2011年-IMF国际货币组织全球_United_Kingdom_The_Future_of_Regulation_and_Supervision_Technical_Note160_28页_478kb

Summary of "United Kingdom: The Future of Regulation and Supervision" Technical Note (July 2011)

Core Content

This technical note provides an analysis of the United Kingdom's proposed reforms to its financial regulation and supervision framework, aiming to enhance financial stability and align with international standards. The reforms are part of the broader Financial Sector Assessment Program (FSAP) and reflect the UK government's response to the financial crisis, particularly in addressing the limitations of the previous tripartite system involving the Bank of England (BoE), Her Majesty’s Treasury (HMT), and the Financial Services Authority (FSA).

The proposed structure introduces a "three peak" model, which includes:

• Prudential Regulation Authority (PRA): A new prudential regulator, a subsidiary of the BoE, responsible for prudential supervision of financial firms.
• Financial Policy Committee (FPC): An independent committee of the BoE, tasked with macro-prudential oversight and stability.
• Financial Conduct Authority (FCA): A new body focusing on market conduct and consumer protection.

The goal is to integrate macro-prudential and micro-prudential approaches, while ensuring clarity in mandates and responsibilities.

Main Views and Key Points

1. Strategy and Objectives

• The UK authorities have a comprehensive strategy to improve the prudential regulation and supervision framework.
• The strategy emphasizes the integration of macro-prudential considerations with micro-prudential regulation.
• A key notion is that firm failures do not necessarily imply a failure of the regulatory system.

2. Mandate Clarification

• The current mandates of prudential bodies are considered unclear, and the authorities are working to clarify them.
• The PRA is given a clear statutory objective to promote system stability, safety, and soundness.
• The FSA’s mandate did not explicitly include prudential supervision, which is now more clearly defined for the PRA.

3. Governance and Coordination

• The new framework includes a well-developed coordination and cooperation mechanism.
• A formal or informal forum for relationship building among regulatory agencies is recommended to enhance effectiveness, especially during crises.
• The FPC is expected to work closely with the PRA and FCA, with the PRA having the authority to veto FCA decisions that could lead to instability.

4. Macro-Prudential Policies

• The FPC will be responsible for macro-prudential analysis, including systemic risk identification and management.
• The proposed macro-prudential tools include countercyclical capital buffers, leverage limits, and variable risk weights.
• The mission supports the idea of a proactive intervention framework, which allows for early action to prevent material problems.

5. Implementation and Challenges

• The implementation of the new framework is assessed as medium-high risk due to uncertainty in timing and practical challenges.
• The authorities recognize the need for continued leadership involvement and the importance of managing expectations.
• The mission emphasizes the importance of maintaining a clear focus on the objectives of the new framework and avoiding dilution of responsibilities.

6. Resource and Process Considerations

• The mission highlights the need for a more focused and efficient supervisory process.
• It recommends that the authorities define the desired supervisory operating model and assess resource requirements.
• The new approach should not divert resources from micro-prudential enhancements, which are still in development.

7. International Alignment

• The proposals align with international standards and practices, including those of the Basel Committee on Banking Supervision (BCBS), International Association of Insurance Supervisors (IAIS), and International Organization of Securities Commissions (IOSCO).
• The UK is also expected to interact effectively with the European Financial Stability Board (EFSB) and European Supervisory Authorities (ESAs).

Key Recommendations

• Ensure clarity in the mandates of the PRA, FCA, and FPC to avoid confusion and promote accountability.
• Maintain a clear distinction between macro-prudential and monetary policy to prevent blurred accountability.
• Implement a proactive intervention framework and include it in relevant legislative mandates.
• Develop a well-defined and evolving macro-prudential risk framework with input from the PRA and FCA.
• Continue to improve the supervisory operating model by integrating specialist and supervisory work, and by focusing on key risk areas.
• Avoid false precision in the new systemic add-ons and remain realistic about the time frame for major enhancements.
• Preserve successful elements of the current system, such as stress testing and enhanced supervision under the Core Prudential Program (CPP).

Conclusion

The UK's proposed regulatory and supervisory reforms are seen as a significant step toward enhancing financial stability and aligning with international standards. The mission supports the strategy and acknowledges the high quality of resources being devoted to its implementation. However, it emphasizes the importance of clear mandates, effective coordination, and realistic expectations to ensure the success of the new framework.