QE as an economic policy tool - what does it do and how
should we use it?
Speech given by
Dave Ramsden, Deputy Governor for Markets and Banking
Peter Sinclair Town Hall lecture, University of Birmingham
17th February 2021
With thanks to Tom Smith, Amy Lee and Jon Bridges for their assistance in preparing these remarks,
and to Bank colleagues including Andrew Hauser, Maggie Illingworth, Mike Joyce, Nick McLaren,
Rhys Phillips, and Beth Blowers for their many helpful comments and suggestions.
1
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Introduction
It's a pleasure to be speaking today at the
University of Birmingham, and an honour to be doing so at the
third Peter Sinclair Town Hall lecture.
My focus today is on quantitative easing - QE for short - and its use as an economic policy tool.
The Bank of England's
internal Independent Evaluation Office (IEO) published its own evaluation of QE
earlier this year, where it noted that "there remain open debates about how QE works in different states of
the world, its broader interlinkages and its potential limitations".1
What I want to use my lecture for today is to
set out my own views on QE as a policy tool, as well as contribute some thoughts to some of those debates.
Before I do that, though, I want to start with my own recollections of Peter. Tim Harford began this lecture
series last autumn by noting that he was an economist because of Peter, as is true, I am sure, of many
people joining us today. I can actually take it further. I was first enthused by economics by one of Peter's
students, the late Ken Durham, like Peter also a great teacher and educator, who taught me economics at
school and encouraged me to apply to Brasenose College.
The only bit of the whole application process to Brasenose which went well was my economics interview with
Peter, which I remember as much more of a friendly conversation than an interrogation. That set the tone
and started an unbroken trend for every one of my interactions with Peter over the next 37 years, whether in
Brasenose, or over one of his famed pastoral teas in the café in the Oxford covered market, at one of the
seminars he would invite me to give to his students at the Bank's CCBS while he was its Director, through to
more recently in the Bank of England since I started working there. Everyone who knew Peter has their own
fund of these stories and you can and should read many of them in the online Condolence Book set up by
the University of Birmingham.
Peter's
To give one personal memory of wonderfully warm and encouraging approach: in our final year at
Brasenose we each had to do a long essay and present it to the rest of the class. I wrote mine on the
European Monetary system, then in its first phase; it was my first exposure to analysing an active policy tool.
I recall that it turned out to be rather heavy on institutional detail about the EMS and rather light on the
economics and efficacy of exchange rate regimes. At the end of my presentation Peter, first, went out of his
way, as he always did in response to any presentation, to compliment me on all the efforts I had put in. Only
after that, did he then, in his characteristically gentle but incisive way, set out several avenues I might follow
in developing my analysis of nominal versus real adjustment. In doing so Peter drew on a whole host of
models that he could call on from memory, some of which I'm sure found their way into
references and
Modern International Economics, the textbook Peter wrote with Shelagh Heffernan, his first wife, who died in
2010.
1
IEO's report the Bank's
The is available on the Bank of England website, as is response.
2
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Peter seemed to be focused on the most important and relevant policy issues of the time he always wanted
to learn more about the world and to suggest ways that economics and economists could improve it. And he
Peter's
conveyed that enthusiasm and ambition to each student intake and to his colleagues. review of
"What's the Use of Economics", the book of proceedings from a conference organised and edited by Diana
Coyle, another former student who gave the second of these lectures, held at the Bank of England nearly a
2
decade ago, is Peter at his kaleidoscopic best and as relevant now as when he wrote it.
For me as an undergraduate student in the early 1980s it was incredibly stimulating to be learning from Peter
about Keynes', Hicks' and Leijonhufvud's contributions to disequilibrium economics, all framed by Peter's
own quantity rationing exposition of multiple equilibria. It was even more exciting to be taught by
someone who was writing about the real-world economic problems of unemployment and how policy could
-
help to achieve a better equilibrium Peter penned a comprehensive overview article with Derek Morris in
the second edition of OxRep in 19853 which is still a very good read today.4
It should therefore come as no surprise that one of the many other topics that Peter turned his prodigious
mind to was QE and monetary policy. His 2017 NIESR paper with Bill Allen examined the shift from the
"old normal" of crisis monetary policy to the "new normal" of QE and forward guidance, as
pre-financial well
"future normal" for
as engaging seriously with what a monetary policy might look like.5 That is a framing I will
use for this lecture in setting out my own views of QE as a monetary policy tool, and then focusing on two
other policy debates highlighted by the IEO review, the links between QE and government financing, an
issue Peter also considered6, and the links between QE and climate change.
