2012年-IMF国际货币组织全球_Czech_Republic_Technical_Note_on_Crisis_Management_and_Bank_Resolution_Framework_31页_753kb

Czech Republic: Technical Note on Crisis Management and Bank Resolution Framework (July 2012)

Core Content Overview

This technical note provides an assessment of the Czech Republic's crisis management and bank resolution framework, highlighting strengths and weaknesses in light of the global financial crisis and future risks. The document is part of the Financial Sector Assessment Program (FSAP) Update and outlines key recommendations to enhance the resilience of the Czech financial system.

Main Views and Observations

Crisis Prevention

• Overall Observation: Measures to prevent crisis—primarily microprudential supervision—should be more robust.
• Key Findings:
  • Supervisory practices have weaknesses, including insufficient intrusiveness and lack of proactivity in addressing emerging risks.
  • The CNB should increase the frequency of supervisory inspections, including for smaller entities and affiliated nonregulated entities.
  • Supervision should focus on monitoring subsidiaries of foreign banks, especially given the uncertain economic environment.

Crisis Preparedness

• Overall Observation: Authorities could enhance their crisis preparation efforts, especially in light of recent global economic events.
• Key Findings:
  • More frequent and formal coordination between the CNB, DIF, and MOF on crisis management issues is needed.
  • Scenario analysis and annual crisis management simulation exercises should be conducted to test and strengthen preparedness.
  • The CNB should have an explicit financial stability objective to act effectively as a resolution authority.
  • An industry-funded resolution fund could be established to reduce public costs in future crises.

Crisis Management

• Overall Observation: The Czech crisis management framework includes important tools but requires addressing certain weaknesses.
• Key Findings:
  • The CNB has the authority to appoint a conservator but the current threshold for doing so is based on systemic importance, which is difficult to determine.
  • A more flexible threshold should be adopted, incorporating both qualitative and quantitative criteria.
  • The liquidation and insolvency framework for banks needs to be more tailored, allowing for the rapid transfer of critical banking functions to a bridge bank or healthy institution.
  • The DIF should be granted expanded powers to contribute to bank resolution, including the ability to provide financial support for purchase-and-assumption transactions.
  • The DIF should be given preferential treatment in insolvency proceedings to promote effective recoveries.

Institutional Framework

Mandates and Division of Labor

• The CNB serves as the central bank and integrated financial sector supervisor, with primary objectives of price stability and secondary objectives of supporting general economic policies.
• Despite these mandates, the CNB is recognized as the primary authority for financial stability, including crisis management and resolution.
• The MOF is the fiscal authority and the only body empowered to propose financial market legislation, including crisis management and resolution measures.
• The DIF is responsible for compensating depositors but lacks the authority to directly contribute to bank resolution, which is a limitation.
• The judicial system handles bank liquidation and insolvency proceedings and adjudicates legal disputes related to crisis management.

Interinstitutional Coordination and Exchange of Information

• Coordination mechanisms between the CNB, MOF, and DIF are not fully implemented or sufficiently clear.
• The CNB and MOF have a Memorandum of Understanding (MOU) for crisis management, but it has not been effectively utilized.
• The DIF lacks formal legal obligations for cooperation with the CNB and MOF, and there is no MOU in place for such cooperation.
• The CNB should provide more explicit notice to the DIF regarding actions that could impact it, and formal coordination arrangements should be strengthened.

Key Recommendations

• Strengthen Supervisory Practices: Increase the frequency and intrusiveness of supervision, especially for foreign bank subsidiaries.
• Enhance Coordination: Formalize and activate the Crisis Management MOU, and establish more structured and regular coordination between CNB, MOF, and DIF.
• Improve Crisis Preparedness: Conduct scenario analysis and annual simulations to test the crisis management framework.
• Clarify Crisis Management Thresholds: Adopt a more flexible and comprehensive criterion for determining when a bank should be resolved.
• Enhance DIF Powers: Expand the DIF’s role in bank resolution, including the ability to support purchase-and-assumption transactions and receive preferential treatment in insolvency.
• Consider Industry-Funded Resolution Fund: Reduce public costs by establishing a resolution fund funded by the banking sector.
• Update Legal Frameworks: Ensure the CNB has the legal basis to act as a resolution authority and that the DIF’s governance structure is reformed to limit conflicts of interest.

Conclusion

The Czech Republic’s financial system has shown resilience during the global financial crisis, largely due to its conservative banking structure and reliance on domestic deposits and loans. However, with increasing risks from the EU and the need for a robust crisis management framework, the authorities must enhance supervision, preparedness, and coordination mechanisms. The document emphasizes the importance of aligning the CNB’s objectives with its role in financial stability, strengthening the DIF’s capabilities, and improving legal and institutional arrangements to ensure effective crisis resolution.