2014年-IMF国际货币组织全球_Switzerland_Technical_Note_37页_491kb

Summary of the Technical Note on Oversight, Supervision, and Risk Management of Financial Market Infrastructures in Switzerland

Core Content

This document is a Technical Note prepared by the International Monetary Fund (IMF), analyzing the oversight, supervision, and risk management of financial market infrastructures (FMIs) in Switzerland. It was completed on August 20, 2014, and is part of the Financial Sector Assessment Program (FSAP). The report assesses the effectiveness of the current regulatory and supervisory framework, the risk management practices of SIX Group AG, and outlines recommendations for improving the stability and resilience of FMIs in Switzerland.

Main Findings

Financial Market Infrastructures in Switzerland

• FMIs in Switzerland are well-developed, stable, and have operated smoothly for many years.
• The three systemically important FMIs are:
  • SIC AG: Real-time gross settlement (RTGS) system for Swiss franc payments.
  • SIX x-clear AG: Central counterparty (CCP) for securities and derivatives clearing.
  • SIX SIS AG: Securities settlement system (SSS) and central securities depository (CSD), also offering custody services for over 50 foreign markets.
• These FMIs are operated by SIX Group AG, a private entity based in Zurich, which also holds the SIX Swiss Exchange (SSX) and other subsidiaries in financial information and payment card services.
• Overseas FMIs such as CLS, LCH.Clearnet Ltd, and Eurex Clearing AG are also relevant to the Swiss financial system.

Supervision and Oversight

• FINMA and SNB are the primary authorities responsible for supervising FMIs.
  • SNB oversees all payment, clearing, and settlement systems, with a focus on systemically important FMIs.
  • FINMA supervises bank-licensed FMIs, including SIX x-clear AG and SIX SIS AG.
• The regulatory framework is based on statutory law, including the National Bank Act (NBA), National Bank Ordinance (NBO), and FinfraG.
• The NBO was revised in 2013 to align with CPSS-IOSCO Principles for Financial Market Infrastructures (PFMI), enhancing the oversight of systemically important FMIs.
• The FinfraG, expected to be passed in 2014, aims to provide a comprehensive legal basis for the supervision of FMIs, including OTC derivatives and trade repositories.

Key Issues and Recommendations

Supervision and Oversight

• Responsibility A (regulation, supervision, and oversight): FMIs are appropriately supervised, with the SNB and FINMA fulfilling their roles.
• Responsibility C (disclosure): Policies on FINMA's supervision of CCPs and CSDs are not fully transparent.
• Responsibility D (application of principles): FMIs should continue to align with the PFMI.
• Responsibility E (cooperation): Cooperation between domestic and international authorities is encouraged, especially in crisis management.

Recommendations:

• The FinfraG should be passed by Parliament.
• FINMA should fulfill its vacancies and publicly disclose its policies related to FMIs.
• SNB and FINMA should hold a firm stance on the full implementation of the PFMI.
• Domestic and foreign cooperation arrangements should be upgraded to handle crisis events effectively.

Risk Management

• SIX Group AG has a comprehensive risk management framework, but it has gaps that need to be addressed.
• Principle 3 of the PFMI is used as the basis for the risk management assessment of SIX Group AG.

Recommendations:

• Ensure the independence of risk management functions within SIX x-clear AG and SIX SIS AG.
• Improve the risk management framework of SIX Group AG to address interdependencies.
• Develop a recovery plan for FMIs in line with international guidance.
• Implement a comprehensive liquidity risk management framework for CCPs and CSDs.
• Fully implement segregation and portability of positions and collateral at the CCP.
• Ensure public disclosure of responses to the international agreed disclosure framework for FMIs.

Conclusion

Switzerland has a well-established and stable FMI system, but there are opportunities for improvement in risk management and supervision transparency. The FinfraG and the revised NBO are key steps toward aligning the Swiss FMI system with international standards. The SNB and FINMA are encouraged to maintain a firm stance on the implementation of PFMI and to develop a dedicated crisis management framework.

Key Terms

• FMIs: Financial Market Infrastructures
• PFMI: CPSS-IOSCO Principles for Financial Market Infrastructures
• CCP: Central Counterparty
• CSD: Central Securities Depository
• SIC: Swiss Interbank Clearing
• SIS: SegaInterSettle
• SNB: Swiss National Bank
• FINMA: Swiss Financial Market Supervisory Authority
• FinfraG: Swiss Financial Market Infrastructure Act

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