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Convergence Program Spi Albania Handover Report
1. SPI Albania
Handover Report
December 2007 - November 2009
By
Convergence Program
www.convergence-see.eu
The World Bank
Washington, DC – Rome (Italy)
November 2009
2. Objective
This document summarizes the activities performed by the World Bank’s Convergence Program1
to assist Bank of Albania and Association of Albanian Banks to set-up the SPI Albania public-
private partnership for financial sector modernization and to operate it for an initial period
through end-February 2010.
Historical Context
Bank of Albania and Convergence Program started the first consultations on possible activities in Albania
in 2004. In March 2006, Convergence Program supported an Italy-Albania Remittances Conference in
Bari (Italy), where Regione Puglia President Vendola hosted a large Albanian delegation led by Governor
Fullani. The Conference led to follow-on activities in Tirana and Milan (Italy), in partnership with the
Albanian Association of Banks and the Italian Banking Association. In April 2006, Prof. Francesco
Cesarini and Mihai Bogza, former Vice Governor of the National Bank of Romania, illustrated how the
Italian Banking Association contributed to Italy’s financial sector development at a seminar organized by
the Association of Albanian Banks. In May 2006, in partnership with Bank of Albania and the Albanian
Deposit Insurance Agency, Convergence Program and European Forum of Deposit Insurers organized a
Regional Technical Seminar to disseminate work done with Romania’s Deposit Guarantee Fund. In
October 2006, Convergence Program presented a paper on regional host cooperation at Bank of Albania’s
Regional Financial Stability Conference. In the same year, discussions started to replicate the SPI
Romania structure that was launched in July 2006 in Romania. In November 2007, Convergence
Program joined Aquifalc, a Regione Puglia-led consortium of Italian and Albanian academic institutions
and think-tanks administered by the Department of Economics of the University of Bari. It is also
important to note that Prof. Shkelqim Cani, former Governor of Bank of Albania, gave a key contribution
in designing and launching the Convergence Program regional activities in the 2005-2007 period, with
specific responsibility to launch the successful SPI Romania program.
SPI Albania Launch
In December 2007 Mr. Ardian Fullani, Governor of Bank of Albania, invited Mr. Biagio
Bossone, former World Bank Executive Director for Albania and Italy, to visit Tirana to explore
the feasibility of helping local stakeholders establish SPI Albania through Convergence Program
involvement. In early January, Bank of Albania and Association of Albanian Banks issued a
mandate letter to the Convergence Program to set up SPI Albania and to work with Regione
Puglia to mobilize funds to cover its activities2 following initial Convergence Program financial
support. On 19 January 2008, Governor Fullani together with Regione Puglia President Nichi
Vendola, AAB Vice Chairman Pencapligil and Deputy Governor of Central Bank of Montenegro
Knezevic launched SPI Albania at a press conference at the margin of Italy’s Annual Banking
Symposium held in Bari.
Operational Preparation
To provide the Albanian financial community with the EU methodology for public-private
reform design (“Better Regulation”), the Convergence Program delivered a Regulatory Impact
Assessment Knowledge Transfer Program between January and April 2008, under the direction
of its Regional RIA Director and with the participation of EU experts. It also delivered a seminar
on the SPI Romania experience for the Albanian banking community.
In February-March 2008, it ran extensive interviews to select and recruit the SPI Secretariat staff,
after placing job ads in local newspapers. Under the leadership of its SPI Regional Operations
1
Total cost of Convergence Program intervention during the period under review has been €300 thousand,
contributed by Italy’s Convergence Program Trust Fund and Regione Puglia through the Aquifalc program.
2
Regione Puglia prepared two projects to channel EU funding to SPI Albania, with Convergence Program’s
technical support. The 2008 proposal was not admitted to final selection. Regione Puglia and the Albanian
stakeholders elected not to submit the second proposal (Bank-Enterprise Observatory) in October 2009.
3. Director, it ran an induction program for two SPI Albania Directors in April 2008. During this
period, Convergence Program undertook extensive consultations with the authorities and the
banking community to prepare the proposed 2008 Financial Modernization Program.