The Bank of England and its balance sheet
I'll come on to the details of what exactly QE is and what uses it
has as a policy tool, including over the last
11 months in response to the Covid pandemic. But I want to start by considering a more general question,
which is the question of what central banks are actually for. That's because I don't think you can
answer the
question of how to use a tool without first knowing what you want the tool to do.
For the Bank of England, the answer to that question is clearly set out in the statutory objectives laid down
for us by Parliament7: our mission is to promote the good of the people of the United Kingdom by maintaining
monetary stability, defined by the Government as low and stable inflation with a target of 2% (and subject to
that supporting the Government's economic policy and growth and employment objectives);
and financial
2
of Professional Economists'
Available on the Society website.
3
Peter was the managing editor of OxRep.
4
"The unemployment problem in the 1980s", Derek Morris and Peter Sinclair, Oxford Review of Economic Policy, vol. 1 no. 2 (1985).
5
William Allen and
"Monetary policy normals, future and past", Peter Sinclair, National Institute Economic Review, vol. 241 no. 1 (2017)
6
Peter Sinclair and Colin Ellis, Oxford Review of
"Quantitative easing is not as unconventional as it seems", Economic Policy, vo. 28 no.
4 (2012)
7
Specifically, in the Bank of England Charter 1694, the Bank of England Act 1998 and the Banking Act 2009.
3
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stability, defined as the resilience of the UK financial system as a whole so that it can serve UK households
and businesses in bad times as well as good.
What makes the Bank of England the right institution to deliver those objectives? The answer is that our
balance sheet is what makes us special and gives us the economic policy tools we need to be able to do
that. Our liabilities serve unique functions at the heart of the financial system: central bank money, whether in
central bank "reserves" - -
the form of bank notes or the deposits held with us by financial institutions
provide the ultimate means of settlement for all sterling payments in the economy. And we are the sole
institution with the power to create sterling central bank money.
That power provides us with a wide range of tools that we can deploy in pursuit of our monetary and financial
stability objectives (as summarised in Figure 1).

The importance of reserves to the financial system means that Bank Rate, the interest rate that we
on firms' reserve accounts, is the single most important interest rate in the UK. Changes in Bank
pay
Rate influence interest rates across the economy including those charged by commercial banks and
those in financial markets. That in turn affects aggregate economic demand and ultimately inflation.
So having reserves on our balance sheet gives us a powerful tool that we can use in support of
monetary stability. Indeed in the years running up to the Great Financial crisis in 2007-08 this was
- in Peter's terminology, the "old normal" for
the main monetary policy tool used by central banks
policy.

A second way we can use the balance sheet in support of monetary stability is by using reserves to
buy or sell other financial assets in the open market; that lets us directly influence market interest
rates. If we buy government bonds, for instance, the price of those bonds goes up which makes their
- -
yield the effective interest rate earned by holders of bonds come down. Like reserves,
government bonds play an important role as safe assets in the financial system, and so changes in
their yields also affect broader financial conditions, aggregate demand and inflation. It is this process
of using reserves to buy other assets that goes by the complex-sounding and in my view slightly
"quantitative easing" or QE. With Bank Rate having been close to its
misleading name effective
Crisis, the "new normal"
lower bound since the Global Financial has been for QE to be the primary
8
"quantitative easing is not as
monetary policy tool. As Peter put it in a paper with Colin Ellis titled
unconventional as it seems" -
it is just another way of using our balance sheet as a tool for monetary
stability.9
 A third way our balance sheet can be used in support of monetary stability is by lending reserves
directly to banks. The precise facilities used to do this vary, with different incentive structures
supporting different policy goals. The Term Funding Scheme, for instance, launched in 2016, was
8
"The monetary policy toolbox in the
I described the evolution of the monetary policy toolbox in more detail in my recent speech UK".
9
the Bank of England's Asset purchase Facility (the APF),
In practice the assets we buy through QE sit on a separate balance sheet,
which is indemnified by HM Treasury. This has important institutional and financial implications which I'll come on to cover,
but does not
affect its use as a monetary policy tool.
