCB might propose for the benefit of one member might be vetoed by another member.  In late 2007, our sub-region was seriously affected by the world-wide banking crisis.  The ECCB found itself powerless to intervene in the banking crisis in the way a central bank is expected.  It soon became apparent that the ECCB was ineffective in acting as a lender of last resort for any member country that might get into difficulty.  Change in our system of banking supervision was desperately needed.  The Central Bank sought advice from the World Bank and the International Monetary Fund on the reforms that had to be made.

[7]     In 2012 the Basel Committee on Banking Supervision issued new Core Principles for Effective Banking Supervision.  These Core Principles are the minimum standards by which the prudential regulation and supervision of banks and banking systems around the world are judged.  There are in all 29 Core Principles^[5] for effective banking supervision.^[6]

[8]     The first of them is that there must be a suitable legal framework for banking supervision.  A properly established Central Bank must be empowered to license banks, conduct ongoing supervision, address compliance with laws, and take timely corrective action to address safety and soundness concerns.  At the time of the financial crisis, the local Ministers of Finance were the licensing authority for banks of the sub-region, not the Central Bank.  Our Central Bank, the ECCB, failed the first of the Core Principles.

[9]     The second Core Principle covers the independence and legal protection required for all Central Banks.  For a Central Bank to be recognised as effective, it must possess independence and autonomy.  Local law must provide protection for the Central Bank and its staff against lawsuits for actions taken while discharging their duties.  No person should be permitted to bring a lawsuit which can block a Central Bank in carrying out its banking supervision.

[10]   That does not mean that the Central Bank is immune from liability.  If a citizen is harmed as a result of any wrongful action taken by the Central Bank, he may still file a lawsuit.  If he has suffered loss, he will be entitled to be paid damages or compensation.  But he cannot get an injunction that will stop the Central Bank from carrying out its supervisory functions.  It was evident to the international banking community that our Central Bank had no such powers or protection under the existing Agreement and local legislation.  Our Central Bank failed the second of the Core Principles.  The ECCB simply did not meet the basic standards expected of a Central Bank.

[11]   The Monetary Council received and considered a number of reports^[7] and recommendations from consultants.  These were hired to advise on steps needed to upgrade the ECCB.  It was imperative the ECCB should pass the Basel Committee’s tests for effective banking supervision.  Finally, the Monetary Council agreed to a number of reforms.

[12]   In sum, our governments agreed to take eleven steps to bring our Currency Union up to international standards.^[8]  Among the first of the reforms agreed was the need to amend the ECCB Agreement to give the Central Bank the power to intervene and take necessary action to prevent the collapse of a failing bank and to restructure its business and capital base.  Other steps included replacement of the outdated Banking Act with a modern Banking Act to reflect the new banking regime.  The new Banking Act was passed by our House of Assembly and became law with the Governor’s assent on 18 April 2016.

The Amended Agreement

[13]   At its 81st meeting on 24 February 2015, the Monetary Council agreed that legislative and regulatory reforms were needed to protect the ECCU banking sector.  Then-Chief Minister, Hubert Hughes, signed up to the Eastern Caribbean Central Bank Agreement (Amendment), 2015 on behalf of Anguilla.  This amendment to the Agreement would not become part of our law until an Order was signed by the Governor incorporating it into our law as provided in the ECCB Agreement Act.^[9]

The Amendment Order

[14]   On 22 April 2016, Anguilla’s Governor duly signed the ECCB Agreement (Amendment of Schedule) Order, 2016.^[10]  By this legislative act, the Governor, as authorised both by our House of Assembly in the provision of section 4 of the ECCB Agreement Act, and by the Executive Council led by Chief Minister Victor Banks, duly brought into law the Amended Agreement signed the year before by Chief Minister Hughes.^[11]

Conclusion

[15]   Anguillians should be proud that we have finally, if belatedly, shown ourselves to be supportive of the new regulatory standards which the international banking community expects of our banking sector.  We were previously viewed as wild-west bankers, not subject to proper regulation by an enabled Central Bank.  We cannot be viewed in this light any longer.  We now conform to international standards.  Our banking sector can stand equal with the rest of the world.

