A credit lens: implementing twin peaks

Abstract

This article looks at credit, linked to both debt and culture, to outline challenges in methods of regulation and its assessment. It takes the proposed architecture of credit regulation within South Africa’s coming “twin peaks” structure, refracted against some Australian experiences, to ask what questions should be posed and what methodologies are available to assess credit regulation in a new regulatory regime. The article argues there may be gaps between existing cultural norms, the behaviours required for a new regulatory regime, and community expectations of what regulation may be expected to achieve. Understandings of the regulatory task, and accountabilities of the regulatory regime become more important. This is particularly so when a new regulatory regime incorporates already established parts and some existing values in a staged approach. It argues that a culture of cooperation and coordination is key to maintain both access to credit as debt, and credit as trust.