David Prosser: A lesson in how to call bankers to account

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Outlook You've got to hand it to New York attorney-general Andrew Cuomo. The Merrill Lynch bonus scandal broke only last week, but Mr Cuomo has already subpoenaed John Thain to appear before him. He wants Mr Thain to testify as part of an investigation over the way in which Merrill Lynch appears to have accelerated bonus payments to staff in the run-up to its takeover by Bank of America.

Compare the speed of the New Yorkers with the sleepy way in which British authorities have reacted to the banking crisis. As of right now, for instance, there appears to have been no investigation by UK law enforcement agencies of anyone involved in the collapse of so many of our banks.

Indeed, even John McFall's Treasury Select Committee, supposedly renowned for its combativeness, has only just got around to asking Sir Fred Goodwin, for example, to come and give evidence about the near demise of Royal Bank of Scotland.

This is not to suggest for one minute that anyone in the UK – or the US for that matter – has broken the law during this crisis. Nor is there anything to be achieved – political Brownie points aside – by legal action taken for its own sake.

However, those people now suffering in the recession that has followed the banking crisis have a right to ask whether the behaviour and actions of those at the heart of the credit crunch have been properly scrutinised. The Americans are doing a much better job of that.