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Did Bright Simons overstretch his take on bank of Ghana’s exposure draft on non

I chanced on an article by Bright Simons on the Bank of Ghana’s Exposure Draft on Non-Interest Banking, which was published by citinewsroom.com, and I felt a few comments would be in order. Let me first commend him for the great insights. I share in his concerns relative to issues about commingling of funds (although with some reservations), insurance (deposits and other assets), liquidity management mechanisms, capital adequacy ratio issues, and tax harmonisation and amendments. Much as I share in these concerns, we must also be fair to the Bank of Ghana.


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