Operational Outcomes3
Following an informal SPI Committee meeting on 27 March 2008, SPI Albania started operating
on 15 May 2008. On 10 June 2008, the SPI Committee approved the 2008 Financial
Modernization Program, consisting of four projects, matching the ECB’s financial modernization
taxonomy. On 4 November 2008, the SPI Committee added a fifth project (Consumer financial
education). In 2008, Parliament enacted laws on changes in the Civil Procedural Code and on
the Bailiff’s Law reflecting SPI Albania recommendations. According to an Impact Assessment
prepared by SPI Albania, these law changes are estimated to reduce banks’ annual operational
costs by about €17 million. Bank of Albania received a comprehensive roadmap for regulatory
changes to accommodate introduction of IFRS. Two 2008 projects, Reducing cash transactions
and Review of capital adequacy regulations were carried over into 2009.
On 12 March 2009, the SPI Committee approved the 2009 ten-project Financial Modernization
Program, prepared after extensive consultations with local stakeholders and donor community.
In the course of 2009, SPI Secretariat completed three projects (Reduction in cash transactions,
Consumer financial education and Liquidity management regulations). The latter project led to
the enactment of a Bank of Albania regulation. The cumulative output in about one year of
activity is therefore five completed projects, followed by enactments for three of them. The SPI
Secretariat has substantially advanced on one project (Procurement rules for financial advisory
services) and has largely scoped the project on Execution procedures on bank accounts.
Therefore SPI Albania has already done substantive analytical and consensus-building work on
seven projects. Work on the Capital adequacy regulation was delayed in 2009 because of
sequencing considerations in Bank of Albania’s work program but is expected to accelerate soon
again. Two more projects may advance in coming months (Feasibility study for central
depository services and Calculation of FX open positions). Overall, in the period under review,
SPI Albania will have done substantive work on ten projects leading likely to six or seven
enactments – with part them materializing after the end of the Convergence Program’s mandate.
Ahead of the completion of its mandate, Convergence Program is organizing a second
Regulatory Impact Assessment Workshop with participation of a leading UK expert in December
2009 for the financial community, under the auspices of Bank of Albania.
In conducting its activities, SPI Albania will have organized 27 Project Working Group
meetings, mobilizing about 145 local experts in 2008-2009 (for a total of almost 4000
expert/meeting). This confirms the strong support SPI Albania has enjoyed from both Bank of
Albania and the Association of Albanian Banks and other public institutions. It is also useful to
note that two Bank of Albania staff filled the critical position as SPI Director of Analytics and
Policy (later renamed SPI Director, Financial Modernization Program).
Besides receiving Convergence Program managerial and technical support, largely through its
dedicated SPI Regional Operations Director Ramona Bratu, and Regione Puglia’s financial
support through Aquifalc, SPI Albania has collaborated with EBRD, EU, FSVC, IFC, TAIEX
3
SPI Albania activities are displayed on the www.spi-albania.eu website.
3
4. and World Bank experts in the course of its activities. The Government of Albania invited SPI
Albania to share its experience during the EU Western Balkans and Turkey Donor Coordination
Conference that took place in Tirana in early April 2009.
Other Activities
Convergence Program arranged a technical assistance agreement with the Italian Banking
Association that provides for the participation of a senior ABI manager to SPI Committee
meetings as Permanent Observer. Same status as Permanent Observer on the SPI Committee was
arranged for the Dean of the Economic Faculty of the European University Tirana. Permanent
Observers assist SPI Committee deliberations through their technical expertise. In March 2009,
the EU Delegation in Tirana was invited to have one of its staff to attend SPI Committee
meetings as a Guest.
In addition, Convergence Program introduced SPI Albania activities to several institutions that
will be able to provide future funding support. It worked closely with Regione Puglia to structure
two proposals for EU funding. It submitted a request for funding three projects to FIRST
Initiative, a $100 million multi-donor Trust Fund managed by the World Bank. It introduced
CIPE (Washington, DC-based Center for Private Enterprise) as a source of funding and capacity
building for AAB, as SPI Albania stakeholder. It supported dialogue between European Banking
Federation and European Commission (DG Markt and DG Enlargement) to structure EU funding
for SPI Platforms in South-East Europe, to be operated by banking associations (e.g., AAB). It
explored the possibility of EBRD funding for SPI Secretariat positions. It managed to secure EU
TAIEX support to one SPI Project led by the Ministry of Finance.