---

[1]      Not Anguilla, whose membership was still vetoed by the St Kitts Government.

[2]      Revised Statutes of Anguilla, c E5.

[3]      Section 28 of the Anguilla Constitution Order, 1982.

[4]      The current members of the Monetary Council are described here: http://www.eccb-centralbank.org/About/monetary.asp

[5]      Previously 25 in number.

[6]      Which I have previously detailed in an article you can read at: http://donmitchellcbeqc.blogspot.com/search/label/Core%20Principles

[7]      Copies of which are available to read on the ECCB website: http://www.eccb-centralbank.org/

[8]      I have described these 11 essential steps in an article on my website which you can read here: http://donmitchellcbeqc.blogspot.com/2015/11/banking-reform-in-anguilla-2015.html

[9]      The Hubert Hughes administration published the Amendment to the Agreement in February 2015 before the general elections which brought the Victor Banks administration to power.  It can be seen on the Government of Anguilla website here: http://www.gov.ai/documents/ag/ECCBLIB-678364-v1-ECCB_Agreement_Amendment_2015_-_Final_Version.pdf

[10]   Local Statutory Instrument No 20/2016.

[11]   What is not clear is what motivated then-Chief Minister Hubert Hughes to attempt to pass the very same amendment to the Agreement into law on 25 October 2013 using the incorrect procedure of rushing an Amendment Act through the House of Assembly with all three readings taking place on the same day in the absence of the three Opposition members and the Ex-officio members of the House.  No one in Anguilla seems to know if the Governor ever contributed to the debacle by assenting to the Act.  The story is related in The Anguillian Newspaper here: http://theanguillian.com/2013/11/opposition-asks-governor-not-to-sign-acts-says-house-sat-without-a-quorum/  The level of incompetence demonstrated by the then Attorney-General’s chambers in drafting and approving this law and procedure is nothing short of astonishing.

Anguilla's Banking Crisis

Anguilla’s Banking Crisis 2013-2015 and the new ECCB Banking Bill, 2015

[1]     Listening to the talk on the radio shows these days, one gets the impression that some Anguillians are confusing Anguilla’s banking crisis with the new draft Banking Act, 2015.  In fact, the one has practically nothing to do with the other.  Let us keep the two issues completely separated in our discourse.

The new ECCB Banking Bill 2015

[2]     We know how the new Banking Act came into existence.  It is in no way derived from the Anguilla banking crisis.  It pre-dates the Central Bank take-over of National Bank Ltd (NBA) and Caribbean Commercial Bank Ltd (CCB).  To repeat what I have written elsewhere, the new Act is the result of the region’s international obligations reflected in the Basel Committee on Banking Supervision’s Core Principles for Effective Banking Supervision, issued in September 2012.[1]  The Core Principles are the minimum standards applied to judge how sound are the prudential regulation and supervision of banks and banking systems in all the regions of the world.  They are the benchmark used by the IMF and the World Bank for testing the quality of supervisory banking systems.

[3]     The new Banking Act, and the ECCB Agreement Amendment from which it comes, have a regional reach.  They establish a single banking space within the Eastern Caribbean Currency Union.  Unlike as under the old Banking Act, a bank licensed in one State will now be able without restriction to open a branch in another State.

[4]     The Central Bank is under an international obligation to implement the Core Principles in our region.  It is required to ensure that the regulatory framework, ie, the standards it demands of itself, the banks it regulates, and the financial arrangements of the governments who make up its board of directors, the Monetary Council, meet the minimum standards established by the Core Principles.

[5]     I have explained elsewhere that the draft Banking Act is a product of these international and regional obligations.[2]  The new Act provides a regime which international regulators will recognise as belonging to a well-regulated banking system.  It was drafted long before the Central Bank moved in on NBA and CCB.

[6]     We have been warned that the deadline for passing the new Banking Act in every State in the Eastern Caribbean runs out at the end of December 2015.  Failure to pass the new Act in Anguilla on schedule will not only affect indigenous banks, but will poison the international banking environment for the international banks that do business in Anguilla.[3]

Banking crisis

[7]     In August 2013 the Central Bank sent in a conservator for the two indigenous banks in Anguilla.  They are, the NBA with assets at the time of about EC$1 billion, and CCB with assets of about EC$700 million.  The explanation given by the Central Bank at the time was that the two banks were illiquid and there was a concern they might fail and that the depositors’ funds would all be lost.

