2015年-FSB全球金融稳定委员会_Second_Report_on_Shadow_Banking_in_the_Americas_45页_1mb

Financial Stability Board Regional Consultative Group for the Americas - Working Group on Shadow Banking Second Report Summary

Core Content

This report is the second shadow banking monitoring exercise conducted by the Financial Stability Board (FSB) Regional Consultative Group for the Americas (RCGA). It aims to enhance understanding of shadow banking activities within the region, particularly in jurisdictions not part of the FSB's global monitoring exercise. The report outlines the methodology, findings, and recommendations for monitoring shadow banking, with a focus on the structure of financial systems, the role of other financial intermediaries (OFIs), their connections with the banking system, and the impact of international financial centers (IFCs).

Main Objectives

• To monitor shadow banking activities in the Americas, especially in jurisdictions not part of the FSB's global shadow banking monitoring.
• To identify key characteristics of shadow banking in the region.
• To assess risks arising from the connections between shadow banking and the traditional banking sector.
• To provide recommendations for improving the oversight of shadow banking.

Key Findings

1. Structure of Financial Systems

• Banks dominate financial activities in the Americas, holding more than 40% of financial assets on average.
• The share of banks in financial assets has been declining since 2008 due to the growth of OFIs.
• In some jurisdictions, non-bank deposit-taking institutions (non-bank DTIs) are also significant, though they generally represent a smaller share of financial assets.
• The public sector plays a notable role in several jurisdictions, particularly in Brazil, Costa Rica, Panama, and Uruguay, where it holds a high share of commercial bank ownership.
• The OFI sector is more developed in jurisdictions with more mature financial systems, such as the Cayman Islands and the United States.

2. Other Financial Intermediaries (OFIs)

• The size of the OFI sector relative to GDP is heterogeneous across the WGSB jurisdictions.
• The OFI sector in the Americas is smaller than in FSB member jurisdictions, with the simple average of total financial assets to GDP being 210% compared to a higher ratio in the AGV countries.
• Investment funds, particularly money market funds and other investment funds, are the largest subsector of OFIs in the region.
• The OFI sector has shown positive growth in several jurisdictions since the global financial crisis, especially in Argentina, Colombia, and Costa Rica, driven by the expansion of investment funds.
• Structured finance vehicles and broker-dealers have experienced contraction in some jurisdictions, notably Uruguay and Panama, due to economic conditions or regulatory changes.

3. OFI Connections with the Banking System

• In several jurisdictions, OFIs are significant sources of funding for banks, often through investment funds.
• In Panama, OFIs account for more than 20% of bank assets in terms of credit risk exposure.
• In other jurisdictions, such as Brazil and Chile, banks rely on OFIs for funding.
• The inter-connections between banks and OFIs are generally low, but the data is limited and does not include off-balance sheet positions like derivatives.

4. International Financial Centers (IFCs)

• Several jurisdictions in the Americas, such as the Cayman Islands, Bermuda, and Panama, are significant IFCs that provide offshore financial services.
• These IFCs represent a material data gap in the FSB's global shadow banking monitoring, as they facilitate large volumes of credit intermediation.
• The offshore assets in these IFCs are substantial, with the Cayman Islands having USD 2095 billion in private funds and Panama having USD 1364 billion in special license banks.
• IFCs are prudentially regulated, though the intensity of regulation varies, with Panama having less stringent requirements than onshore banks.

Key Recommendations

• Continue monitoring shadow banking in the region, with a focus on non-bank DTIs, broker-dealers, and finance companies.
• Address regulatory gaps between banks and non-bank DTIs to prevent regulatory arbitrage.
• Improve data collection and transparency to better assess the risks associated with shadow banking activities.
• Develop a more comprehensive understanding of the role of IFCs in global non-bank credit intermediation.
• Expand the scope of the monitoring exercise to include more granular data on off-balance sheet positions.

Methodology

• The WGSB used a modified version of the FSB's AGV template to capture the specific characteristics of the Americas.
• The template was adapted to include:
  • A distinction between money market funds, public funds, and private funds.
  • Information on the public sector's role in financial markets.
  • Specific data on non-bank credit card companies.
• A separate offshore template was developed to capture activities in IFCs.
• Two questionnaires were conducted on non-bank DTIs and broker-dealers to gather more detailed information on their regulatory and supervisory frameworks.

Conclusion

The report highlights the growing role of non-bank financial intermediaries in the Americas and the need for enhanced oversight and regulation to mitigate systemic risks. It also underscores the importance of international financial centers in facilitating offshore credit intermediation and the necessity for continued monitoring and data collection to understand and manage these risks effectively.