Overall Assessment
The SPI Albania platform has catalyzed the ability of the Albanian financial community to run a
large-scale financial modernization program, relying on local expertise for both project
management and solution-searching, with very limited reliance on foreign experts.
Based on its own capacity to identify regulatory change opportunities, the community agreed to
undertake many projects of strategic importance for the future of financial intermediation in
Albania, reflecting objectives of authorities, market participants and consumers that were
consistent with policy priorities. And it was able to lead and organize the work of many experts
that have produced recommendations, using the EU Better Regulation methodology, which
authorities have relied upon to prepare legislative and regulatory acts.
This ability to identify issues of common concern, to mobilize local resources to handle them
quickly and rigorously and to produce quality results that support authorities’ enactment
activities, is a considerable achievement for which the Albanian financial community deserves
full recognition. It is remarkable how open the community has been to embrace an innovative
way to operate and how quickly this methodology has become an accepted norm.
In essence, through the SPI Albania experience with its own specific governance, management
and analytical instruments, the Albanian financial community has empowered itself to contribute
to Albania’s accession to the European Union. A useful benchmark for SPI Albania’s activities
is the ECB-hosted European Financial Markets Lawyers Group (www.efmlg.org).
4
5. Prospects
With the benefits of collaboration and coordination well established by now, the SPI Committee4
offers the space to carry on with the financial modernization agenda, which is necessary for
Albania’s convergence with EU institutional and economic standards. Building on financial
stability, financial modernization refers to legislative and regulatory actions that improve the
economic impact of financial intermediation. While the former is under sole Central Bank
responsibility, the latter requires coordinated interventions by several public institutions and civil
society associations and is therefore more difficult to pursue in the absence of an SPI Platform-
like coordination mechanism.
Likewise, public and private institutions will find it advantageous to appoint their best experts to
meet their peers in public-private working groups to share views, influence solution-searching
and, above all, to participate in the step-by-step process of improving the business environment
for financial intermediation, using the EU Better Regulation methodology. Such project working
group gatherings offered fantastic professional learning experiences, enabling the deepening of
professional skills, a particularly important feature given the absence of a bank training center in
Albania.
Key Requirements
Keeping the SPI Albania activities going will require above all organizational and coordination
skills among SPI Albania stakeholders. But it is critical that a local institution replaces the
Convergence Program as the SPI Albania “champion”. While discussions among local
stakeholders will lead to the identification of the institution that will play this role, the SPI
Albania financial modernization agenda will not advance unless the Association of Albanian
Banks plays a prominent role to advocate for it – as do its peers in advanced jurisdictions5. It is
important to recognize that this “champion” role involves civic leadership and responsibility
above all, with very modest financial requirements.
The costs of the part-time technical expertise required to support project working deliberations is
immaterial – in the context of the cost of professional services in Albania. A critical ingredient
to the smooth functioning of the system, and of the good use of the voluntary professional
contributions to project working group activities made by participating institutions, is the
presence of an agile central person with the capacity to bring order and coordinate loose
resources scattered throughout the community. This person is also the “custodian” of the SPI
Committee Terms of Reference (that is, ensuring that SPI activities are conducted in accordance
with the highest standards of public-private governance). The cost to the local community of this
central resource, when calculated on a per project basis, is also immaterial.
While discussions of sharing resources for a common project are never easy, a reasonable
approach could be to share the total cost of technical and coordination resources of about Euro 5
thousand per SPI project between public and private stakeholders. Funding and location
decisions are separate. As during the Convergence Program assistance the central person was
4
The SPI Committee (Terms of Reference) offers a structured context for public-private cooperation through: a) high-
level commitment to financial modernization; b) consensus decision-making; and c) mobilization of local experts of
public institutions, market participants and other institutions to work collaboratively to find practical solutions.
5
European Commission has stated that “Banking associations play a crucial role in the uptake, implementation
and monitoring of the socio-economic acquis”.
