2011年-IMF国际货币组织全球_Guernsey_Financial_System_Stability_Assessment_48页_655kb

Summary of Guernsey: Financial System Stability Assessment—Update

Core Content

This document is an update to the Financial System Stability Assessment (FSSA) on Guernsey, conducted by the International Monetary Fund (IMF) in December 2010. It serves as background for the periodic consultation with the member country and reflects the findings of an IMF Financial Sector Assessment Program (FSAP) Update mission that took place in March 2010. The report highlights the resilience of Guernsey's financial sector during the global financial crisis, while identifying ongoing vulnerabilities and recommending improvements to ensure long-term stability.

Main Findings

• Financial Sector Resilience: Guernsey's financial sector has generally weathered the crisis well, though some banks, insurance companies, and investment firms faced difficulties, particularly due to financial distress in their parent companies.
• Key Vulnerabilities: The main risks include intra-group contagion, credit concentration, and liquidity risk. The financial sector is heavily reliant on parent group companies, with most bank assets being claims on these entities.
• Impact of Parent Bank Failures: The crisis had a significant impact on Guernsey's banks due to the financial distress of their parent banks. For example, the Guernsey subsidiary of Landsbanki (Icelandic) was placed in administration due to inability to access group funds.
• Economic Context: Guernsey is a British Crown Dependency with no independent monetary policy, relying on price and wage flexibility, labor mobility, and fiscal measures to adjust imbalances. Its economy is heavily dependent on financial services, which account for nearly 40% of GDP and a quarter of total employment in 2009.
• Tax Regime: Guernsey has a low tax regime, with a 20% corporate tax rate (excluding traditional banking and utilities), and is under review for compliance with EU standards. It has signed 15 tax information exchange agreements (TIEAs) and is working towards full automatic exchange of information.
• Regulatory Framework: The Guernsey Financial Services Commission (GFSC) has strengthened its powers and independence, and has implemented most of the recommendations from the 2003 FSAP. However, further improvements are needed, especially in enforcement, off-site analysis, and financial stability monitoring.
• Stress Test Results: Stress tests showed that the life insurance sector is relatively resilient, but banks and insurance companies face significant risks from parent company solvency and liquidity issues.
• Financial Stability Policy: The GFSC has introduced a Depositor Compensation Scheme (DCS), but its limitations must be communicated clearly to depositors. The report recommends reviewing the DCS in the medium term in light of international standards.

Key Recommendations

Priority	Recommendation
High Priority	Monitor financial position of bank parent companies using financial soundness indicators (FSIs) relating to solvency. Add and monitor data on large exposures (for borrower units).
High Priority	Add senior analyst level expertise to the GFSC staff to analyze risk across sectors using supervisory data and other information.
High Priority	Establish a forum for monitoring financial stability and coordinating policy responses.
High Priority	Complete preparations for potential deposit compensation payouts.
Medium Priority	Amend the FSC Law to provide for longer terms of office for the chairman of the GFSC.
Medium Priority	Broaden the range of enforcement powers for insurance regulation.
Medium Priority	Consider how best to implement public disclosure standards established by IAIS for insurance regulation.
Medium Priority	Collect and publish statistics on assets held by trusts and companies serviced by the Guernsey fiduciary sector. Make more comprehensive insurance sector data available.
Medium Priority	Further develop assessments of economic capital requirements (OSCA) and stress tests for insurers.
Medium Priority	Create an ombudsman service for adjudicating complaints by individual retail consumers.
Medium Priority	Extend investor compensation arrangements beyond current scope and review the DCS in light of international standards.

Financial Sector Structure

• The financial sector is diverse and includes banking, insurance, investment, and trust and company services.
• The Collective Investment Scheme (CIS) sector is the largest, accounting for 50% of total financial sector assets, followed by the banking sector (43%) and the insurance sector (7%).
• The majority of financial institutions are foreign-owned, with operations typically based in the UK or other major international groups.
• Banks primarily engage in deposit-gathering and private banking, with a large portion of their assets being claims on parent companies (about 70% of total assets).
• Insurance includes life and non-life companies, as well as captives, which are a significant part of the sector.
• Investment Business includes fund management and stock broking, but is more limited compared to other sectors.
• Trust and Company Services are extensive, supporting many thousands of trusts and companies.

Regulatory Oversight

• The GFSC has strengthened its powers and independence, including the ability to impose discretionary financial penalties.
• Banking Supervision: The GFSC has improved enforcement for banks, though more resources are needed for cross-sector analysis.
• Insurance Supervision: The sector has seen improvements with the introduction of the Own Solvency Capital Assessment (OSCA) and enhanced regulatory frameworks.
• Investment and Trust Services: These are effectively regulated, but more economic data is needed to fully assess their risks.
• AML/CFT Compliance: The GFSC is in line with international standards, and the results of the AML/CFT assessment will be detailed in a separate report.

Outlook and Policy Agenda

• Guernsey's financial system remains vulnerable to risks from parent companies, credit concentration, and liquidity issues.
• The sector is expected to continue its focus on private banking and institutional services, which has increased complexity.
• The government is committed to maintaining an internationally competitive tax regime and tax neutrality for financial products.
• Ongoing regulatory and tax reforms are necessary, especially in light of EU and international standards.
• The GFSC needs to enhance its capacity to monitor and address financial stability risks, including through better coordination with parent supervisors and improved data collection.

Conclusion

The report underscores the importance of maintaining strong regulatory oversight and enhancing financial stability measures in Guernsey. While the sector has shown resilience, future challenges require proactive policy measures and continuous monitoring to ensure sustainability and compliance with international standards.