The FSAP Program: Practice and Potential
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The FSAP Program: Practice and Potential






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  • Include both logos to indicate coop
  • (To include national and spillover issues) Spillover: financial contagion -- systemically important systems and AML
  • Exposure: credit concentrations; risks insured, capitalization, deposit concentration, exchange mismatch
  • Cover (i) financial sector regulation and supervision; (ii) institutional and market infrastructure; and (iii) policy transparency. The standards routinely assessed consist of the: (i) IMF Code of Good Practices on Transparency in Monetary and Financial Policies (MFP Code); (ii) Basel Core Principles for Effective Banking Supervision (BCP); (iii) Core Principles for Systemically Important Payment Systems (CPSIPS); (iv) International Organization of Securities Commissions (IOSCO) Objectives and Principles of Securities Regulation (IOSCO Principles); (v) I nternational Association of Insurance Supervisors (IAIS) Insurance Core Principles (ICP); and more recently, (vi) the Financial Action Task Force (FATF) Recommendations for Anti-Money Laundering and Combating Financing of Terrorism (AML/CFT). In addition, other standards, principles and In addition, other standards, principles and guidelines may be used to inform the FSAP analysis, including: (i) the OECD Corporate Governance Principles; (ii) World Bank Principles for Effective Insolvency and Creditors Rights; (iii) CPSS-IOSCO Recommendations for Securities Settlement System (RSSS); and (iv) International Accounting and Auditing Standards. (The last four will not be covered in future except perhaps RSSS). Use is also made of Bank-Fund Public Debt Management Guidelines and Reserves Management Guidelines for informing the analysis in these areas. The number of standards assessed per FSAP has increased from two to four in the pilot cases (average of 3.7 per FSAP), to three to six more recently (average of 4.9 per FSAP in FY 2003), excluding AML/CFT assessments.
  • Average was 4.9 (not incl AML; but yes including A&A, Corporate Governance; Insolvency and creditor rights) per country: new proposal: average of 3 per country. Achieved: 2.6+AML in Calendar 2004.; 2.1 if advanced economies are excluded.
  • Narrow issues: Some sectors/institutions have no agreed standards also e.g.: Credit cooperatives Currency unions
  • Fewer codes: Average of 3 only for the future (+AML) cf. 4-6 in 2002
  • There’s no standard for crisis management, deposit insurance
  • Methodological reviews
  • Exchange rate: direct, indirect; Interest rate: buckets Liquidity -- runs Quality of loan classification: migration, or underestimation A few have done insurance Shocks chosen in consultation with authorities Elaborations: empirical correlations; stock market crash; 3 used Monte Carlo! Inadequate for complex institutions/derivatives
  • Future: More work on contagion More work on peer group of countries -- how bad is bad More work on regression links
  • Aide memoire (to help remember the wrap-up meeting) -- often slide show presentation

The FSAP Program: Practice and Potential The FSAP Program: Practice and Potential Presentation Transcript

  • The FSAP Program Practice and Potential
  • Financial Sector Assessment Program
    • Diagnosis of potential vulnerabilities
    • and analysis of development priorities
    • in the financial sectors of member countries
  • Outline of presentation
    • The FSAP program to date
    • Use of standards and codes
    • Stability aspects
    • Development aspects
  • The FSAP program seeks to…
    • Identify strengths and vulnerabilities
    • Determine how key risks are being managed;
    • Ascertain development and TA needs; and
    • Help prioritize policy responses
  • Some institutional features
    • Joint product of the IMF and the World Bank
      • joint Bank-Fund Financial Sector Liaison Committee (FSLC)
      • designed to strengthen IMF bilateral surveillance and World Bank’s financial sector development work.