4
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intended to reinforce the pass-through of the August 2016 cut in Bank Rate to what was then a
historically low level. Our current Term Funding Scheme with additional incentives for SMEs is
intended to reinforce the transmission of the March cut in Bank Rate to 0.1% while also supporting
1: A summary of the Bank's balance sheet tools
Figure
Taken from the Bank of England Markets and Operations Guide, which gives full detail on all our balance sheet tools.
5
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SMEs. More recently the Bank's response to Covid has
lending to the real economy, particularly to
included a Covid Corporate Financing Facility, launched jointly with HM Treasury, designed to lend
cash, funded by reserves, directly to large companies, supporting their cash flow while leaving the
banking system to focus on lending to smaller businesses.

Finally our balance sheet has a key role to play in supporting financial stability by providing
-
insurance to banks and other financial intermediaries against liquidity risk the risk that solvent firms
cannot meet their financial obligations as they fall due. Of course we expect firms to self-insure
against liquidity risk as part of prudent financial management. But it would be unrealistic and
inefficient to expect them to insure against all shocks and so as a backstop we provide firms with the
borrow reserves (as well as dollars and euros). Liquidity insurance is very much an "old
ability to
normal" -
it goes back to Walter Bagehot in 1873 and his famous dictum to lend freely, at a high rate
of interest and on good banking securities. But it is worth noting that, whilst liquidity insurance is an
"old normal",
our current suite of facilities is much expanded over the last fifteen years. The Bank
learned lessons from the GFC, launching a revised Sterling Monetary Framework in 2013 under an
the Bank's former Governor and another former student of Peter's described
approach Mark Carney,
as much a part of the "new normal".11
as Open for Business10. This expanded toolkit is just
Of course the financial system is constantly evolving. And our balance sheet tools must evolve alongside it
towards a "future normal":
 crisis, and the turbulent "dash for cash"
On the financial stability side, the experience of the Covid
that took place in financial markets in March 2020, when exceptionally high demand for cash led to a
breakdown in the functioning of core financial markets, has raised questions of whether central
banks need new tools for dealing with market dysfunction.12 (I will come back to this question later in
the context of the impact that our QE purchases had).
 On the monetary policy side, the Bank's Monetary Policy Committee, which is responsible for
policy actions to take, has asked us to start "internal technical preparations
deciding what monetary
to deliver the option of a tiered system of reserve remuneration that could be ready to be
implemented, should it be judged appropriate, alongside a negative Bank Rate".13

Looking further ahead central banks around the world are grappling with the question of whether to
provide the public with electronic money, or Central Bank Digital Currency, and the challenges and
"future normal".14
opportunities that such a decision could throw up in a possible
10
Carney's speech
Set out in Mark 'The UK at the heart of a renewed globalisation'
11
I described the evolution of these tools in my 2018 speech
"Finding the right balance".
12
As set out in Andrew Hauser's speech "From Lender of Last Resort to Market Maker of Last Resort via the dash for cash".
13
As noted in the Minutes of the February 2021 MPC meeting.
14
The Bank set out some initial thinking on this in a March 2020 Discussion Paper, and together with six other central banks and the
Bank for International Settlements published a report in October 2020 identifying the foundational principles necessary for any publicly
available CBDCs to help central banks meet their public policy objectives.
6
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
Central banks including the Bank of England are considering what contribution they can make,
consistent with their remits, to encourage an earlier and more orderly transition to a carbon-neutral
economy.
QE as a monetary policy tool
will say more about QE and climate change as part of the potential "future normal" towards the end of my
I
lecture but for now I want to focus on QE in the context of the here and now.
The fact that QE only came into use in the UK in March 2009 means that in practice its history, at least in the
UK, is a short one. As Figure 2 illustrates, it has been used essentially five times in twelve years. QE1, 2 and
3 came in response to the financial crisis and the euro area crisis that followed; QE4 followed the Brexit
referendum; and QE5, which is still ongoing, formed part of the policy response to the Covid crisis last
March.
Figure 2: Bank of England QE programmes and selected policy interventions since 2009
IEO's report
Taken from the on its evaluation of QE.
Figure 3: Bank of England balance sheet as a % of GDP
Source: Bank of England, available here. Dotted line extends series to end-2021, assuming completion of current asset purchase
programme. All figures shown as a % of lagged GDP except 2021 figure which uses 2019 GDP to avoid distortions from the
temporary Covid-related falls in 2020.
