2015年-IMF国际货币组织全球_Bosnia_and_Herzegovina_Financial_System_Stability_Assessment_76页_1mb

Financial System Stability Assessment of Bosnia and Herzegovina (2015)

Core Content

The Financial System Stability Assessment (FSSA) for Bosnia and Herzegovina (BiH), conducted by the IMF in 2015, highlights the ongoing challenges and improvements in the country's financial system. The assessment was based on a Financial Sector Assessment Program (FSAP) mission that visited BiH from October 29 to November 18, 2014.

Main Findings

Financial System Overview

• The financial system is dominated by the banking sector, which holds about 87% of financial system assets and 84% of GDP.
• Most banks are foreign subsidiaries, accounting for over 80% of the banking sector's assets.
• The insurance sector is small but becoming more competitive.
• Interconnectedness among banks is limited, but linkages with the insurance sector are significant.
• The Development Bank of Republika Srpska plays a major role in supporting the banking system.

Systemic Vulnerabilities

• The system-wide non-performing loan (NPL) ratio is high at 14% as of end-2014, with two-thirds of NPLs already provisioned.
• NPLs are a result of the global financial crisis, low growth, and lax lending policies.
• Bank governance issues, related-party loans, and weak corporate resolution and insolvency frameworks hinder asset quality improvement and profitability restoration.
• Some domestically-owned banks struggle with capital requirements, while others rely on public support without clear exit plans.
• Stress tests indicate high loan concentration risks and low liquidity ratios for these banks.
• Insurance companies have thin solvency margins.

Financial Sector Resilience

• Aggregate solvency and liquidity indicators appear broadly sound, but dispersion among banks is wide.
• The legal framework for creditor/debtor relationships is comprehensive, but debt resolution and bankruptcy liquidation processes are ineffective.
• The payment system meets many international standards, but liquidity and legal risks persist due to high concentration of transaction values in a few banks.
• The current insurance prudential framework (Solvency I) is not risk-sensitive and requires updating.

Key Recommendations

Banking Oversight

• Develop a remedial action program with new tools, earlier enforcement, and heavier fines to expedite corrective actions.
• Strengthen provisioning under IAS by issuing standards to encourage conservative impairment assumptions.
• Enact new Laws on Banks and amend relevant legislation to address supervisory powers, consolidated supervision, and identification of ultimate beneficial owners.
• Conduct additional asset quality reviews (AQRs) in banks with weak solvency and liquidity indicators.
• Ensure banks continue implementing IFRS and external auditors implement IAS.

Insurance Oversight

• The appointment of the FBiH-ISA director should be based on relevant law.
• The new insurance law in the FBiH should be approved if it aligns with EU insurance directives.
• Introduce a formal channel of information sharing with banking agencies.
• Update the solvency regime to incorporate risk elements, develop an early warning system, and improve capacity building.

Financial Safety Net

• Revise reserve requirements, maturity mismatch, and liquidity ratios.
• Design and implement a Liquidity Coverage Ratio (LCR) adapted to BiH.
• Revise consequences for non-compliance with reserve requirements.
• Enable prompt depositor pay-outs and provide resolution powers to FBA and BARS under new banking laws.
• Broaden the scope of the Deposit Insurance Fund (DIF) to fund bank resolution using least-cost solutions.
• Establish a Financial Stability Fund (FSF) to support open bank resolution and provide limited emergency liquidity in systemic crises.
• Strengthen and regularly test contingency plans of SCFS members.
• Enhance cooperation between DIA and financial safety net players.
• Expand macroprudential analysis and policy in the coordination Memorandum of Understanding (MoU).

Financial Market Infrastructure

• Strengthen the legal framework to designate payment systems and protect settlement finality and netting in line with international standards.
• Develop a comprehensive risk management framework for the Real-Time Gross Settlement (RTGS) system.
• Stress test the RTGS system, including the default of the largest participant and affiliates.
• Establish a recovery time objective for the RTGS system following disruptive events.
• Create a new oversight unit in the Payment Systems Department with sufficient resources.

Additional Areas

• Streamline collateral execution procedures by allowing a final auction at no reserve price if previous rounds failed.
• Consider tools and incentives to facilitate restructurings and debt resolution, and adopt out-of-court restructuring guidelines.
• Revise the insolvency framework to encourage early proceedings and expand coverage to include businesses run by individuals.

Institutional and Regulatory Challenges

• Regulatory and supervisory responsibilities are fragmented across entities.
• Supervisors have limited corrective and enforcement powers.
• Identification of ultimate beneficial owners and related-party lending is problematic.
• There is a need to strengthen the supervisory board selection process and internal audit functions of state banks.
• Consumer protection and financial literacy in the insurance industry are weak and require improvement.

Progress and Future Steps

• Banking and insurance oversight have improved since the 2006 FSAP.
• Anti-Money Laundering/Combating Terrorism Financing (AML/CFT) framework has seen progress, but further implementation is needed.
• The establishment of the Standing Committee on Financial Stability (SCFS) has improved coordination among oversight institutions.
• The legal system under the currency board arrangement rules out a standing liquidity facility and emergency liquidity assistance.
• The secondary market for government securities is small and illiquid.
• Capital markets are small, and financial sector development in microfinance and leasing is constrained.

Conclusion

• A stronger and more resilient financial sector is essential for maintaining macroeconomic stability and revitalizing economic growth.
• Decisive and timely actions to address weak banks are critical.
• The creation of a credible and transparent financial safety net, including a Financial Stability Fund (FSF) and enhanced contingency planning, is necessary.
• Strengthening governance, risk management, and regulatory frameworks will be key to addressing systemic vulnerabilities and improving financial sector performance.