[8]     At some point, it was suggested that there was a hole of some EC$600 million in NBA’s assets.  It has never been clear to me what shortfall there was in CCB’s assets.  Additionally, of the EC$1 billion in loans, some 50% were non-performing and of doubtful value, given the depressed market that exists for their securities.  Because of the Aliens Landholding Regulation Act (ALRA), there is in practice no market in the region or internationally.[4]  Under the new regime, ALRA is about to be amended or repealed.

[9]     So that, if all NBA’s depositors came to the bank and demanded their funds back, and if the conservator could sell all the loans and other investments, then, from what we are being told, there would be a shortfall of some EC$500 million of depositors’ money.  Some EC$500 million might be raised, but there would be EC$500 million short to be repaid.  Indeed, if there was a run on the bank, given that most of the depositors’ funds are tied up in loans, we were told that the bank would soon run out of cash and would have to close.

[10]   This was the banking crisis that the conservator was allegedly sent in to solve in August 2013.  We were told at the time that the idea was to find a solution to the liquidity problem, and that as soon as the banks were returned to good health things would be returned to normal.  No one seems to have realised that in recent weeks this promise has been brushed under the carpet.

The Resolution

[11]   The Chief Minister of Anguilla has, in repeated broadcasts on radio over the past two weeks, explained that he has decided on the resolution of the banking crisis.  He is going to transfer all the bad loans (allegedly some 50% in both banks) to a new regional corporation to be established by Act of Parliament in each of the States and Territories giving effect to a regional Treaty.  This regional company will be known as the Asset Management Company Ltd (AMC).  This company will renegotiate with defaulting borrowers and, as a last recourse, sell their securities, locally, regionally and internationally, with ALRA amended or repealed.  The participating governments will share in the profits of AMC pro rata.  We in Anguilla have no further interest in the bad loans sold, transferred or given (it is not clear which) to AMC.

[12]   Then, the Chief Minister is going to merge the two banks, NBA and CCB.  Lawyers know what the merger of two companies involves.  Typically, and in this case essentially, it involves the formation of a new banking company, let us call it the National Caribbean Bank of Anguilla Ltd (NCBA).  The conservator will transfer all the remaining assets of NBA and CCB, including the existing customers and depositors, to the new bank, NCBA.  These assets will presumably include the profitable subsidiary companies of NBA and CCB.  The new bank will have one shareholder, the government of Anguilla.  The government will be either borrowing a large sum of money to invest in the new bank or putting up a large guarantee to stand behind the depositors, it has not been made clear which.  There will be no other local shareholders in NCBA.  The new board of directors will be appointed in the usual way by the sole shareholder.  Let us call them the government directors of NCBA.

[13]   No one is giving any thought to what is to happen to NBA and CCB after the merger.  NBA has some 3,500 shareholders and CCB some 75 shareholders.  Their boards of directors have already been dissolved by the Central Bank, and do not exist anymore.  Their shareholders remain on the books, hoping that one day someone will tell them what is to happen to them.  Well, I am prepared to tell them now, based not on anything anyone has informed me, but on what little I know of mergers and acquisitions.

[14]   Until approximately one week ago, I harboured a faint hope that the second recognised way to carry out a merger of the two banking companies was being contemplated.  That occurs when one of the two banks buys up the assets and takes on the liabilities of the other.  There is then said to be an acquisition, and the two banks are merged by one having purchased the other.  It happens every day.  But, over the past week I became disillusioned about that solution.  It was clear that, with the AMC purchasing all the bad debts of the two banks, there was no plan to accomplish the merger by purchase.  That left only merger by selling the assets of both banks to a new bank.

[15]   The only sensible way this resolution can work is, after the bad loans have been transferred to the AMC, and the good loans have been transferred to the NCBA, to simply abandon the old banks.  They serve no further purpose.  After a year or two, the Registrar of Companies will strike them off the Register for non-compliance with the Companies Act requirement for filing of annual returns.  That will be the end of them.  The old banks will fade away into the sunset.

