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Members of the International Law Association’s Committee on International Monetary Law (MOCOMILA) in Vienna, including Queen Mary Professors John Taylor and Rosa Lastra.
The Resolution on Non-Bank Financial Intermediation (NBFI) was adopted by the International Law Association (ILA) at its 82nd Biennial Conference in Vienna in August 2026, following work by its Committee on International Monetary Law (MOCOMILA).
Professor John Taylor, Professor of International Finance and Trade Law at Queen Mary’s Centre for Commercial Law Studies, was the main drafter of the NBFI Resolution and was assisted by a working group and other expert members of MOCOMILA, including Professor Rosa Lastra, Sir John Lubbock Chair in Banking Law at Queen Mary and Vice-Chair of MOCOMILA.
A rapidly growing part of the financial system
Non-bank financial intermediation covers financial activity carried out by institutions that are not classified or regulated as banks.
Professor Taylor said: “Non-Bank Financial Intermediation today exceeds bank finance and will continue to grow. Half of total global financial assets are offered by entities that are not classified nor are they regulated as banks. A recent Resolution of the International Law Association calls for greater scrutiny and transparency.”
The Resolution calls on domestic and international financial authorities to strengthen their knowledge, understanding and monitoring of NBFI activities, business models and risks. It also calls for greater international cooperation and coordination, and greater clarity around the responsibilities of the public and private sectors in providing assistance during crises arising from NBFI activity.
A key concern identified by Professors Lastra and Taylor is the lack of reliable and complete data about the sector, including the scale and different types of NBFI activity, who is exposed to potential risks, and the extent of connections between non-bank institutions and banks.
They argue that better data is essential if regulators and policymakers are to understand whether reforms are needed and identify potential risks to wider financial stability.
UK and international relevance
In addition to her role as Vice-Chair of MOCOMILA, Professor Lastra has served as Specialist Adviser to the House of Lords Financial Services Regulation Committee during its inquiry into the growth of private markets.
The Committee’s report, Private markets: Unknown unknowns, published in January 2026, highlighted gaps in available data about private markets and called for continued monitoring by UK financial authorities.
Professors Taylor and Lastra argue that the ILA Resolution supports key findings and conclusions from the Committee’s inquiry, particularly the need for stronger data collection, analysis and transparency, alongside vigilant monitoring of NBFI activity and its interconnectedness with banks.
Looking ahead, they identify improving data transparency as a priority and call for national and international financial authorities and standard setters to consider how the Resolution’s recommendations could be implemented within their respective mandates.
They also stress that the aim is not simply to subject NBFIs to greater regulation. Non-bank institutions provide important sources of finance to domestic and international commerce, and the academics argue that oversight should balance these benefits with the need to protect financial stability and investors.
Queen Mary’s Centre for Commercial Law Studies will host a hybrid seminar with Professors Taylor and Lastra from 12pm to 1pm on 21 October 2026, where they will discuss non-bank financial intermediation and the ILA Resolution.