2013年-IMF国际货币组织全球_Belgium_Technical_Note_on_Financial_Conglomerate_Supervision_43页_982kb

Summary of Belgium: Technical Note on Financial Conglomerate Supervision

Core Content

This document provides an analysis of the financial conglomerate (FC) supervision framework in Belgium, highlighting the challenges and risks associated with the bancassurance model and suggesting policy improvements to enhance supervision effectiveness.

Main Points

Background on Belgian Financial Conglomerates

• Belgian FCs, particularly those operating under the bancassurance model, were significant domestic and international players before the 2008 financial crisis.
• These conglomerates combined banking and insurance activities, leveraging synergies in marketing and distribution.
• They expanded rapidly, often through significant leveraging, leading to a dominant position in the domestic financial market (over 80% of assets) and notable international presence (e.g., Dexia, Fortis).
• However, the rapid growth also led to an accumulation of risks that outpaced internal risk management and supervisory capabilities.

Impact of the Financial Crisis

• The crisis hit the largest Belgian FCs hard, resulting in state intervention and substantial restructuring.
• Fortis and Dexia were split and dismantled, while KBC implemented a comprehensive divestment plan.
• After restructuring, the four major FCs (KBC, Belfius, Argenta, and AXA) control over 50% of the financial sector's assets in Belgium.

Supervisory Challenges

• The bancassurance model poses challenges in risk management and supervision due to its complexity, cross-sectoral activities, and potential for conflicts of interest.
• The existing EU framework for FC supervision has weaknesses, including regulatory arbitrage, limited supervisory tools for mixed financial holding companies (MFHCs), and incomplete prudential requirements at the group level.

Key Information

Supervisory Framework in Belgium

• The Belgian supervisory regime is based on EU directives and includes sectoral legislation (banking and insurance laws), specific FC legislation (2005 Royal Decree), and provisions for domestic systemically important financial institutions (D-SIFIs).
• The National Bank of Belgium (NBB) is the primary supervisory authority, responsible for banks, insurance companies, and FCs.
• The NBB has the authority to designate FCs using qualitative and quantitative criteria, such as the ratio of financial sector assets and the significance of activities in different sectors.

Current Supervisory Approach

• The NBB applies stricter regulations to financial holding companies (FHCs) through "waivers" for certain FCs, while MFHCs are subject to a less comprehensive supervisory framework.
• This differentiated approach has led to a fragmented operational framework and potential inconsistencies in supervisory practices.

Policy Recommendations

Supervisory Powers and Authority

• Enhance supervisory powers over MFHCs: The NBB should have the formal power to require a comprehensive capital planning process, including forward-looking stress tests.
• Expedite the implementation of the revised FICOD: This will improve the supervisory framework and align it with international standards.
• Formalize coordination between NBB and FSMA: To enhance group-wide supervision in the new regulatory structure.

Supervisory Responsibility and Coordination

• Establish a supervisory baseline: A formalized and consistent approach to prudential requirements for FCs.
• Improve internal control and risk management assessments: Through more frequent onsite reviews, better communication with management and auditors, and the use of internal capital adequacy assessment reports (ICAAP).

Governance

• Apply governance requirements consistently across FCs: To prevent conflicts of interest and ensure sound management.
• Conduct validation and back testing: To ensure the accuracy of self-reported governance information.

Risk Management

• Introduce group-wide risk concentration reporting: To better identify and manage concentration risks.
• Implement multi-sectoral stress testing: To assess the resilience of FCs under various scenarios.
• Develop a macro analytical approach: Including peer group analysis capabilities to enable horizontal comparisons across sectors.

Capital and Liquidity

• Detect multiple gearing and leveraging: To prevent capital dilution and ensure sound capitalization.
• Enhance group-level liquidity monitoring: To better manage liquidity risks across all FCs.
• Request group-wide capital planning: To ensure a more robust capital management framework.

Conclusion

The document emphasizes the need for a more comprehensive and consistent supervisory framework for financial conglomerates in Belgium, addressing the complexity and risks associated with the bancassurance model. It calls for enhanced supervisory powers, improved coordination between regulatory bodies, and a stronger focus on group-level governance, risk management, and capital adequacy. The NBB is well-positioned to lead these improvements, given its technical capacity and involvement in the Banking Union.

Table of Policy Recommendations