2009年-世界发展银行全球_Belarus___Financial_Sector_Assessment_20页_765kb

Belarus Financial Sector Assessment Summary

I. Overall Assessment

The Belarusian financial sector has shown resilience to recent strains, with satisfactory bank performance indicators and a relatively high capital adequacy ratio. However, it faces growing challenges due to a less forgiving external environment and a slowdown in key trading partners like Russia. The financial system is particularly vulnerable to credit, foreign exchange, and liquidity risks.

Key Findings

• Capital Adequacy: The capital adequacy ratio is overstated by 2-3 percentage points due to improper loan classification and under-provisioning of loan-loss reserves.
• Systemic Stability: The adoption of a blanket deposit guarantee in early 2008 helped maintain stability.
• Government Influence: Pervasive government involvement in the financial sector, including state ownership of banks and non-financial enterprises, and directed lending programs, has constrained the development of a sound and sustainable financial system.

Key Recommendations

• Overhaul the directed lending mechanisms.
• Establish a dedicated agency to fund public sector lending outside the banking sector.
• Transfer government deposits from banks to the NBRB.
• Offer SOE deposits to banks on a competitive basis.
• Engage an experienced consultant to support the privatization of Belarusbank.
• Strengthen the independence of the NBRB Board and bank supervisory processes.
• Improve corporate governance requirements for banks.

II. Financial System Structure

The financial system in Belarus is dominated by banks, with a high degree of concentration. As of June 2008:

• Total Commercial Banks: 28 (down from 30 in 2004)
• State-Controlled Banks: 5 (representing 76% of total assets)
• Foreign-Owned Banks: 16 (representing 20% of total assets)
• Private Banks: 7 (representing 2.1% of total assets)

The insurance sector is small, with only 23 insurance organizations (0.9% of GDP), and is heavily concentrated with state ownership. The securities market is underdeveloped, with government securities dominating the market and limited private debt issuance.

III. Financial Sector Performance and Vulnerabilities

A. Financial Soundness Indicators

• Capital Adequacy Ratio: 16.5% in September 2008, but likely overstated due to inadequate loan loss provisioning.
• Non-Performing Loans (NPLs): Reported NPLs to gross loans ratio was less than 1% in mid-2008, down from 2% in 2005.
• Profitability and Liquidity: Return on equity was 12%, return on assets was 1.7%, and liquidity was 20.7%.
• Risk Absorption: Banks' ability to absorb risks is likely overstated due to poor loan classification and provisioning practices.

B. State Influence in Lending

• State Programs: Up to 30 state programs existed in 2008, with the majority of recommended loans distributed by the two largest state-owned banks.
• Loan Distribution: Over 40% of new loans in one of the largest banks were under state programs.
• Loan Allocation: State influence distorts competition, undermines credit underwriting, and results in higher borrowing costs for the real sector.
• Guarantees: Government guarantees have been a key factor in supporting the banking sector, but they pose long-term risks.

Key Recommendations

• Reform the directed lending system.
• Create a new development agency to handle public sector lending.
• Ensure transparency and competitiveness in the allocation of state funds.
• Enhance risk-based pricing and remove interest rate ceilings.

IV. Financial Regulation and Supervision

A. Banking Sector

• Regulatory Framework: The banking code was enacted in 2006, and secondary legislation is regularly updated.
• Supervision: The General Directorate for Banking Supervision (GDBS) is transitioning to risk-based supervision but lacks corporate governance requirements.
• Capital Adequacy: The framework needs improvement to reflect the structure of the banking sector accurately, particularly with regard to credit risk.

B. Insurance Sector

• Regulatory Framework: The insurance sector lacks sound governance and has limited operational independence.
• State Dominance: State-owned companies receive the majority of insurance premiums (90%), and private insurers face restrictions.
• Reinsurance: A new state-owned reinsurance company has a legal monopoly, requiring local insurers to cede a significant portion of their reinsurance.

C. Securities Markets

• Supervision: The Securities Department (SD) of the Ministry of Finance oversees the securities market, but lacks clear mandates, operational independence, and financial autonomy.
• Legal Gaps: There are no laws governing Self Regulatory Organizations (SROs) or investment funds.
• Staffing Issues: The SD faces challenges in attracting and retaining experienced staff due to inadequate salaries.

V. Financial System Safety Net and Bank Resolution Framework

A. Crisis Preparedness and Coordination

• Crisis Framework: A formal crisis management framework should be established among the NBRB, MOF, and DIF, including practical guidelines and information exchange routines.
• Crisis Manual: A "crisis manual" should be developed to outline procedures for crisis resolution, coordination, and communication.

B. Emergency Liquidity Assistance (ELA)

• Framework: A documented policy for ELA should be developed, including guidelines for eligible collateral and terms for assistance.
• Collateral: The eligible collateral base is limited, representing only 6.2% of banks' assets as of June 2008.
• Moral Hazard: ELA should be accompanied by punitive interest rates to prevent moral hazard.

C. Deposit Insurance

• New Law: A new deposit insurance law was passed in July 2008 and will be effective in January 2009.
• Equity: The law treats state and non-state banks equally, improving the competitive environment.
• Implementation: The law aims to simplify the complex system of deposit insurance and enhance transparency.