2015年-IMF国际货币组织全球_Bosnia_and_Herzegovina_Financial_Sector_Assessment_Program_75页_646kb

Summary of the Detailed Assessment of Observance of the CPMI-IOSCO Principles for Financial Market Infrastructures in Bosnia and Herzegovina

Core Content

The document presents a detailed assessment of the observance of the CPMI-IOSCO Principles for Financial Market Infrastructures (PFMIs) in Bosnia and Herzegovina (BiH), focusing on the Real-Time Gross Settlement (RTGS) system and the responsibilities of the authorities overseeing financial market infrastructures (FMIs). The assessment was conducted by an IMF staff team during the 2014 Financial Sector Assessment Program (FSAP) mission, and the findings are based on the legal, operational, and supervisory frameworks in place.

Main Views and Key Findings

Payment System Landscape

• Bosnia and Herzegovina has four FMIs, including two interbank payment systems (RTGS and Giro Clearing System - GCS), two central securities depositories (CSDs), and international payment clearing services.
• The RTGS system handles large-value interbank transfers and is the most significant FMI in BiH. It was introduced in 2001 and has grown significantly in volume and value, reaching KM 63 billion in 2013 (2.42 times GDP).
• The GCS system processes low-value and non-urgent transactions on a same-day basis and is also considered systemically important.
• The RTGS system is used for interbank payments above KM 10,000 and supports both high and low-value transactions, including settling GCS net balances at three daily intervals.
• The RTGS system is owned and operated by the Central Bank of Bosnia and Herzegovina (CBBH), and all large-value transfers are routed through the SWIFT network.

Central Securities Depositories and Settlement Systems

• Each entity (Republic Srpska and Federation of Bosnia and Herzegovina) has its own CSD, which also functions as a securities settlement system.
• The Central Registry of Securities (CRS) in Republic Srpska and the Registry of Securities of the Federation of Bosnia and Herzegovina (RVP) in the Federation are key components of the securities settlement landscape.
• Both systems use delivery versus payment (DVP) models for settlement, with different cycle lengths (T+3 and T+2).
• Securities are held in dematerialized form and are assigned ISIN codes.
• A guarantee fund is in place to protect members against potential defaults, with basic and additional payments contributing to its funding.

Regulatory, Supervisory, and Oversight Structure

• The CBBH is the primary authority responsible for overseeing the RTGS system and has legal powers to promote and maintain appropriate payment and settlement systems.
• The CBBH also oversees interbank payment operations, reserve requirements, and money market activities.
• The Payment Systems Department (PSD) is responsible for the operational management of the RTGS and GCS systems, with a disaster recovery site located 200 km away to ensure business continuity.
• Entity Banking Agencies (BARS and FBA) are responsible for licensing and revoking authorization for internal payment operations and are empowered to monitor the financial soundness of banks.

Observance of the CPMI-IOSCO Principles

• The RTGS system has good compliance with many PFMIs principles, but there are key areas for improvement:
  • Legal basis: While sound, legal certainty regarding settlement finality and netting is lacking. An explicit law on settlement finality or the elimination of 'zero-hour rules' in insolvency is recommended.
  • Risk management: A comprehensive risk management framework is needed, including formal risk identification, mitigation measures, and ongoing monitoring.
  • Liquidity risk: Despite being generally effective, it is concentrated among five banks. Stress testing and throughput rules are suggested.
  • Operational risk: A recovery time objective (RTO) of two hours is recommended. The disaster recovery site is well-established but lacks formal documentation.
  • Efficiency and effectiveness: Fee schedules should be reviewed and updated to reflect costs. Minimum service levels should be established, monitored, and disclosed.

Authorities' Responsibilities

• The CBBH has limited oversight powers over payment systems, as its legal mandate primarily focuses on operational responsibilities.
• Recommendations include:
  • Strengthening the legal framework to designate payment systems and protect settlement finality and netting.
  • Adopting the PFMIs principles into the regulatory framework.
  • Establishing a dedicated oversight unit within the PSD with sufficient resources.
  • Developing Memoranda of Understanding (MOUs) to enhance cooperation and oversight among relevant authorities.

Key Information

• The RTGS system was the first in the former Yugoslavia to dismantle the old payment system, leading to efficiency gains and risk reduction.
• The currency board arrangement reduces credit risk by prohibiting intraday credit and enforcing reserve requirements.
• The interbank payment system functioned normally after the 2014 floods, demonstrating resiliency.
• The transaction and credit registries managed by the CBBH are used to monitor financial integrity, assess creditworthiness, and prevent illegal activities.
• The guarantee fund for the CRS and RVP is not yet used but is a critical risk mitigation tool.

Tables and Figures

• Table 1: Annual transaction volume and value processed by FMIs in 2013.
• Table 2: Ratings summary of the RTGS system.
• Table 3: Ratings summary of authorities' responsibilities.
• Figure 1: Overview of the trading, clearing, and settlement organization.

Conclusion

The assessment highlights significant progress in modernizing the payment system in BiH, particularly through the RTGS and GCS systems. However, there are gaps in legal certainty, risk management, and supervisory capacity that need to be addressed to ensure the resilience and stability of the financial market infrastructure. Strengthening the legal and supervisory frameworks is essential to align with international standards and enhance the efficiency and effectiveness of payment systems in BiH.