2011年-IMF国际货币组织全球_Mongolia_Financial_System_Stability_Assessment_31页_1mb

Mongolia: Financial System Stability Assessment Summary

Core Content

This document is the Financial System Stability Assessment (FSAP) on Mongolia, prepared by the IMF staff team on March 3, 2011, based on information available at that time. It outlines the current state of Mongolia's financial system, identifies key vulnerabilities, and provides recommendations for strengthening financial stability.

Main Findings

• Economic Recovery: Mongolia has experienced a vigorous economic recovery since the 2008–09 global crisis, with real GDP growth expected to surpass 10 percent in 2011. The 2009 Stand-by Arrangement (SBA) helped stabilize financial markets.
• Banking Sector Restructuring: The authorities have made progress in restructuring the banking sector by placing two state-owned banks under conservatorship and improving prudential regulations on asset classification and loss provisions.
• Financial Stability: Financial stability has been re-established but remains delicate. The banking system is still vulnerable to credit and market risks, and capital quality is weak.
• Capital Adequacy Ratio (CAR): The system-wide CAR improved to 15.1 percent in 2010, but this is likely overstated due to relaxed provisioning requirements and inadequate risk weighting of interbank exposures.
• Non-performing Loans (NPLs): NPLs declined from 20 percent in 2009 to 8 percent in 2010, but the decline is partly due to the exclusion of the two banks under conservatorship.
• Credit Risk: Credit risk remains the principal vulnerability. Large single borrower and sectoral loan concentrations, as well as related-party lending, increase the risk of systemic failures.
• Liquidity and FX Risk: The banking system has become more liquid, but remains exposed to liquidity risks and foreign exchange (FX) risks due to maturity mismatches and unhedged FX lending.
• Regulatory Framework: The Bank of Mongolia (BOM) permits regulatory forbearance and continues to use compliance-based supervision, which is not forward-looking or risk-based. The BOM is planning to shift toward risk-based supervision.
• Deposit Guarantee: The blanket deposit guarantee provides overly generous coverage and should be replaced with a well-designed deposit insurance scheme.
• Financial Sector Structure: The financial system is dominated by commercial banks, which account for over 95 percent of total financial system assets. The non-bank financial sector is small and underdeveloped.

Key Vulnerabilities

• Credit Risk:
  • Large single borrower and sectoral loan concentrations.
  • Related-party lending due to cross-ownership linkages between banks and industrial companies.
  • A 40% increase in classified loans could undercapitalize five banks.
  • A default by the largest borrower would reduce the system-wide CAR by 3.5 percentage points.
• Liquidity Risk:
  • The ratio of liquid assets to short-term liabilities increased to over 30% in 2010, but the system remains vulnerable.
• FX Risk:
  • Increased foreign currency lending and unhedged exposure.
  • A sharp depreciation of the torog (Mongolian currency) could increase credit risk.
• Regulatory Risk:
  • Weak enforcement of prudential regulations and lack of risk-based supervision.
  • Regulatory forbearance and poor governance in banks.
• Systemic Risk:
  • A default of five medium-sized and small banks could destabilize two other banks, including a systemically important one.
  • The banking system is particularly sensitive to shocks from the construction, mining, and trade sectors.

Key Recommendations

Summary of Financial Soundness Indicators

Conclusion

The assessment highlights the fragility of Mongolia's financial system and the need for reform in both the regulatory and supervisory frameworks. While the economy has shown strong recovery, the banking sector remains exposed to multiple risks, and the deposit guarantee system needs to be overhauled. The recommendations emphasize strengthening capital, enhancing supervision, and developing a robust crisis management framework to ensure long-term financial stability.