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Bay Street sign in heart of Toronto's financial district

Deborah Baic/The Globe and Mail

At the Group of 20's inaugural meeting in Pittsburgh last September, all the talk was about harmonization and the co-ordinated action needed to prevent another financial crisis.

But as G20 leaders prepare to meet in Toronto next month, countries are taking different, and sometimes conflicting, paths to regulatory reform.

The United States is cracking down on big banks and their risky trading operations. Europe is focused instead on the behaviour of hedge funds and other private investors. Canada, meanwhile, appears content to defend the status quo, arguing that its regulatory regime held up fine in the crisis.

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"I'm pessimistic that all of this can be done in one grand design," said Ross Levine, an economics professor at Brown University in Providence, R.I., and an expert in financial regulation.

Harmonization of international rules would be nice, but he pointed out that divergent rules didn't cause the 2008 financial meltdown.

He also worries that once new regulations are in place, they'll lose their value over time if there's no room for change. "If regulation is going to be effective, it can't be static," Prof. Levine said.

In a recent paper, he argued that proposed new U.S. financial rules give the same flawed regulators, including the U.S. Federal Reserve Board, too much power.

In the immediate aftermath of the financial crisis, global leaders pledged to work together to build a more robust financial system.

Speaking in Ottawa Thursday, Canadian Prime Minister Stephen Harper warned that the global economy is too shaky for countries to be working at cross purposes.

"With the fragile global economic recovery hanging in the balance, it is crucial that we build consensus at the summit on reform of the financial sector, control of sovereign debt, and the framework for strong, sustainable and balanced economic growth over the long term," said Mr. Harper, who is hosting the June 26-27 G20 meeting.

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But Canada has been vocal opponent of a global bank tax being pushed by many European leaders.

U.S. Treasury Secretary Timothy Geithner also stressed the need for a unified approach, following a meeting in Berlin with German Finance Minister Wolfgang Schaeuble. He said countries have a shared interest in creating a global approach to financial regulation. And he warned against pursuing policies that could push activities beyond the control of regulators.

"These are global markets, you need common standards - you don't want to just let risk move outside the scope of regulation," Mr. Geithner told reporters.

But Mr. Geithner acknowledged that "we're going to have slightly different approaches because we have different systems."

And in private, U.S. officials have been harshly critical of Germany's plan to ban naked short selling - a form of speculative trading. The United States is also concerned that European plans to crack down on hedge funds could make it tough for U.S. funds to court European clients.

European officials, meanwhile, are fighting U.S. efforts to push commercial banks out of the lucrative derivatives business. The measure is contained in the recently passed U.S. Senate financial reform package, but could be watered down as the bill is reconciled with slightly different House legislation.

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Some analysts said there may be a silver living in the rifts between countries on how to prevent the next crisis.

Too much regulation could hamper financial markets and cut off badly needed credit to businesses and consumers, said Gary Townsend, a former U.S. bank regulator who is now president of Hill Townsend Capital in Chevy Chase, Md.

"All governments should take a step back and a deep breath," he said.

Much of what's being proposed in the United States and Europe is "geared at re-election, rather than good government."

Mr. Townsend said a special congressional committee is still months away from issuing its final report on what caused the financial crisis.

"We don't need to do anything new today to prevent a financial panic that could happen 10 years from now," he said.

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