2014年-FSB全球金融稳定委员会_Peer_Review_of_Germany_45页_314kb

Summary of Peer Review of Germany

Core Content

The Peer Review of Germany was conducted by the Financial Stability Board (FSB) in 2014, following the Financial Sector Assessment Program (FSAP) of 2011. The review focuses on two critical areas: macroprudential policy framework and microprudential supervision. These topics were central to the FSAP recommendations and are of particular relevance to the broader FSB membership.

The report is based on the responses of German financial authorities to a questionnaire, discussions within the Standing Committee on Standards Implementation (SCSI), and insights from EU-level initiatives. It highlights the progress made and outlines key recommendations to further strengthen Germany’s financial stability framework.

Main Findings

• Good progress has been made in addressing FSAP recommendations in both macroprudential and microprudential areas.
• Several reforms are still ongoing, requiring continued attention.
• EU initiatives have played a significant role in shaping reforms, especially in the context of macroprudential policy and microprudential supervision.
• The Financial Stability Committee (FSC) has been established but its effectiveness is yet to be fully evaluated due to its recent formation.
• Communication and decision-making within the FSC need further clarification to ensure transparency and accountability.
• Stress testing and on-site inspections have been improved, but liquidity risk and insurance sector oversight remain areas for enhancement.

Macroprudential Policy Framework

Key Developments

• The Financial Stability Act (FSA) introduced institutional and organisational reforms, establishing the FSC and clarifying the Bundesbank’s role in supporting it.
• The FSC includes representatives from the Federal Ministry of Finance (BMF), Bundesbank, BaFin, and FMSA (non-voting).
• The FSC aims to identify systemic risks and formulate recommendations, but it does not have direct regulatory powers.

Recommendations

1. Clarify the FSC’s role in financial stability, especially regarding the development and implementation of prudential regulations and crisis management.
2. Develop an analytical framework for triggering warnings and recommendations, as well as for assessing the impact of policy actions.
3. Establish a macroprudential toolkit ex ante to ensure timely application of tools when needed.
4. Enhance communication strategy to avoid duplication with member institutions and ensure clarity on target audiences.

Microprudential Supervision

Key Developments

• Stress testing and regulatory reporting have been improved for banks and insurance companies.
• The Single Supervisory Mechanism (SSM), introduced in 2014, will transfer primary supervision of large banks in the Eurozone to the European Central Bank (ECB), with BaFin and Bundesbank retaining a role.
• Credit risk oversight is currently reliant on external auditors, which raises concerns about the depth and consistency of supervision.
• Insurance sector on-site inspections have been limited due to Solvency II preparations, with more focus on internal models.

Recommendations

1. Strengthen supervisory practices to ensure the early and comprehensive identification of risks within institutions.
2. Enhance business model and risk culture analysis through on-site inspections and off-site analysis.
3. Improve awareness of major acquisitions and their impact on banks' risk profiles.
4. Increase credit risk expertise to better supervise non-IRB aspects of credit risk.
5. Incorporate liquidity risk scenarios into stress testing frameworks.
6. Expand on-site inspections for insurance companies, focusing on a broader range of risk areas.
7. Introduce a formal "ladder of actions" for both banking and insurance supervision, incorporating forward-looking elements and objective triggers.

Key Information

• The FSAP 2011 highlighted the need for structural reforms, especially for Landesbanken, and noted the importance of deposit protection schemes and exit strategies from government support.
• The FSC is still in its early stages and requires further clarification and operationalisation.
• The SSM will significantly change the roles and responsibilities of BaFin and Bundesbank in banking supervision.
• The FSB recommends that Germany develop a comprehensive macroprudential strategy and improve communication and coordination within the FSC.

Annexes

• Annex 1 provides background on the structure of the German financial system and recent regulatory developments.
• Annex 2 outlines follow-up actions on other key FSAP recommendations, though these were not analyzed in the peer review.

Conclusion

Germany has made positive strides in implementing reforms to enhance financial stability, particularly through the establishment of the FSC and the integration of EU-level initiatives. However, the report highlights the need for greater clarity in decision-making processes, improved communication, and enhanced supervisory tools to ensure the effectiveness and consistency of financial sector oversight. The recommendations aim to support the ongoing development of Germany’s financial stability framework and align it more closely with international standards.