2016年-IMF国际货币组织全球_Kingdom_of_Bahrain_Financial_Sector_Assessment_Program_Detailed_Assessment_of_Observance_Assessment_of_Observance_of_the_CPMI_108页_1006kb

Summary of the Detailed Assessment of Observance of the CPMI-IOSCO Principles for Financial Market Infrastructures in the Kingdom of Bahrain

Core Content

This report presents the findings of the IMF's Report on the Observance of Standards and Codes (ROSC) mission to Bahrain, conducted in December 2015. It evaluates the observance of the CPMI-IOSCO Principles for Financial Market Infrastructures (PFMIs) by the Central Bank of Bahrain (CBB) and its payment and securities settlement systems: the Real-Time Gross Settlement (RTGS) system and the Scripless Securities Settlement (SSS) system. The assessment is based on the CBB's self-evaluations, relevant laws, and discussions with officials and industry representatives.

Key Financial Market Infrastructures in Bahrain

Payment Systems

• Real-Time Gross Settlement (RTGS) System:

  • Settlement of high-value interbank and customer payments in real time.
  • Operates from 8:00 a.m. to 2:07 p.m. on business days.
  • Integrated with the SSS system.
  • 28 direct members (licensed retail banks) and 17 indirect members (e.g., pension funds, insurance companies).
  • Total transaction value in 2014 was BD 63 billion (around 5 times GDP).
  • Average daily value in August 2015 was BD 289 million.
  • Participants have access to intraday credit (IDC), fully collateralized with government securities and BD deposits.
  • Encourages early payment submission through an ascending fee schedule.
  • Has a disaster recovery relocation (DRR) site and near relocation area (NRA) to ensure business continuity.

• Bahrain Cheque Truncation System (BCTS):

  • Operated by the BENEFIT Company (TBC).
  • Clears checks based on images.
  • Customers receive check proceeds by 3:00 p.m. on the same day if deposited before 11:30 a.m.

• Bahrain Electronic Network for Financial Transactions (BENEFIT):

  • Operated by TBC, mainly for debit card transactions.
  • Supports cash withdrawals and POS transactions within GCC countries.
  • Includes direct debits and online e-commerce transactions via Payment Gateway (PG).

• Near Real-Time Electronic Fund Transfer System (EFTS):

  • Launched on November 5, 2015.
  • Enables near real-time fund transfers within 30 seconds (Fawri+).
  • Offers deferred batch payments (Fawri) and electronic bill presentment and payment (Fawateer).

Securities Settlement Systems

• Scripless Securities Settlement (SSS) System:

  • Operated by the CBB, serving as a central securities depository (CSD) for government securities.
  • Settlement of primary and secondary market transactions on DVP1 basis.
  • Total transaction value in 2014 was BD 7.3 billion (around 58% of GDP).
  • As of August 2015, scripless securities amounted to BD 4.2 billion.
  • Provides short-term liquidity to direct members via collateralized repos.
  • Has a business continuity plan (BCP) and no transaction fees, only annual membership fees.

• Central Securities Depository of Bahrain Bourse (CSD-BHB):

  • Acts as a centralized depository for dematerialized securities.
  • Clearing and settlement of securities transactions on DVP2 basis.
  • Operates the Automated Trading System (ATS).
  • Provides government securities to retail investors through BHB.

Main Findings

Observance of Principles

• RTGS System:
  • Observes 6 principles.
  • Broadly observes 10 principles.
  • Partly observes 2 principles.
• SSS System:
  • Observes 8 principles.
  • Broadly observes 10 principles.
  • Partly observes 2 principles.
  • One principle is non-applicable.

Areas for Improvement

• Legal Basis:
  • Legal certainty for settlement finality and netting arrangements is needed in primary legislation.
  • Consideration of an explicit law on settlement finality and elimination of 'zero-hour rules' in insolvency law.
• Governance:
  • Governance is clear but requires more Board involvement in risk management.
  • The Payments Committee (PC) should include legal, capital markets, financial stability, and retail banking representatives.
• Risk Management:
  • A comprehensive risk management framework is needed to address legal, credit, liquidity, and operational risks.
  • Stress testing for the largest participants and affiliates, monitoring throughput rates, and analyzing liquidity usage.
• Credit Risk:
  • Collateral is of high quality, but no haircut is applied.
  • Haircuts should be introduced for intraday credit and overnight repos between the CBB and RTGS members.
• Operational Risk:
  • The BCP should ensure critical systems resume operations within two hours of disruption and complete settlement by the end of the day.
  • System availability should be monitored and publicly disclosed against a 99% target.
  • Secondary site should have a distinct risk profile, and testing frequency should be increased.
  • Scalable capacity and oversight of critical service providers need to be addressed.
• Access and Tiered Participation:
  • Concentration risks in the payment system require management through indirect participants.
  • Membership to indirect participants should be considered, subject to risk management criteria.

Recommendations

1. Establish and publicly disclose clear criteria for identifying FMIs.
2. Enhance the legal basis and powers of the CBB for oversight.
3. Develop a policy document outlining CBB's regulatory, supervisory, and oversight policies for all FMIs.
4. Formally adopt the PFMI principles and ensure consistent application across all FMIs.
5. Expand cooperation with overseas authorities to promote safety and efficiency in FMIs.
6. Strengthen the legal underpinnings for payments and securities settlement systems to protect finality and netting arrangements.
7. Review and update the risk management framework to include all types of risks.
8. Implement stress testing for major participants and improve BCPs.
9. Increase testing frequency and ensure scalable capacity.
10. Develop oversight expectations for critical service providers.

Authorities' Responsibilities

• The CBB is responsible for overseeing and supervising FMIs.
• Oversight is conducted through two directorates: Banking Services Directorate (BSD) and Payments Committee (PC).
• The CBB has adopted PFMI standards and is working to improve current oversight arrangements.
• The CBB Law of 2006 grants it regulatory powers over payment and securities settlement systems.
• The CBB has been actively engaged in the development and improvement of FMIs since 2005.

Conclusion

The assessment highlights that while the RTGS and SSS systems in Bahrain are generally aligned with international standards, there are opportunities for improvement in legal certainty, governance, risk management, and oversight. The recommendations aim to strengthen the resilience and efficiency of financial market infrastructures in the country.