2016年-世界发展银行全球_Russian_Federation_Financial_Sector_Assessment_Program___Financial_Infrastructure_Technical_Note_43页_1011kb

报告摘要

Summary of Financial Sector Assessment Program (FSAP) on Russian Federation Financial Infrastructure

I. Core Content

The Russian Federation has a well-developed financial infrastructure, particularly in payment and settlement systems, which play a vital role in maintaining financial stability and supporting economic development. The assessment highlights the importance of these systems in enabling the smooth functioning of monetary and capital markets, as well as in the effective implementation of monetary policy.

The key components of the Russian financial infrastructure include the Bank of Russia Payment System (BRPS), the National Settlement Depository (NSD), and the National Clearing Centre (NCC). These systems are crucial for the settlement of transactions, both in cash and non-cash forms, and are considered systemically important. The BRPS includes three subsystems: VER (Intraregional Electronic Payment System), MER (Interregional Electronic Payment System), and BESP (Banking Electronic Speedy Payment System). The NSD functions as a central securities depository (CSD), settlement depository (SD), and trade repository (TR), while the NCC operates as a central counterparty (CCP) and clearing house for various financial markets.

II. Main Points

1. Legal and Regulatory Framework

The legal framework for payment and settlement systems in Russia is spread across several laws, including the CBR law, NPS law, CD law, Securities law, Clearing and Clearing Activities law, Civil Code, and Insolvency law.
The Central Bank of Russia (CBR) provides regulatory instructions, regulations, and directions, which are supplemented by methodological recommendations.
There is a need for comprehensive review and harmonization of the legal provisions to ensure legal certainty and clarity, especially regarding the overriding of settlement finality and insolvency remoteness provisions.

2. Payment System Landscape

The Russian payment system landscape includes systemically important payment systems (SIPS), socially important payment systems (SocIPS), e-money operators, and domestic and international card payment systems.
The Sberbank payment system and Golden Crown payment system are two of the six SocIPS recognized by the CBR.
The MIR card system, a domestic payment system, was launched in December 2015 to enhance payment options and reduce reliance on foreign card systems.

3. Risk Management and Business Continuity

The BRPS and NSD-PS are subject to collateralized liquidity support from the CBR, with a daily mark-to-market mechanism for collateral.
Operational risk mitigation includes physical access control, IT and cyber security, public key encryption, and a secondary site for business continuity.
Business continuity planning is conducted annually, and participants' systems are not tested during these exercises. It is recommended that these systems be included in future testing to ensure alignment with Principle 17 of the PFMIs.
The CBR should consider developing the capability to call for additional collateral on the day of enforcement and ensure that staff relocation does not impact recovery time objectives.

4. E-money Operators

There are 102 e-money operators registered with the CBR, offering non-cash retail payment instruments.
E-money can be loaded through cash, cards, online banking, ATMs, and payment terminals and is used for utility bills, person-to-person transfers, e-commerce, fines, and taxes.
KYC requirements are graded, with different categories for e-money instruments and associated maximum e-money balances.
There is a need for stronger regulations to protect client funds from being used to fulfill other creditor claims in the event of an e-money operator's bankruptcy.
Interoperability between e-money schemes should be encouraged to promote greater usage of e-money.

5. Retail Payments and Financial Inclusion

Cash remains a major mode of retail payment in Russia, but non-cash instruments such as credit transfers, direct debits, payment cards, and e-money are increasingly used.
Payment cards are the most popular non-cash retail payment instrument, with a focus on international brands and the domestic MIR card.
A comprehensive national strategy is needed to increase non-cash retail payments and reduce cash usage, which would support financial inclusion.
The strategy should involve all relevant stakeholders, including the CBR, FMIs, the Government (MOF), MTOs, and e-money operators.

6. National Settlement Depository (NSD)

The NSD is a non-bank credit institution and serves as a CSD, SD, SIPS, and TR.
It is the sole CSD for Russian and foreign securities, with 57% of securities dematerialized and 43% immobilized.
NSD operates on DvP and FoP settlement models for on-exchange and OTC transactions, respectively.
It has segregated assets for participants and clients, and no overdrafts are allowed.
NSD has an operational risk management framework and a recovery plan approved by its Supervisory Board in 2015. It should ensure that link-related risks are included in its overall risk management framework.

7. National Clearing Centre (NCC)

The NCC is a Qualified CCP and a systemically important CCP under the CBR.
It operates as a clearing house and central counterparty for FX, securities, derivatives, and commodities.
The NCC has a Supervisory Board and Management Board, with a Risk Committee that includes Supervisory Board members, CBR representatives, self-regulatory organizations, and Clearing Members.
It has implemented default waterfall procedures and stress collateral to manage participant default.
The NCC collects initial and variation margins across all market segments, based on price volatility, product type, and liquidity.

III. Key Recommendations

The CBR should harmonize and review the legal framework for payment and settlement systems.
Interoperability among SocIPS should be encouraged to expand the reach of cashless payments.
The CBR should explore the possibility of additional collateral during enforcement.
The NSD should test its business continuity plan to ensure end-of-day settlement under adverse scenarios.
The NCC should ensure that the Risk Committee is chaired by an independent and knowledgeable individual and that the majority of members are non-executive.
A comprehensive national strategy should be developed to increase non-cash retail payments, reduce cash usage, and promote financial inclusion.