    • An international cooperative effort drawing on financial sector experts from collaborating official institutions as well as Bank-Fund staff
    • Started May 1999 (pilot basis)
    • Voluntary participation
  • FSAPs : 1999-200 4
    • Completed FSAPs: 73 countries
    • FSAPs underway: 18 countries
    • Future participation confirmed: 14 countries
    • FSAP updates: 9 countries
  • FSAPs completed (1999-2006: 97)
  • FSAPs underway or agreed (25)
  • Updates (23)
  • Building blocks
    • Assembly of data on system functioning
      • Including scale, liquidity, efficiency, reach, exposure
    • Standards and codes assessments
      • Detailed structured discussions with authorities
    • Formal stress-testing
    • Interviews with market participants
    •  Overall assessment
  • Codes are selected from…
    • Basel Core Principles for Effective Banking Supervision (BCP)
    • Transparency (Monetary & Financial Policies)
    • Systemically Important Payment Systems (CPSIPS)
    • Securities Regulation (IOSCO)
    • Insurance (IAIS)
    • AML-CFT (FATF)
    • For reviews:
  • Basel Core Principles for Effective Banking Supervision
      • Objectives, Autonomy, Powers, and Resources
      • Licensing and Structure
      • Prudential Regulations and Requirements
      • Methods of Ongoing Supervision
      • Information Requirements
      • Formal Powers of Supervisors
      • Cross-border Banking
    Standards and Codes
      • Organisation of an Insurance Supervisor Licensing and Changes in Control
      • Corporate Governance
      • Internal Controls
      • Prudential Rules
      • Market Conduct
      • Monitoring, Inspection and Sanctions
      • Cross-border Business Operations
      • Supervisory Coordination and Cooperation, and Confidentiality
    IAIS Insurance Core Principles Standards and Codes
      • The regulator
      • Self-regulation
      • Enforcement
      • Cooperation in regulation
      • Issuers
      • Collective investment schemes
      • Market intermediaries
      • The secondary market
    IOSCO Objectives and Principles for Securities Regulation Standards and Codes
  • IMF Code of Good Practices on Transparency in Monetary and Financial Policies
      • Clarity of roles, responsibilities and objectives of central banks / financial policies
      • Open process for formulating and reporting monetary / financial policies decisions
      • Public availability of information on monetary / financial policies
      • Accountability and assurance of integrity by the central bank / financial policies
    Standards and Codes
      • Legal basis
      • System’s impact on risks and procedures for management of risks
      • Final settlement
      • Assets for settlement
      • Security and operational reliability and contingency arrangements
      • Practicality of the system
      • Objective and publicly disclosed criteria for participation
      • Governance of the system – its effectiveness, transparency and accountability
      • Responsibilities of the central bank in applying the Core Principles
      • Securities settlement systems
    CPSS Core Principles for Systemically Important Payment Systems Standards and Codes
      • Criminal justice measures
        • Including FIU, confiscation of proceeds, enforcement, international co-operation,
      • Preventive measures for financial institutions
        • Legal & institutional framework & implementation
        • Banking, Insurance, Securities: sector-specific criteria
      • Information on controls and monitoring of cash and cross border transactions
    Anti-Money Laundering & Countering the Financing of Terrorism (AML-CFT) Standards and Codes
  • Frequency of codes in early FSAPs to Dec 2002
  • FSAPs vs. code assessments: What’s the difference? (1)
    • Not all relevant codes can be covered
      • So need to be supplemented by less formal work
    • Cross-sectoral issues
      • Interaction between different sectors
      • Regulatory overlap or underlap
    • Coverage gaps
      • e.g. contractual savings/social insurance (financial sector aspects); deposit insurance
  • FSAPs vs. code assessments: What’s the difference? (2)
    • Codes developed by regulatory bodies and reflect their partial focus
    • Mechanical code diagnosis may miss national features
    • Prioritization and highlighting
  • FSAPs vs. code assessments: What’s the difference? (3)
    • No standards for key stability & development issues such as
      • Macrofinancial crisis management
      • Competition environment,
      • Tax, quasi-tax and subsidy issues
      • Access to financial services
      • Missing markets
      • Overall legal framework
  • The future (1): less reliance on full code assessments
    • Subtlety and sophistication inapplicable in many environments (small, less developed systems)
    • Attempt to retain enough of the essence of the code without excessively detailed questioning?
    • Avoid “Fiddling while Rome burns” by selecting only most relevant codes…
    • … and switching resources to country needs
  • The future (2): FSAP updates
    • Evolving towards a more flexible model differentiated in line with country needs
    • Elements will include:
      • Ongoing surveillance (with Art. IV)
      • Coverage of additional sectors (rolling assessment)
      • Updates of ROSCs if warranted by changes
      • More in-depth development studies (e.g. involving more continuous engagement)
      • Greater emphasis on TA/follow-up
  • Crisis prevention vs. prediction
    • Can FSAPs predict a crisis?