7
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The headline numbers involved in those five interventions detailed in Figure 2 have been very large: in total
once the current programme comes to an end the Bank will have purchased £875bn of government bonds
-
and £20bn of corporate bonds that is roughly 40% of annual (pre-Covid) UK GDP. Once that programme is
complete the Bank's balance sheet, which already
stands at around 40% of GDP, will be approaching
- an unprecedented figure in the Bank's 327 year history
£1trillion, or 50% of GDP in size (Figure 3).
The robust operationalisation of those QE purchases has been crucial to the Bank's mission over the
past
twelve years. The IEO's review noted that
"a common finding across successive rounds of QE is that the
Bank has excelled at delivering at pace and under pressure, drawing on very effective staff input from
multiple areas." Never has that been more apparent than the response of Bank staff to the Covid crisis, with
close to 600 balance sheet operations conducted across multiple interventions during the course of 2020,
the vast majority of which conducted at home, including QE, where we purchased at the fastest pace ever in
the early stages of the crisis.
Figure 4: Recommendations from the IEO review of QE
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It is understandable that a relatively new policy tool, used on such a large scale, has attracted significant
public attention, in addition to the IEO evaluation, whose recommendations are set out in Indeed
Figure 4.
the House of Lords Economic Affairs Committee is currently taking evidence for its own QE inquiry.15 These
-
evaluations and inquiries, and the broader public debates around QE, are welcome they are an important
part of the process by which policymakers like myself are held accountable. I see them as a key part of the
process by which we learn more and develop our understanding of tools like QE.
I should be clear at the outset, though, that I am confident that QE works as intended as a monetary policy
tool. It's unsurprising, as the
IEO noted, that with such a small number of observations there are still open
questions about the QE transmission mechanism and impact, and we have welcomed the IEO's
recommendations about how the Bank might continue to advance its understanding. To make matters more
complex, we also recognise that the effects of QE are likely to be state contingent, meaning that there is no
single "effect of QE"
(Figure 5).16 But based on my reading of the academic evidence and my practical
experience as a UK policy maker, and consistent with the findings of the IEO report, my central view is that
QE achieves its goal of supporting demand and inflation. We have good evidence that it does indeed lower
interest rates, through a combination of portfolio balancing, signalling and market liquidity channels. And
while the specific contribution of the different channels is still uncertain and much debated, there is
increasing evidence that the associated reductions in borrowing costs and accompanying increase in
household wealth does feed through to increases in GDP growth and inflation.17
There are, of course, other important considerations regarding the broader impact of QE. For example, as
the IEO's report notes, there has been significant public debate about the possible spillovers associated with
QE, with a particular focus on the potential for distributional effects.18 While this topic is not the focus of my
remarks today, I would emphasise that the Bank continues to take the analysis and communication of
potential side-effects from its policy interventions extremely seriously.
15
on the Committee's
Further details including transcripts of the oral evidence sessions are available website.
16
As set out most recently by Andrew Bailey in his 2020 Jackson Hole speech and accompanying paper.
17
The supporting paper for Andrew Bailey's Jackson Hole speech, mentioned above, gives a good overview of the evidence for the UK,
as does Box B of the IEO report, while the 2019 BIS Committee on the Global Financial System report on unconventional monetary
as does Ben Bernanke's 2020
policy tools summarises the cross country evidence, AEA Presidential Lecture.
18
The Bank has actively contributed to work on this topic, with a notable contribution, for example, by Bunn, P, Pugh, A and Yeates, C
(2018) "The distributional impact of monetary policy easing in the UK between 2008 and 2014."
9
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Figure 5: Stylised QE transmission mechanism
Taken from the supporting paper for Andrew Bailey's Jackson Hole speech.
