FSB全球金融稳定委员会-Peer-Review-of-Germany_41页_750kb

Peer Review of Germany Summary

Core Content

This report presents the findings and conclusions of the second Financial Stability Board (FSB) peer review of Germany, conducted in 2020. The review focuses on Germany's macroprudential policy framework and tools, including its ability to collect and analyze data, assess risks from non-bank financial intermediation (NBFI), and implement reforms in response to FSB and FSAP recommendations.

The peer review was based on responses to a questionnaire by German financial authorities and discussions within the FSB's Standing Committee on Standards Implementation (SCSI). It was prepared before the onset of the COVID-19 pandemic, so it does not include detailed analysis of recent market developments or actions taken by German authorities in response to the pandemic.

Main Findings

• Macroprudential Framework: Germany has a well-established macroprudential framework through the Financial Stability Committee (FSC), which adopted its strategy in 2014. The FSC includes the Bundesbank, BaFin, and BMF as members and serves as a central point for macroprudential surveillance.
• Data Collection and Analysis: While progress has been made in data collection, there remains a significant gap in granular and timely information on residential real estate financing. The FSC and Bundesbank have improved data integration and quality, but more work is needed to address these gaps.
• Policy Tools: Germany has introduced two borrower-based macroprudential tools for residential real estate loans: a loan-to-value (LTV) cap and amortisation requirement. The countercyclical capital buffer (CCyB) was activated in 2019 and later reduced to 0% due to the pandemic. There is a need to expand the macroprudential toolkit with income-based instruments.
• NBFI Risk Management: The FSC regularly discusses NBFI-related risks, particularly in the investment fund sector. BaFin has enhanced its risk classification methodology and introduced new liquidity risk management tools, such as notice periods, redemption gates, and swing pricing. The use of side pockets for open-ended funds could also be considered.
• Communication and Transparency: The FSC's communication strategy is focused on transparency and public understanding of its macroprudential mandate. However, it lacks a formal calendar for meetings and does not publish minutes or records of quarterly discussions. Enhancing communication channels and regularity could improve its effectiveness.

Key Recommendations

1. Enhance Data Collection:

   • Establish regular, consistent, and granular reporting on lending standards for residential real estate loans.
   • Continue improving the quality and integration of data for macroprudential analysis, including for NBFI and interconnectedness.

2. Strengthen Communication and Transparency:

   • Introduce additional periodic communication channels to enhance market participants' awareness and understanding of the macroprudential framework.
   • Expand the analysis of non-bank and emerging risks as part of the ongoing FSC strategy review.

3. Expand the Macroprudential Toolkit:

   • Implement income-based instruments such as debt-to-income (DTI) and debt-service-to-income (DSTI) caps for residential real estate financing, as recommended by the FSC in 2015.

4. Extend Liquidity Risk Management Tools:

   • Consider extending the set of liquidity risk management and pricing tools for investment funds.
   • Provide guidance on the use of these tools, especially in stressed market conditions.

Document Structure

• Introduction: Outlines the purpose and background of the peer review, noting that Germany's first review was in 2014 and that the current review is based on the FSB Handbook.
• Macroprudential Policy Framework and Tools: Details the background, institutional arrangements, data collection, and policy tools for macroprudential analysis.
• Assessing and Managing Risks from NBFI: Focuses on the analytical framework, data for NBFI, and policy tools used to manage financial stability risks from non-bank financial intermediation.
• Conclusions and Recommendations: Summarizes the key findings and provides actionable recommendations to the German authorities.

Annexes

• Annex 1: Overview of Germany's implementation of G20 reforms as of September 2019.
• Annex 2: Description of the main instruments available to the German authorities for macroprudential purposes.

Additional Notes

• The FSC is a confidential body that issues warnings and 'comply or explain' recommendations, which must be addressed by relevant institutions.
• The FSC's role in crisis management is defined in the Financial Stability Act, but it does not have a formal role in operational decision-making.
• The report emphasizes the need for continued improvements in data availability, policy toolkit expansion, and communication strategies to ensure the effectiveness of macroprudential policies.