2016年-世界发展银行全球_El_Salvador_Financial_Sector_Assessment_Development_Module_23页_510kb
报告摘要
Financial Sector Assessment Summary - El Salvador (November 2016)
Core Content
This Financial Sector Assessment (FSA) provides an overview of the developmental aspects of El Salvador's financial sector as of 2016, based on the 2010 FSAP report. The assessment focuses on several key areas including financial system efficiency, financial inclusion, regulatory perimeter, public sector banks, capital markets, pensions, and insurance. It also outlines recommendations for regulatory and institutional improvements.
Main Highlights
Economic Context
- El Salvador faces a challenging economic environment, characterized by low growth, structural issues, and high levels of crime and political uncertainty.
- The country has been fully dollarized since 2001, contributing to low and stable inflation (1.0% in 2015).
- Real GDP growth averaged 1.9% between 2010 and 2015, with a contraction of 3.1% in 2009 due to the global financial crisis.
- Economic growth is estimated at 2.5% in 2015.
Financial Sector Structure and Efficiency
- The financial system has grown more slowly than the regional average.
- Private sector credit to GDP is below expected levels, and the country lags behind Central American and LAC peers.
- The banking sector is dominated by global and regional financial groups, with foreign ownership being the highest in Central America.
- The top three Colombian financial groups control 54% of banking sector assets, while domestic banks control only 8.3%.
- Concentration in the banking sector has been declining since 2010, with the Herfindahl-Hirschman Index (HHI) being the third lowest in the region.
- Profitability indicators (ROA and ROE) have decreased since 2011 but remain at adequate levels, with ROA slightly above regional averages.
- Credit allocation has shifted towards consumption rather than productive activities.
Financial Sector Infrastructure
- The national payments system (NPS) has consolidated and expanded, but challenges remain in reducing risks and improving efficiency.
- The RTGS system is critical to NPS, settling 1.8 times GDP in 2015, with annual growth of 17% over the past three years.
- Cheques are still dominant in non-cash transactions, particularly high-value ones, and should be reduced.
- The credit reporting system (CRS) is fragmented, hindering creditworthiness evaluation. The SSF is well-positioned to oversee CRS improvements.
- The Law on Credit Histories requires further consideration and secondary regulation by the BCR.
- The BCR should enhance consumer protection guidelines, including clarifying credit reporting rights and data update methods.
- Integration of data sources like CNR is recommended to improve credit behavior evaluation.
Financial Inclusion and Regulatory Perimeter
- Despite some improvements, El Salvador has low access to and use of financial services.
- Reforms are needed to facilitate transaction accounts and strengthen consumer protection.
- Non-discriminatory access to telecommunications infrastructure is recommended for financial institutions.
- A legal framework for factoring should be created to support MSMEs.
- Regulatory perimeter extension to NBSCIs requires careful design, including incentives for compliance and mechanisms to mitigate conflicts of interest.
- INSAFOCOOP should be strengthened to provide prudential supervision of cooperatives outside the SSF's perimeter.
Public Sector and Development Banks
- Bandesal, the main development bank, should refocus on second-tier operations (loans and guarantees) and provide credit enhancements for specific bond issuances.
- First-tier banking should be reserved for large infrastructure and key sector transactions.
- Subsidized interest rate programs should include cost calculations and compensation for public institutions.
- BH and BFA should be supported with increased regulatory capital to expand outreach.
Capital Markets
- Capital markets have seen improvements but remain relatively small.
- The securities issuance process is a bottleneck, requiring more efficient procedures.
- The SSF should streamline the authorization process, implement electronic document systems, and develop a frequent issuers regime.
- Over time, the focus should shift from ensuring issuer solvency to ensuring disclosure.
- Simplifying requirements for foreign securities in the secondary market is needed to increase investment opportunities.
Pensions
- A pension reform is necessary to ensure sustainability of both public and private systems.
- The reform should de-link contribution transfer formulas between pillar 1 and asset portfolios.
- Workers returning their funds should not be penalized for not receiving investment returns.
- Pension funds should be allowed greater flexibility in foreign investments, starting with index/ETF funds.
- The CIP-A debt in pension portfolios should be restructured into 30-year bullet maturity instruments with higher interest rates.
Insurance
- The insurance sector is small but growing, representing 2.4% of GDP.
- The proposed Insurance Companies Law draft should be approved with suggested modifications to compliance functions and solvency calculations.
- The sector should incorporate liquidity risks and consider the treatment of guarantee products as insurance.
- The SSF is transitioning to a risk-based supervision process, which will align with the new risk-based capital law for insurance companies.
- A law on insurance contract provisions is being prepared.
Key Recommendations
| Recommendation | Timeframe | Priority |
|---|---|---|
| Develop a comprehensive payment system law addressing settlement finality and netting | Short Term | Medium |
| Improve RTGS operational risk management and efficiency | Medium Term | High |
| Formalize an oversight framework for financial infrastructure | Short Term | High |
| Clarify BCR regulations on consent clauses, data retention, and consumer protection | Short Term | High |
| Evaluate alternative data for credit reporting systems | Medium Term | Medium |
| SIGET should address discriminatory practices by mobile network operators | Short Term | High |
| Strengthen the draft reform of transparency regulation NPB4-46 | Short Term | Medium |
| Introduce a law on factoring for legal certainty and streamlined processes | Short Term | Medium |
| Develop a consensus draft law for regulatory perimeter extension to cooperatives | Short Term | High |
| Reinforce SSF training for NBSCI supervision | Short Term | High |
| Strengthen INSAFOCOOP's prudential supervision capacity | Medium Term | Medium |
| Refocus Bandesal on second-tier operations | Short Term | High |
| Include cost calculations for subsidized interest rate programs | Short Term | High |
| Support BH and BFA with increased regulatory capital | Medium Term | Medium |
| Streamline securities authorization process | Short Term | High |
| Simplify foreign securities purchase requirements | Long Term | Medium |
| Increase pension funds' foreign investment limits | Medium Term | High |
| Restructure CIP-A debt into 30-year bullet maturity instruments | Short Term | High |
| Approve the updated Insurance Companies Law with compliance and solvency modifications | Short Term | High |
Conclusion
The FSA highlights both progress and challenges in El Salvador's financial sector. While the sector has shown some efficiency gains and structural improvements, there is a need for continued regulatory reform, infrastructure development, and institutional coordination to enhance financial stability, inclusion, and market development. The recommendations aim to align the financial sector with international standards and promote sustainable growth.
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