2015年-世界发展银行全球_Jamaica___Financial_Infrastructure_Technical_Note_60页_1mb

Jamaica Financial Sector Assessment Program: Payment and Settlement Systems and Credit Reporting Systems Summary

I. Core Content

The Financial Sector Assessment Program (FSAP) in Jamaica, conducted by the World Bank and IMF in 2014, evaluates the country's financial infrastructure with a focus on payment and settlement systems and credit reporting systems. The assessment highlights the importance of these systems in promoting financial inclusion, ensuring financial stability, and mitigating systemic risk. It also outlines key recommendations for improving the legal framework, operational efficiency, and regulatory oversight.

Jamaica has a well-developed payment and settlement infrastructure, which includes central bank money settlement for systemically important payment systems and securities segments. The JamClear-RTGS system plays a central role in this infrastructure, facilitating the settlement of large-value payments, retail ACH, and securities transactions.

The credit reporting system is in a developmental phase, with two operational credit bureaus and a third under license. While the Credit Reporting Act provides a legal basis for credit bureaus, challenges remain in terms of data collection, information sharing, and consumer consent. The BoJ is the main authority overseeing the credit reporting system (CRS), and there is a need for enhanced oversight, interoperability, and legal alignment.

II. Main Points and Recommendations

A. Payment and Settlement Systems

• Legal and Regulatory Framework:

  • The Payment Clearing and Settlement Act (PCSA) and Securities Act (1993) provide a legal basis for netting, finality, and irrevocability of payments.
  • The FSC Act (2001) needs amendments to grant the FSC powers to authorize securities settlement systems (SSS) and central counterparty (CCP) in the corporate securities market.
  • Legal opinion should be obtained to ensure the Securities Act and FSC Act align with Principle 1 of the Principles for Financial Market Infrastructures (PFMIs).

• Large-Value Payment Systems:

  • The BoJ should amend Rule 7.7.6 of the RTGS participant rules to define the time after which unsettled payment instructions cannot be revoked.
  • A Business Continuity Plan (BCP) should be formally adopted, tested regularly, and extended to cover other systems like JCSD and JamClear-CSD.
  • The Intraday Liquidity (IDL) facility should be made available for net settlement batch files to prevent liquidity pressures and systemic risk.

• Retail Payment Systems:

  • BoJ should develop an access policy for retail payment infrastructure, promoting greater inclusivity and efficiency.
  • ATMs should be located in Post Offices to improve access in rural areas, and additional functionalities like bill payments and internet banking should be introduced.
  • Fees and charges for payment services should be compiled and published to enhance transparency and foster competition.
  • Exclusivity arrangements should be prohibited to increase market penetration and competitive pricing.
  • "No frill" accounts should be supported with graded KYC requirements to deepen financial access.
  • A Working Group on Retail Payments should be established under the NPSC, including stakeholders like the Government and remittance companies.

• Government Payments:

  • The Government should develop a strategy to shift G2P payments to electronic modes, improving efficiency and cost reduction.
  • The PATH and NIS schemes should be modernized with retail electronic payment products.
  • The CTMS should be fully leveraged for direct benefit transfers.
  • Moral suasion and statutory powers should be used to prevent restrictive practices.

• Securities Settlement Systems:

  • JamClear-CSD must operate in compliance with Principle 11 of the PFMIs, with robust accounting and reconciliation practices.
  • A study should be conducted on historical data to assess the sufficiency of JCSD's credit facilities and capital to handle defaults.
  • The legal basis for JCSD to function as a SSS and CCP is not available under current provisions, requiring amendments to the Securities Act.
  • As an interim measure, the FSC may obtain legal opinion to determine if contractual arrangements allow JCSD to continue as a SSS or CCP.

III. Credit Reporting Systems

• Legal and Regulatory Framework:

  • The Credit Reporting Act allows for the establishment of credit bureaus, but data collection is slow due to fragmented data structures and lack of standardization.
  • Consumer consent provisions in the Credit Reporting Act are ambiguous, particularly regarding data collection and disclosure.
  • The Prescriptive nature of the law may hinder the inclusion of additional credit information providers (CIPs) such as microfinance institutions and retailers.

• Data Supply and Fragmentation:

  • There is a lack of coordination between public and private sectors in data sharing.
  • Information from public databases such as TRN, Companies Office, Collateral Registry, and utility companies is not currently available in credit bureaus.
  • Credit bureaus operate on reciprocity, which may lead to data fragmentation if not all creditors participate.

• Oversight and Cooperation:

  • The BoJ is the main oversight authority for the CRS, but other government agencies are not involved.
  • A cooperation framework among authorities is needed to enhance the development of a safe, efficient, and reliable credit reporting system.

IV. Key Information

• Jamaica's payment infrastructure is well-developed and centralized, with JamClear-RTGS as the core system.
• Retail payment systems are underdeveloped in rural areas, and ATM access is limited.
• The credit reporting system is in progress, with two operational bureaus and one under license.
• Legal and regulatory improvements are critical for the development of securities settlement systems and credit reporting systems.
• Interoperability and competition are key priorities in retail payment systems.
• Consumer protection and transparency are essential for enhancing trust and promoting financial inclusion.

V. Conclusion

Jamaica has a robust payment and settlement system, but there are opportunities for improvement in regulatory frameworks, data collection, and consumer access. The FSAP recommendations focus on legal alignment, operational efficiency, and enhancing transparency and competition in the retail payment and credit reporting sectors. These steps are crucial for fostering financial inclusion, ensuring financial stability, and supporting economic growth.