5
6. paid by the World Bank and located in AAB premises, in the future another pragmatic
arrangement could emerge. In any case, proving the ability to keep SPI Albania running is a
strong selling point to future donors (e.g., the EU or CIPE) about the depth of management and
technical resources that are available in Albania to manage projects that will contribute to
Albania’s accession to the European Union.
Conclusions
The paucity of resources required to keep the partnership alive pales when compared to the
power of achieving tangible results that this partnership has demonstrated. It is a matter of
dialogue among local stakeholders to proceed to the next step of their partnership: after agreeing
to undertake a common financial modernization program, to share professional resources to
execute it and to reach conclusions by consensus, stakeholders will now have an opportunity to
agree on how best to contribute the little spark that will keep the SPI Albania engine running.
The AAB decision to appoint as Secretary General the former SPI Director, Financial
Modernization Program (and former Bank of Albania staff) was a first visionary step to embed
SPI Secretariat experience in a local institution. With a strong public-private mandate, the new
AAB Secretary General could energize SPI Albania in its next phase under local management.
SPI Albania stakeholders will have the vision and ability to find the right solution to support
Albania’s continuous financial modernization. As Head and Founder of the Convergence
Program, I confirm my full availability to assist the Albanian financial community through this
transition phase.
Main Author:
Luigi Passamonti
lpassamonti@worldbank.org
+1-203-473 5776
This document is posted on the Convergence Program website (www.convergence-see.eu) and will be used for the project completion assessment
required by the World Bank and Italy’s Ministry of Economy and Finance which has co-financed the activities of the Convergence Program.
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7. Annex
Summary Findings of the Evaluation of
SPI Secretariat Activity
Projects
1. Improving Banks Liquidity Risk Management
2. Reducing Cash Transactions
3. Consumer Financial Education
4. IFRS Implementation
5. Improving Auction Procedures: (i) Civil Procedure Code
(ii) Bailiff Practices
I. Statistics of the survey
No. of active Project Working Group members: 52
No. of respondents: 26
Participation ratio: 50 %
II. Summary findings of the survey
No. SPI Secretariat Activity Aspect General For the 5 projects
Assessment
1. Role in organizing PWG activity Very good 5- Very Good
2. Preparation of the Project TORs Very good 5- Very Good
3. Support in organizing PWG meetings Very good 5- Very Good
4. Contribution in helping conduct the PWG Very good 4- Very Good; 1-Good
meeting
5. The records (minutes) of the discussions held Very good 5- Very Good
in the PWG meetings
6. Quality of documentation and information Very good 5- Very Good
7. Quality of the analytical work Very good 5- Very Good
8. Quality of the background documentation Very good 5- Very Good
9. Preparing the Regulatory Impact Assessment Very good 2 Very Good; 1-Good; 2 -n/a
10. Providing international support for the Good 4 – Good; 1- n/a
project
11. Support in preparing the project reports Very good 5- Very Good
12. Correctness in reflecting opinions in the Yes 5- Y
centralized documents
13. Contribution in consensus building Very good 5- Very Good
14. Neutrality and objectivity during PWG Yes 5- Y
discussions
15. Support to PWG in reaching the commonly Yes 5- Y
agreed solutions
16. Correctness in outlining the issues in Yes 5- Y
discussion and in providing solutions in the
project documents
17. Importance of the “honest broker” role Quite 2- Very Important; 3- Quite
played by the SPI Secretariat important Important
19. Information on the progress with non-PWG Yes 5- Y
activities
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8. Main benefits of the SPI Secretariat supporting the public-private partnership
Benefits No. of % of
points max
1. To assemble and support a project working group 21 84
2. To identify issues relevant to public-private stakeholders 22 86
3. To prepare background information and analyses for the project 22 90
working group, including Regulatory Impact Assessment
4. To define a project scope to accurately reflect the needs of all 22 90
stakeholders
5. To keep the project working group work at good pace, anticipating 20 80
and overcoming obstacles
6. To help with consensus-building 21 85
7. To prepare a convincing SPI Committee decision paper 20 81
8. To use technical expertise efficiently to find practical solutions 21 84
9. To keep attention on prompt enactment of issues decided under the 21 87
SPI Albania framework.
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