2011年-IMF国际货币组织全球_Russian_Federation_Financial_System_Stability_Assessment_77页_1mb
报告摘要
Summary of the Russian Federation: Financial System Stability Assessment (August 18, 2011)
Core Content
This report provides a comprehensive assessment of the financial system stability in the Russian Federation as part of the Financial Sector Assessment Program (FSAP). It evaluates the response to the recent financial crisis, current risk assessments, and the strengths and vulnerabilities of the financial system, focusing on institutions, markets, and the policy framework.
Main Findings
Financial Stability During the Crisis
- The Russian authorities successfully maintained financial stability despite a major global shock and a sharp contraction in domestic output.
- Financial soundness indicators began to recover in 2010, and crisis-related support measures were discontinued.
- Stress tests indicate that banks are resilient to a variety of sizeable shocks, although reported data may overestimate loan quality and the level of provisions for non-performing loans is still low.
Challenges and Risks
- The crisis has slowed progress toward a more competitive banking system, with increased concentration and moral hazard.
- The financial system remains fragile due to:
- Modest economic growth projections.
- Exposure to international commodity price fluctuations and capital flows.
- Weak governance, including non-transparent ownership structures and deficiencies in financial reporting.
- The failure of Mezhprombank and the Bank of Moscow highlights systemic governance and supervisory weaknesses.
Regulatory and Supervisory Framework
- The regulatory and supervisory framework for banking has gaps and weaknesses.
- The Central Bank of Russia (CBR) lacks authority to supervise bank holding companies and related parties, and has limited powers in information sharing and risk management guidance.
- Pending legislation at the State Duma could address these shortcomings, but until then, Russia scores poorly in compliance with international standards.
- The supervision of non-bank financial institutions was recently unified under the Federal Service for Financial Markets (FSFM), which is seen as a positive development, but requires adequate powers, resources, and independence.
Macroprudential and Crisis Management
- The CBR has made progress in monetary policy transparency but needs to improve the effectiveness of monetary operations.
- A macroprudential policy oversight framework is being developed, with the establishment of an inter-agency working group and a special department at the CBR.
- The deposit insurance framework is well-structured and effective, but the bank resolution framework needs to be unified with broad powers for the administrator.
- "Open bank assistance" tools should be reserved for systemic situations only and require government approval.
Key Recommendations
Short-Term Recommendations (within 12 months)
- Empower the CBR to use professional judgment in interpreting laws and regulations, issuing enforceable risk management guidance, and applying it to individual banks.
- Approve pending amendments to expand CBR supervisory authority over bank holding companies and related parties, and eliminate restrictions on information-sharing with other domestic and foreign supervisors.
- Allow the CBR to sanction individual directors and key managers, raise capital requirements on individual institutions, and impose restrictions on transactions between affiliates.
- Ensure the FSFM has the power to issue secondary regulations and set industry-wide binding norms.
- Empower the FSFM to require insurers to have internal controls and risk management systems appropriate to their business complexity.
- Apply fit and proper requirements to directors and key management of insurers on an ongoing basis.
- Make home-host notifications and cross-border cooperation in insurance mandatory for the FSFM.
- Adopt pending legislation to empower the FSFM to appoint a provisional administrator, freeze assets, and wind down distressed securities firms.
Medium-Term Recommendations (1–3 years)
- Pursue efforts to ensure an effective macroprudential policy oversight.
- Require government guarantees for all CBR loans that are unsecured or not backed by marketable collateral or guarantees.
- Require repo transactions to take place using central counterparty clearing.
- Set limits on the concentration of collateral in the repo market.
- Adopt a prompt remedial action framework for banks.
- Introduce a unified administration regime for all banks with broad powers for the administrator, including purchase and assumption (P&A).
- Restrict open-bank assistance to systemic situations only, requiring government approval before deployment.
Conclusion
While the Russian financial system has shown resilience during the crisis and is on a recovery path, significant challenges remain. These include governance weaknesses, regulatory gaps, and the need for improved macroprudential oversight. Strengthening the supervisory framework, enhancing transparency, and ensuring a unified and effective resolution regime are crucial for long-term financial stability.
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