To make the macroeconomic effects of QE more concrete: previous Bank of England analysis suggests that
the initial £200 billion of QE during QE1 may have increased GDP by 1.5%-2% and inflation by
0.75pp-1.5pp.19 Using similar estimates in a 2016 speech, Mark Carney, estimated that if the MPC had left
- -
monetary policy Bank Rate and QE unchanged in the financial crisis, the level of GDP would have been
8% lower and 1.5 million more people would have been out of work.20
Whether the £200bn of QE we announced last March had the same impact is a complex question, and there
are arguments in both directions as to whether its impact will turn out to have been larger or smaller. On the
one hand, government bond yields have been very low by historical standards and it is possible that there
may be limits to how much more QE can do to push them down. On the other hand, our March purchases in
particular took place as I have said against a backdrop of extreme market disorder. Our purchases,
alongside other policy measures here and abroad, were instrumental in restoring order, and indeed we
-
deliberately carried them out at an unprecedentedly fast pace to achieve that in the words of the Governor,
Andrew Bailey, we "went big and fast". Had we not done this then that market disorder might, as we said at
the time, have led to an unwarranted tightening of monetary and financial conditions, and an even sharper
contraction in GDP.
I want to emphasise this last point. Some commentary that I have seen has suggested that in addressing
market disorder the MPC somehow broadened its objectives and used a monetary policy tool for financial
stability purposes. I don't see it like that at all. The MPC took action in pursuit of its objectives, because
further market dysfunction triggered by the Covid shock would have led to even worse outcomes for GDP
and inflation. Their action had the welcome side effect of supporting financial stability, but it was taken for
monetary policy purposes. Indeed it is quite possible to imagine other circumstances where the MPC would
19
"The United Kingdom's quantitative easing policy: design, operation and impact", Bank of
Joyce, M, Tong, M and Woods, R (2011),
England Quarterly Bulletin, 2011 Q3
20
"The spectre of
In his 2016 speech monetarism".
10
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not act to quell market disorder, if doing so would run counter to rather than in support of monetary stability.
It's for exactly this reason that the work I mentioned earlier, on whether central banks need new tools to deal
directly with market dysfunction, is so important.
QE and government financing
One aspect of QE that has received particularly close attention has been its relationship to the Government's
finances. Specifically, some commentators have raised the question of whether, by buying government
bonds at a time when the Government deficit is expanding, the Bank is somehow financing government
spending. Again, this is a question that comes down to the objectives in pursuit of which policy is being set.
As my colleague Ben Broadbent has said, you need to look not just at who, in terms of which policy
institution, is doing what, but also why they are doing what they are doing in terms of policy actions.21
Since the start of the Covid pandemic the priority for both the MPC and the Government has been to support
the economy through the outbreak and to minimise the potential for long-term damage or scarring to the
economy's potential. And to do
that, to bridge across the period of the shock, we have taken unprecedented
fiscal and monetary actions, as well as using our financial stability tools to the full. Those actions were
consistent and they were complementary. But - crucially - they were taken independently and in pursuit of
each institution's own
policy objectives.
This argument in principle is backed up by what has actually happened in practice. Just in terms of
scheduling, the MPC's decisions have largely been taken ahead of rather than in response to
the MPC, acting on advice from the Bank's
Debt Management Office (DMO) announcements. Indeed in June
executive, agreed, at the same time as adding to the target stock of asset purchases, to substantially slow
the pace of purchases, from £13.5bn/week to an initial £6.9bn/week, before the DMO published its updated
remit, which set out plans for increased issuance.
As for economic outcomes, inflation has been well below our 2% target for the past year, while measures of
-
inflation expectations such as those from financial markets have been stable and consistent with the target
not what you would expect to see if QE was being used for purposes other than our monetary stability
objective.
In fact it is true that there are links, as I'll set out, between QE and the Government's finances -
as there are
for any of our other balance sheet tools. But these are very different from the charge of "monetary financing"
that I have been responding to so far. Instead of reflecting deliberate deviations from our monetary policy
objectives, they come down to more prosaic and technical, though very important, and hence understandably
a focus of the IEO report, issues of risk management and accounting.
21
Ben's recent speech "Government debt and inflation" as does Andrew Bailey's recent
addresses this question comprehensively,
"Modern challenges for the modern central
speech bank".
11
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I'll start, once again, with the Bank's own balance sheet. Like any financial institution the Bank holds loss-
absorbing capital to insulate it against unexpected losses. In the latest published accounts the Bank's
loss-absorbing capital stood at £3.5bn.22 That is an appropriate sum to hold against potential losses from the
Bank's liquidity operations and funding schemes, which are prudently
backed by good quality collateral.23
But the risks from the QE portfolio, which by its nature is necessarily uncollateralised and unhedged, are
For that reason the Bank's QE purchases are carried out from a
potentially much larger. (Figure 6)
subsidiary called the Asset Purchase Facility (APF) which is indemnified by HM Treasury, so that the cost of
any net losses is met by HM Treasury rather than from the Bank's own capital, while any gains accrue to HM
Treasury, with net cash flows transferred once a quarter.24
Figure 6: APF cash-flow arrangements
Taken from the IEO's report on its evaluation of QE.
