2011年-世界发展银行全球_Financial_Sector_Assessment_Program_Update___Saudi_Arabia_-_Basel_Core_Principles_for_Effective_Banking_Supervision_41页_1mb

报告摘要

Financial Sector Assessment Program Update: Saudi Arabia

Core Content Overview

This report presents a detailed assessment of the Saudi Arabian Monetary Agency (SAMA) compliance with the Basel Core Principles for Effective Banking Supervision as of September 2011. Conducted by the IMF and the World Bank at the request of Saudi authorities, the assessment was based on a review of legal frameworks, policies, and practices in place at the time. The methodology used the 2006 Basel Committee on Banking Supervision (BCBS) guidelines, and the findings are structured around the 25 Core Principles (CPs).

Key Findings

1. Institutional and Macroeconomic Setting

Banking sector structure: Commercial banks are the largest financial sector in Saudi Arabia, with 23 licensed banks (20 active), of which 12 are Saudi-incorporated banks holding 98% of total banking system assets.
Market concentration: The top seven banks account for 85% of total assets, with the three largest holding about 45%.
Banking performance: The sector is well capitalized and profitable, with a solvency ratio above 17% (end-2010) and a return on assets of nearly 2% and return on equity of 13.6% in December 2010.
Credit and liquidity: Credit growth increased in 2010 after a decline in 2009, with the nonperforming loan (NPL) ratio remaining at 3%. Liquidity appears adequate, and the NPL ratio is covered by provisions of 116%.
Sector characteristics: Loan portfolios are concentrated in sectors like SMEs and housing. Sharia-compliant products are limited to "plain vanilla" structures, and the financial system is relatively simple, centered on core banking activities.

2. Compliance with Basel Core Principles

Core Principle	Grading	Comments
1. Objectives, independence, powers, transparency, and cooperation	LC	SAMA's objectives are not clearly defined. Legal framework (BCL) is outdated and lacks formal independence and transparency.
2. Permissible activities	C	Activities are effectively controlled, and the term "bank" is protected.
3. Licensing criteria	LC	Licensing criteria are not made public, and the "add value" requirement is not aligned with safety and soundness.
4. Transfer of significant ownership	MNC	No legal provisions exist for regulating significant ownership transfers.
5. Major acquisitions	C	Acquisitions are subject to supervisory approval, but limits on investments are not clearly defined.
6. Capital adequacy	C	Minimum capital ratios exceed Basel requirements.
7. Risk management process	LC	Risk management requirements are not directly imposed on foreign branches and are only indirectly applied to banks.
8. Credit risk	LC	Credit risk regulation should be strengthened based on lessons from recent corporate failures.
9. Problem assets, provisions, and reserves	C	Provisions cover NPLs, but on-site assessments of individual risks are lacking.
10. Large exposure limits	MNC	Large exposure limit can be raised to 50% (used by SAMA), but this is not systematically enforced.
11. Exposure to related parties	MNC	Definition of related parties is not comprehensive, and related party exposures are not systematically supervised.
12. Country and transfer risks	C	Risks are low and extensively reported.
13. Market risks	LC	Guidance does not cover all derivative activities and lacks binding rules.
14. Liquidity risk	C	Basel III approach is to be implemented.
15. Operational risk	C	Operational risk is managed, with a capital charge applied.
16. Interest rate risk in the banking book	C	Risk levels are low but considered in internal capital adequacy assessment.
17. Internal control and audit	LC	Framework is comprehensive but outdated.
18. Abuse of financial services	LC	On-site inspections are concentrated on a few years.
19. Supervisory approach	LC	Risk ratings are not differentiated, and risk profiles are not updated annually.
20. Supervisory techniques	LC	Full-scope examinations are not always comprehensive, and limited scope exams focus on compliance.
21. Supervisory reporting	LC	Full-scope inspections do not always assess the reliability of electronic return management systems (ERMS).
22. Accounting and disclosure	LC	Provisioning buffer process is not formalized.
23. Corrective and remedial powers	LC	Formal supervisory actions require external approvals, and there is no specific bankruptcy regime.
24. Consolidated supervision	LC	SAMA lacks clearly defined consolidated supervision powers.
25. Home-host relationships	C	Confidentiality requirements are not lifted when necessary, and no MOUs with foreign supervisors exist.

Main Recommendations

1. Legal and Institutional Reforms

Define SAMA's objectives clearly, with public statements in the short term and revised laws in the medium term.
Update the Banking Control Law (BCL) to reflect modern supervisory needs and to provide SAMA with statutory independence and authority.
Codify and publish all circulars to enhance transparency and clarity.
Introduce legal provisions for significant ownership transfers and major acquisitions.

2. Supervisory Enhancements

Implement a more systematic approach to supervision, including full-scope and focused on-site inspections.
Improve the definition of related parties and connected parties to ensure comprehensive oversight.
Remove the requirement for banks to "add value" when applying for new licenses.
Finalize the draft Memorandum of Understanding (MOU) with the Capital Market Authority (CMA) and initiate exchange of inspection reports and joint on-site work.
Consider establishing a specific bankruptcy and resolution regime for banks.

3. Risk Management and Disclosure

Issue a framework circular that consolidates all key risk management requirements.
Enhance the risk-based approach (RBA) and move towards a more comprehensive and binding system.
Formalize the provisioning buffer process and ensure it is based on clear and updated standards.
Improve the internal control and audit framework to reflect modern practices and ensure it is regularly updated.

4. Accounting and Standards

Ensure full compliance with IFRS and ISA for banks and auditors.
Strengthen Pillar 3 disclosure requirements to provide more transparency and information for stakeholders.

Authorities' Response

The Saudi authorities acknowledged the assessment findings and expressed willingness to implement the recommended reforms.
They emphasized the importance of aligning with international standards, particularly Basel II and III, and improving the legal and regulatory framework to support stronger supervision.
SAMA has initiated efforts to introduce Basel III requirements and improve risk management practices, especially in response to past corporate failures.

Conclusion

The assessment highlights that while SAMA has made progress in banking supervision, particularly with the introduction of Basel II, there are still significant gaps in legal independence, transparency, and the comprehensive supervision of related parties and large exposures. The recommended action plan aims to address these issues by strengthening the legal framework, enhancing supervisory techniques, and aligning with international standards to ensure the resilience and stability of the Saudi banking system.

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