2019年-IMF国际货币组织全球_Finland_Selected_Issues_13页_536kb

Finland: Implications of Nordea's Redomicile

Core Content Overview

This document, prepared by the International Monetary Fund (IMF) in December 2018, analyzes the implications of Nordea's relocation of its headquarters from Sweden to Finland in October 2018. The report outlines Nordea's operations, the impact of the move on the Finnish financial sector, and the policy responses from Finnish and European authorities.

Main Points

A. Introduction

• Redomicile: Nordea moved its headquarters to Finland in October 2018, aiming to be part of the banking union.
• Impact on Supervision: The move increases the size and complexity of the Finnish banking sector, requiring enhanced supervision and crisis preparedness.
• Euro Area Oversight: Nordea is now under the supervision of euro area institutions, including the Single Supervisory Mechanism (SSM) and the Single Resolution Board (SRB).

B. Nordea's Operations

• Structure: Formed in 2000 by merging Danish, Finnish, Norwegian, and Swedish banks.
• Services Offered: Personal, commercial, and wholesale banking, asset and wealth management, and economic research.
• Ownership: Sampo, a Finnish financial holding company, holds 21% of Nordea's shares.
• Market Presence: Nordea holds significant market shares in all four Nordic countries, with nearly all of its loans directed to these countries.
• Loan Portfolio: Dominated by household mortgage loans (40.9%) and corporate loans (45.4%).
• Capital and Liquidity: Well-capitalized with a Tier 1 capital ratio of 19.3% and a total capital ratio of 24.6% in 2017. Liquidity ratios are above regulatory minima, with an average LCR of 147%.
• Ratings: Maintains high credit ratings (Aa3 from Moody’s, AA- from S&P and Fitch).
• Resolvability: Improved resolvability with a resolution requirement of 7.1% of own funds and total liabilities.

C. Implications of Nordea's Redomicile

Supervision and Capital Requirements

• Supervision: Nordea is now directly supervised by the ECB through the SSM, with the Finnish Financial Supervisory Authority (FIN-FSA) actively involved.
• Joint Supervisory Team (JST): Composed mainly of ECB and FIN-FSA staff.
• Pillar 2 Requirements: Will be reviewed in 2019 by the ECB.

Liquidity

• Liquidity Requirements: Based on harmonized EU regulations, with the Net Stable Funding Ratio (NSFR) at 103.5% in 2017.
• Liquidity Access: Nordea can access Eurosystem monetary policy operations as long as it meets counterparty and collateral requirements.
• Emergency Liquidity Assistance (ELA): Managed by the Bank of Finland (BoF), with ECB oversight.

Resolution

• Single Resolution Board (SRB): Nordea is under SRB's direct remit.
• Resolution Planning: Conducted through Internal Resolution Teams (IRT) involving the SRB and FFSA.
• Resolution College: Includes host supervisors from Nordic countries and the SRB as chair.
• Single Resolution Fund (SRF): Nordea contributes to the SRF, which is not yet at full capacity.

Deposit Insurance

• Finnish Deposit Guarantee Scheme: Covers Nordea's depositors up to €100,000.
• Covered Deposits: Increased from €51 billion to €127 billion due to the redomicile.
• Deposit Guarantee Fund: Administered by the FFSA, funded by risk-based fees.

D. Policy Responses

• Supervision: FIN-FSA increased its staff by 30 in 2018 to handle supervision of Nordea.
• Capital Buffers:
  • Systemic Risk Buffer: Set at 3% by the FIN-FSA.
  • G-SII Buffer: Set at 1%, effective January 2020.
  • O-SII Buffer: Set at 2%, effective January 2019.
• Resolution Framework: The SRB has set MREL requirements for Nordea, and the bank is issuing senior non-preferred debt to meet these.
• International Cooperation: The move tests the coordination between euro area and non-euro area financial authorities.

E. Assessment

• Supervisory Capacity: The ECB and FIN-FSA have responded to the challenges, enhancing supervision and cooperation.
• Capital and Liquidity: Nominal capital requirements remain largely unchanged, but the composition may vary due to the SSM's approach.
• Resolution Framework: The resolution framework aims to prevent taxpayer bailouts, though it is still evolving. The SRF has sufficient resources to support a resolution, though access to the backstop is not yet fully finalized.
• Common Deposit Insurance: Not yet implemented, but is a key component of the banking union and important for retail depositor confidence.

Key Information

• Nordea's Size: Nordea's assets in Finland increased from €239 billion to €427 billion post-redomicile.
• Economic Impact: Limited direct macroeconomic impact, as most operations are outside the banking union.
• Legal Changes: Nordea's legal structure was reorganized in 2017, with most non-Swedish activities operating through branches.
• Branchification: Operations in Estonia, Latvia, and Lithuania were merged with DNB Bank to form Luminor Bank, with Nordea retaining 56% of shares and 50% of voting rights.
• Macroprudential Tools: Finland retains authority over macroprudential decisions, including the setting of capital buffers.

Conclusion

Nordea's redomicile to Finland has increased the size and interconnectedness of the Finnish financial sector, placing new demands on supervision and crisis preparedness. While the move does not inherently increase risk, it highlights the importance of the banking union's resolution and capital frameworks. The Finnish authorities have taken steps to ensure the stability of the sector and maintain cooperation with European institutions.