In practice the APF has made a net accounting gain over its life to date. The scale of this gain was not
foreseen, much less intended, at the time of its creation, and has certainly never been regarded as a goal of
QE. Instead it reflects the fact that since QE was launched interest rates have fallen and stayed low, while
the MPC has not yet taken the decision to sell any of its bonds, which might crystallise losses. As a result
cumulative transfers to HM Treasury have now reached over £100bn. The direction of these transfers is,
however, likely to reverse in the future under many possible scenarios, once the economy recovers from
Covid and yields start to rise. The potential size and timing of any such reversal is uncertain and will vary
depending on a number of factors, such as the total size and composition of asset holdings, the future path
of Bank Rate and the path of any asset sales. In response to one of the IEO review's recommendations the
22
On page 36 of the Bank's 2019/20 Annual Report. The Bank has £5.8bn of total capital of which £3.5bn is loss-absorbing.
23
Ultimately, the Bank is fully backed by HMT, who have committed to replenishing the Bank's capital in those extreme
circumstances
where the Bank could take a material loss.
24
The exchanges of letters between the Chancellor and the Governor confirming the indemnity arrangements are available on the
Government and Bank of England websites, as is the exchange of letters agreeing the cash transfer arrangements.
12
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Bank will publish later in 2021 updated analysis of how such factors are likely to influence the size and
direction of future transfers.25 Certainly the transfers are material and worth highlighting - but they are a
side-effect of QE, not its goal.
QE and climate considerations
A second aspect of QE that has received close external scrutiny is its relationship to climate change.
Responding to climate change is a strategic priority for the Bank; we continue to work towards promoting
safety and soundness by enhancing the Prudential Regulation Authority (PRA)'s approach to supervising the
financial risks from climate change, and towards enhancing the resilience of the UK financial system by
supporting an orderly market transition to a low-carbon economy. In particular we have supported the
Financial Stability Board's work on climate disclosure through the Task
Force on Climate-related Financial
Disclosures (TCFD). To show its commitment last June the Bank published a report disclosing for the first
time its own approach to climate risk management for all its operations.26
Attention, however, has understandably focused on the £20bn corporate bond purchases that form part
(around 2%) of our QE programme, and whether more should be done to account for climate considerations
in these holdings. Our approach to date has been to invest in sectors in proportion to the total outstanding
eligible issuance accounted for by each sector in the UK economy.27 An important part of the design of the
was to achieve the MPC's aim of imparting monetary stimulus in a way that was
CBPS back in 2016
sector-neutral, consistent with the remit given to the Committee by the Chancellor.
As a result, the carbon footprint of the APF Corporate Bond Purchase Scheme (CBPS) portfolio is broadly
representative of the sterling investment grade corporate bond market (Figure 7). Measuring the climate
impact of this market portfolio remains a developing science, and our disclosure report shows a range of
possible metrics, including the commonly reported weighted average carbon intensity (WACI). More
"portfolio warming potential"
experimental metrics under development, are metrics, which attempt to assess
alignment with international climate targets. One estimate suggests this is 3.5° for the CBPS, and so not
aligned with the long-term goals of the Paris Climate agreement (Figure 7). Again that is, unsurprisingly,
broadly consistent with the wider market. Other approaches lead to a wide range of different results for our
portfolio, ranging from less than 1.75° to 4°, illustrating the considerable degree of uncertainty.
25
A 2013 Bank of England Quarterly Bulletin article by Nick McLaren and Tom Smith sets out the factors that are likely to determine the
size and direction of future transfers.
26
"The Bank of England's climate-related financial disclosure 2020", available on the Bank's website.
27
Eligible bonds are sterling investment grade corporate bonds issued by companies which make a material contribution to economic
which are set out on the Bank's website.
activity in the UK, subject to certain restrictions Corporate bonds issued by banks, building
societies, insurance companies and other financial sector entities regulated by the Bank or the Financial Conduct Authority are not
eligible.
13
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