Red herring

[16]   The controversy in the media over the new Banking Act is a red herring obscuring the sad fate of the two local banks and their many thousands of shareholders.  The only bank the new Banking Act will regulate is the new government-owned bank, NCBA.  The old shareholders in NBA and CCB will have no interest in the new bank.  The two old banks will never be regulated by the new Banking Act.  The new Act will never in any way affect NBA or CCB.

[17]   The shareholders and directors who are presently campaigning against the new Act, on the basis that its provisions are draconian, are misled.  The fact that the new Act bars injunctive relief against the Central Bank, as they complain, is irrelevant.  The fact that the new Act bars the right of anyone to sue the Central Bank is irrelevant.  Only the new shareholder of NCBA (the government) and the new government directors have any reason to complain about the contents of the new Act.  There is no provision in the new Act that will affect the present shareholders, or the old directors, or their old banks, the NBA and the CCB.  The new shareholder and the government directors are the only ones who will be affected by the new Act.  They are not complaining.  For this reason, the demands of the old shareholders to have the new Act amended are misplaced.

[18]   What is incontrovertible is that the passage of the new Banking Act into law is a necessary pre-condition for the creation of the new bank which is intended to be licensed under the new regime.  And, the formation of the new bank is urgent.  The deadline is rapidly approaching.  The Eastern Caribbean Currency Union is, it seems, at risk of falling off a cliff if the new standards are not put into law before the deadline.

[19]   Meanwhile, Anguilla’s corresponding banking relationships are at risk.  The new bank will not be able to enter into any corresponding banking relationships with European and North American banks unless the new Banking Act is in place.  Indeed, if the new bank is not put in place in a matter of days, we are told that the existing international banks providing banking services in Anguilla (Scotia Bank and First Caribbean Bank) will likely lose their existing corresponding banking relationships.  All relations between Anguilla’s banks and international banks will cease.  It seems that this is the principal reason for the haste with which these measures are being put in place.  It is a pity that nothing was done during the past two and a half years.

[20]   It may be unfair to suggest that another reason why nothing was done in the past two and a half years is that both the past government and the present government were concerned that all hell would break loose if the Anguilla public (most of whom are shareholders in one bank or the other) were given enough time to absorb the consequences of the resolution of the banking crisis that is now being put into effect.

[21]   As I have written elsewhere,[5] it is unfortunate that no sufficient effort was put into rescuing the two existing banks.  An insertion of new capital, and a dilution of the existing shareholders’ equity, as was done in the USA and the UK, would have been immensely fairer.

[22]   And, finally a word of caution.  All the explanation I have given above of what the Chief Minister is going to do to the old banks and to the new bank is based on pure speculation and on what is reported in the media.  But, having practised for many years, mainly as a corporate lawyer, and having been involved in the merger of several companies over the years, I know how it is done.  There may still be some surprises.

[23]   Whatever happens, it is essential that the new Banking Act be put in place in Anguilla without amendment and at the earliest possible time.  The consequences of our failure to do so will be nothing short of catastrophic, not just for Anguilla but for the region. 

[24]   Indeed, the British Government, we are told, have warned our government in writing that if the banking crisis is not resolved, and the new Banking Act in place before mid-Autumn, they will move in and by Order in Council impose a solution that will be immensely more drastic than anything that the ECCB proposes.  We have mere days left to act.

---

[1]       This 85 page document can be found on the website of the Bank for International Settlements here: http://www.bis.org/publ/bcbs230.pdf

[2]       http://donmitchellcbeqc.blogspot.com/2015/11/a-dictatorial-central-bank.html

[3]       Peter Queeley of Montserrat is a banker, which I am not.  He has explained it all clearly in this article: http://www.discovermni.com/2015/11/opinion-the-proposed-new-banking-act-and-its-implications-for-montserrat-part-2/

[4]       http://donmitchellcbeqc.blogspot.com/2015/10/aliens-landholding-regulation-act_22.html

[5]       http://donmitchellcbeqc.blogspot.com/2015/11/banking-reform-in-anguilla-2015.html