2017年-IMF国际货币组织全球_Botswana_Technical_Assistance_Report_108页_1mb

Summary of the Technical Assistance Report: Banking Sector Safety Net and Crisis Management in Botswana

Core Content

This Technical Assistance Report (TAR) was prepared by the International Monetary Fund (IMF) in February 2017, following a mission to Botswana in early 2016. The report focuses on improving the banking sector safety net and crisis management framework to align with international best practices. It outlines key areas for reform, including corrective action, emergency liquidity assistance (ELA), and bank recovery and resolution.

Main Recommendations

The report contains a list of key recommendations aimed at strengthening the legal and institutional framework for dealing with bank distress and failure in Botswana. These recommendations are divided into three main categories:

1. Bank Corrective Action

• Amend the legislation (Banking Act and Bank of Botswana Act) to strengthen the legal powers of the Bank of Botswana (BoB) to respond to banking problems quickly and decisively.
• Develop a corrective action framework and contingency plan to address banking problems.
• Strengthen the early warning system to enable early detection of bank stress and liquidity vulnerabilities.

2. Emergency Liquidity Assistance (ELA)

• Review the existing liquidity management capabilities of the banking system, including the effectiveness of current BoB liquidity-providing market operations and the functioning of the interbank market.
• Establish an ELA framework with clear internal governance and authorization procedures.
• Define clear criteria for when and why to provide ELA funding, including solvency, systemic importance, viability, and capital assessments.
• Document and authorize ELA principles, guidelines, and criteria to ensure adequate collateralization and minimize potential losses.
• Develop a detailed and robust collateral assessment and valuation approach.
• Establish clear trigger points and metrics for ongoing assessment of ELA provision to counterparties.

3. Bank Recovery and Resolution

• Develop a framework for ex post monitoring of banks’ use of funds, business practices, and transactions, as well as any additional conditionality imposed on ELA borrowers.
• Revise and strengthen the proposed amendments to the BoBA and BA to establish a comprehensive set of powers for bank recovery and resolution, benchmarking against the FSB Key Attributes.
• Develop and implement policies requiring all banks to establish and regularly test recovery plans.
• Develop policies for resolvability assessments and resolution plans for systemically important banks (D-SIBs), and other banks if resources permit.
• Establish a Financial Stability Council (FSC) to coordinate between the BoB, the Ministry of Finance and Development Planning (MFDP), and the Nonbank Financial Institutions Regulatory Authority (NBFIRA) on financial stability (including resolution) issues.
• Establish a Financial Stability Committee (FSCOM) within the BoB to oversee and coordinate all aspects of financial stability, involving representatives from banking supervision, resolution team, financial markets, and payment systems.
• Establish a multilateral Memorandum of Understanding (MOU) between the BoB, MFDP, and NBFIRA on financial crisis resolution.
• Establish liquidity management and bank recovery and resolution MOUs with foreign counterparts and participate in cross-border crisis management groups for systemically important banks.
• Develop a program of workshops, staff training, and regular bank crisis exercises to build institutional capacity for crisis resolution.
• Develop comprehensive policy proposals for a deposit insurance scheme, with a view to establishing it within the next two to three years.
• Develop comprehensive policy proposals for resolution funding arrangements beyond deposit insurance, including associated safeguards.

Key Information

Institutional and Legal Framework

• The current legal framework for bank resolution and crisis management in Botswana is weak and requires significant amendments.
• The BoB lacks sufficient legal powers to resolve distressed banks effectively, including the ability to take corrective actions, apply for judicial winding up, or impose business restrictions.
• The Bank of Botswana Act (BoBA) and Banking Act (BA) need to be revised to provide a more comprehensive legal basis for crisis management and bank resolution.

Financial Sector Overview

• The banking sector in Botswana is relatively small, with assets to GDP at 55% and credit to GDP at 32% as of end-2015.
• The sector is moderately concentrated, with four banks holding 79% of banking assets and two holding 46% of total assets.
• The nonbank financial institutions (NBFI) sector is larger, with assets under management reaching 44% of GDP for investment institutions and 41% for pension funds.
• There are significant cross-linkages between NBFIs and commercial banks, with NBFIs’ wholesale deposits accounting for nearly 10% of total bank deposits.

Current Challenges

• The economic slowdown and reduction in policy rates have led to declining interest margins and tightened liquidity.
• The BoB has limited powers for corrective actions and resolution, and its liquidity management needs reassessment.
• The absence of deposit insurance creates a significant gap in the crisis management framework, increasing the risk of depositor runs and bank contagion.

Resolution Funding

• A resolution funding mechanism is needed beyond deposit insurance, with the government as the initial provider of funding.
• Funding should be subject to clear preconditions, terms and conditions, and robust safeguards to ensure it is only used as a last resort after loss absorption by shareholders and creditors.

Coordination and Capacity Building

• Domestic coordination between the BoB, MFDP, and NBFIRA is essential, and an inter-agency Financial Stability Council (FSC) is recommended.
• Cross-border coordination should be strengthened, especially with regard to foreign-owned banks.
• Capacity building is necessary for the BoB, including the development of legal expertise, ELA legal agreements, and risk assessment frameworks.

Conclusion

The report emphasizes the need for a comprehensive and legally robust framework for bank recovery and resolution in Botswana. It highlights the importance of legal clarity, early warning systems, effective liquidity management, and institutional coordination. The recommendations are categorized into short-term and medium-term actions, with the BoB and MFDP as the main responsible authorities. The development of a deposit insurance scheme and resolution funding arrangements is also strongly encouraged to enhance financial stability and crisis management capabilities.