2011年-IMF国际货币组织全球_Germany_Technical_Note_on_Banking_Sector_Structure_33页_933kb

Germany: Banking Sector Structure Summary

Core Content

This technical note from the International Monetary Fund (IMF) provides an in-depth analysis of the German banking sector structure, focusing on its three-pillar system comprising private commercial banks, public sector banks (including Landesbanken), and cooperative banks. The document is based on information available up to July 29, 2011, and outlines the challenges and considerations in the context of the global financial crisis and regulatory reforms.

Main Points

1. Three Pillar System Overview

• Private Commercial Banks: Represent the largest segment by assets, accounting for 36% of the total banking system assets. These include large banking groups (one of which is foreign-owned), medium and small banks, and foreign bank branches.
• Public Sector Banks (Sparkassen and Landesbanken): Account for 31% of total assets. Sparkassen are legally established but effectively controlled by municipalities or rural regions. Landesbanken (LB) were originally central banks for Sparkassen but have expanded into international and wholesale activities.
• Cooperative Banks: Comprise about 2/3 of the institutions and account for 11% of total assets. They are owned by their members, who are typically depositors and borrowers. Their primary role is to support members, but they also serve the general public.

2. Evolution of the System

• The three-pillar structure has remained largely unchanged over the past decade, though consolidation has occurred steadily.
• Since 1990, the number of banks has decreased by 44%, mostly in the Sparkassen and cooperative sectors to achieve economies of scale.
• Some LB have acquired private banks, and cross-border acquisitions have taken place, but public involvement remains high compared to other EU countries.

3. Capitalization and Basel III Challenges

• The banking system is adequately capitalized overall, but capital quality is weak in some institutions.
• Total capitalization reached nearly 15% in 2009 due to public support and balance sheet contraction.
• The presence of hybrid capital (silent participation) is significant, especially in the largest German banks.
• Meeting Basel III requirements will be challenging for some banks due to low internal capital generation and reliance on non-equity capital.
• Sparkassen and cooperative banks are better positioned to meet the new requirements due to higher-quality capital.

4. Leverage and Regulatory Treatment

• German banks have high leverage, which is partly due to the tiered structure and reliance on interbank loans.
• Basel III's zero risk-weight for interbank loans within the same pillar leads to under-estimation of capital requirements.
• The new bank levy introduced by Germany aims to reduce leverage and interconnectedness but is unlikely to have a major impact due to its low level.

5. Asset Quality and Credit Supply

• Non-performing loans (NPLs) are relatively low, with the banking system's NPL ratio slightly increasing after the crisis.
• Sparkassen and cooperative banks have a higher NPL ratio due to lending to SMEs.
• The "house bank" relationship helps to stabilize credit supply and reduce cyclicality in NPLs.
• German banks maintained credit supply during the crisis, with Sparkassen and cooperative banks expanding retail lending.

6. Profitability and Efficiency

• German banks, on average, show lower profitability compared to European peers.
• Private banks had an average after-tax ROE of 7.5% in 1994-2007, slightly higher than Sparkassen and cooperative banks.
• LBs had even lower profitability, with an average after-tax ROE of 3.8% over the same period.
• Profitability is expected to remain low in the medium term due to structural factors rather than cyclical issues.

7. Government Support and State Aid

• Public sector banks received significant state aid during the financial crisis, especially LBs.
• The Sonderfonds Finanzmarktstabilisierung (SoFFin) was established in 2008 with €480 billion to support the banking system.
• By 2010, €29.2 billion of SoFFin funds had been used, and €63.6 billion in guarantees were outstanding.
• SoFFin access was closed by the end of 2010, replaced by a permanent bank resolution framework.

8. Governance and Market Discipline

• Public sector banks are subject to less market discipline than private banks.
• The mutual guarantee system (Gewährträgerhaltung) has been terminated, but grandfathering arrangements remain in place.
• Governance reforms are necessary for banks receiving state aid to ensure long-term viability, including cost-cutting, downsizing, and ownership changes.

Key Information

• Structure: The German banking system is characterized by a three-pillar structure, with distinct roles for private, public, and cooperative banks.
• Regulatory Issues: The zero risk-weight for interbank loans and reliance on hybrid capital are major concerns under Basel III.
• Performance: Despite some recovery post-crisis, profitability remains low, especially for LBs.
• Government Role: Public sector banks have historically been supported by government guarantees and funding, which has contributed to their stability but also raised concerns about political influence.
• Future Challenges: Tightening liquidity regulations, increased capital requirements, and competition from internet banking and demographic changes will continue to affect the sector.

Conclusion

The German banking system, while maintaining stability and effective financial intermediation, faces ongoing challenges related to profitability, capital structure, and regulatory compliance. The three-pillar system, particularly the role of public and cooperative banks, requires structural reforms to ensure long-term resilience and efficiency. The transition to Basel III standards and the need for improved governance are critical for the sector's future.