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Two comments on this. One: the U.K. isn’t Norway, when it comes to financial services. Predicting how consultation or Art 102 EEA would work in practice is therefore tricky. As they say in FS, past performance is no guarantee of the future.
Two: it’s all very well criticising the EEA - but an equivalence regime also risks forcing the U.K. into rule-taking. And equivalence can be drawn at the drop of a hat and without the legal framework surrounding actions under Art 102 EEAA. That inherent instability is an issue.
And NB that even as an EU Member State the U.K. can and does get outvoted on FS: in which case it is also a rule taker.
As always, it’s nuance and trade-offs.
PS - this piece sets out some good supporting reasons behind my first point.