    • Is the system in “Zone of vulnerability”?
    • Identifying channels of vulnerability
    • Crisis management mechanisms
  • Vulnerability = Risks x Systemic Weakness
  • Stress testing (1)
    • Quality of stress test results
    • =
    • quality of data X relevance & scale of shocks
  • Stress testing (2)
    • (Mainly banking system)
    • Typical shocks: exchange rate, interest rate, liquidity, commodity price; housing prices; quality of loan classification
    • Scale of shocks: reference to history
    • Correlations: usually scenarios
    • (More elaborate procedures used for some advanced economies)
  • Stress testing (3)
    • Account sometimes taken of sectoral pattern of lending, market portfolio.
    • Must be bank-by-bank: averages can conceal
    • The essence: recalculate bank’s capital after shock
    • Impact of shock on loan performance usually judgmental -- occasionally use of historic relations; rarely use information on non-financial corporate finances
  • Approach to the development assessment
    • Builds on information gathering part of the stability part & regulatory code assessments
    • But takes a functional and systemic approach
    • Seeks to trace deficiencies to (i) gaps in financial infractructure and (ii) flaws in policy
    • Optimal policy recommendation highly country specific
      • Laissez-faire inadequate; activism often counterproductive
      • Political, governance & admin. preconditions important
  • Development assessment: the information gathering phase
    • Quantitative benchmarking
      • size, depth, cost and price efficiency and penetration
    • Infrastructural reviews
      • legal, informational and transaction technology
    • Sectoral reviews
      • service provision, structure and regulation
      • (incl specialized development institutions)
    • Demand-side reviews
    • Other cross-cutting aspects of policy environment
  • Development assessment: the analytical and reporting phase
    • Delivering the message:
    • Describe the functional gaps
      • E.g. lack of term finance; no venture capital; high intermediation costs; limited access; nascent insurance industry…
    • Pinpoint the source(s) of the difficulty
    • Propose strategic approach to solution
      • highlighting cross-sectoral aspects
  • Outputs
    • Aide Mémoire Working document, not for publication
    • FSSA * (IMF Board) Financial sector stability assessment
    • FSA ** (WB Board) Financial sector assessment
    • ROSCs * Summary report on observance of standards & codes (annexed to FSSA)
    • Technical Notes On selected issues
    • Detailed standards & codes assessments
    • Mexico examples:
      • *
      • **
  • Publication policy
    • Aide Memoire given only to authorities
    • FSSAs and FSAs:
      • are confidential but do not contain information concerning the health or prospects of individual financial institutions.
      • voluntary publication (same publication and deletions policy as Article IV staff reports)
    • Financial sector ROSCs:
      • voluntary publication; could be published separately from FSSA
    • Detailed assessments of observance of standards and codes
      • can be published by authorities with the consent of IMF-WB
    • Technical Notes
      • can be published by authorities with the consent of IMF-WB management, with exception of stress test results and information on individual institutions, and with appropriate deletions for highly market-sensitive information.
  • What can we conclude from an FSAP?
    • Is the system stable? If not, what actions required?
    • How to strengthen the financial system further?
      • Improve code compliance;
      • Build infrastructure (human, organizational, physical);
      • Prioritize and sequence reform plans.
    • How to help the process with technical assistance?
  • What countries like about the FSAP
    • Informs domestic policy making
      • Provides a consistent, comprehensive framework for financial sector stability issues and development needs
      • Helps country ownership of the reform process
    • Provides a basis and incentive for national authorities to conduct self-assessments
    • “ Peer review” aspect — use of experts from collaborating official institutions from other countries
  • For the Bank and Fund…
    • The FSAP findings:
    • Help strengthen the IMF's Article IV surveillance process
    • Inform the work program between WB and authorities, and identify priority areas for support.
  • « Glögt er gests augađ »
    • ( “Keen is the eye of the visitor”
    • -- an Icelandic saying )
    • The greatest potential of the FSAP is not so much the ratings
    • or the overall risk assessment,
    • but its ability to bring
    • a new perspective to
    • financial sector policy in the host country