The Twin Peaks Model has several drawbacks. A primary concern is the risk of unclear boundaries for institutions that are subject to dual regulation, which requires consistency in legislation and structuring for clarity (JCFSB, 2010). This was an issue noted in the UK by the Financial Stability Board (2013). Additionally, there are worries about inadequate coordination and cooperation between the regulatory bodies, which could hinder effective information sharing if not properly managed (IMF, 2013). When central banks implement the Twin Peaks Model, conflicts may arise between them. Llewellyn (2006) noted that if a central bank balances both prudential regulations and monetary policy, it might resort to loosening monetary policy to mitigate systemic risks during economic downturns. This scenario could create overlapping internal information within the central bank, leading to unnecessary synergies (Van Hengel et al. 2013). Despite these risks being manageable, they must be taken into account when applying the model (New Zealand Treasury, 2010).
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There are, however, also some disadvantages attached to the Twin Peaks Model. The biggest
concern is the possibility of creating blurred boundaries with double regulated institutions. To
ensure clarity between the regulators consistency of legislation and structures must be a firm
foundation (JCFSB, 2010). This was one of the issues the UK faced, according to the Financial
Stability Board (2013).
Another major concern was the potential risk of poor coordination and cooperation between
the regulators in charge. This could potentially lead inadequate sharing of information and
coordination, if not supervised in the right manner (IMF, 2013). Considering how the Twin
Peaks Model is modified and put into practice, Central Banks may have disputes between each
other. Llewellyn (2006) explained that when a central bank oversees both prudential
regulations and the monetary policy, there might be a high risk of easing monetary policy in an
attempt to try and prevent systemic risks, in hard economic times. There may also be an overlap
of internal information with the central bank, causing unnecessary synergies (Van Hengel et
al. 2013). Even though these are manageable risks, they still need to be considered when
implementing the model (New Zealand Treasury, 2010).
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