2014年-FSB全球金融稳定委员会_Report_on_Shadow_Banking_in_the_Americas_29页_655kb

Summary of the FSB Regional Consultative Group for the Americas Shadow Banking Report

Core Content

This report, prepared by the Financial Stability Board (FSB) Regional Consultative Group for the Americas (RCGA), provides an analysis of shadow banking activities in the region. It outlines the methodology and findings of a "macro-mapping" exercise conducted by the Working Group on Shadow Banking (WGSB) to monitor and understand the risks associated with non-bank financial intermediation.

The report is part of the FSB's broader effort to enhance the oversight and regulation of shadow banking globally. It highlights the importance of monitoring shadow banking to mitigate systemic risks and promotes a more resilient credit intermediation system.

Main Objectives

• To design a shadow banking monitoring exercise for RCGA jurisdictions based on the FSB Analytical Group (AGV) methodology.
• To provide a macro-mapping component, combined with jurisdiction-specific analysis of shadow banking's role, connections to the traditional banking sector, and potential risks.
• To propose recommendations and identify future challenges for improving shadow banking oversight in the region.

Key Findings

1. Shadow Banking in the Americas

• Shadow banking is defined as "credit intermediation involving entities and activities outside the regular banking system."
• The WGSB macro-mapping exercise collected valuable data on non-bank credit intermediation across 12 participating jurisdictions.
• The exercise helped disseminate the AGV methodology to non-FSB members and initiated an understanding of the role of International Financial Centers (IFCs) in global non-bank credit intermediation.

2. Structure of Financial Systems

• Banks dominate financial activities in most WGSB jurisdictions, holding close to 40% of financial assets.
• The share of banks has declined due to higher growth in Other Financial Intermediaries (OFIs).
• OFIs and Pension Funds and Life Insurance Companies are relatively more significant in WGSB jurisdictions compared to the average AGV jurisdiction.
• Non-bank deposit-taking institutions (DTIs) are relatively small in both groups of jurisdictions.

3. Size and Growth of the OFI Sector

• The OFI sector is heterogeneous across WGSB jurisdictions when measured against GDP.
• The Cayman Islands has the largest OFI sector relative to GDP, followed by the United States and others.
• Investment funds and broker dealers are the largest subsectors of OFIs in the region.
• Structured finance vehicles contracted almost 10% in 2012, while "Other investment funds" and U.S. holding companies showed the highest growth rates.

4. Connections with the Banking System

• In several jurisdictions, OFIs are significant sources of funding for banks.
• Exposures to OFIs account for close to 10% of bank assets in Canada.
• Interconnections between banks and the OFI sector are generally low in most WGSB jurisdictions, but may be underestimated due to the exclusion of off-balance sheet positions.

5. Role of IFCs in Shadow Banking

• Three jurisdictions (Cayman Islands, Panama, and Uruguay) are identified as IFCs.
• The Cayman Islands has the most significant offshore activities, with USD 3.3 trillion in offshore assets, equivalent to almost 1600 times GDP and 21 times total domestic assets.
• Offshore assets in Panama are USD 16.6 billion, or 45% of GDP.
• Uruguay's IFC activities are much smaller and have been declining since 2004.

6. Data Limitations and Challenges

• The Cayman Islands Monetary Authority (CIMA) faces significant data restrictions that limit the ability to measure and separate onshore and offshore activities.
• These include:
  • Securitization vehicles not being required to register with CIMA.
  • Broker-dealers not required to report assets if they serve specific groups or are regulated elsewhere.
  • Closed-ended private funds and funds with fewer than 15 investors not being required to report to CIMA.

7. Non-Bank Deposit-Taking Institutions

• Financial cooperatives (credit unions, savings and loans, building societies) are the most common form of non-bank DTIs in the Americas.
• These institutions are generally not Basel-compliant and provide services similar to traditional banks.
• They are considered a potential source of regulatory arbitrage, especially if banks adopt Basel III rules.
• They also hold a large number of small deposits, which could have a significant negative impact on public trust in the financial system.

Conclusion

The WGSB's macro-mapping exercise has provided a valuable framework for understanding shadow banking in the Americas. It has highlighted the diversity of financial systems, the role of OFIs, and the importance of IFCs in facilitating non-bank credit intermediation. The exercise also identified key risks and data gaps that require further attention and improvement in regulatory oversight.