2011年-IMF国际货币组织全球_Germany_Financial_Sector_Stability_Assessment_55页_1mb

Summary of Germany: Financial Sector Stability Assessment

Core Content

This report is a Financial Sector Stability Assessment (FSAP) Update for Germany, prepared by the IMF staff team in June 2011. It serves as background for the Article IV Consultation and outlines key findings and recommendations on the stability of Germany’s financial system post-global financial crisis.

Main Findings

• Financial System Recovery: Germany's financial system has stabilized after being significantly impacted by the global crisis, particularly due to foreign exposures and funding strains for certain banks.
• Low Profitability: Despite recovery, many German banks, especially Landesbanken, continue to suffer from low profitability, which hampers their ability to build stronger capital buffers.
• Structural Reforms Needed: Structural reforms are overdue, with Landesbanken requiring restructuring and downsizing. The need to loosen regional constraints and improve commercial orientation is general across the banking sector.
• High Regulatory Standards: The standard of financial sector regulation and supervision is high, but the crisis highlighted the need for more timely information, enhanced on-site supervision, and forward-looking supervisory actions.
• Crisis Management Framework: The framework for managing financial crises has been significantly enhanced, particularly with the introduction of a new bank resolution regime. However, deposit protection schemes need rationalization, and mechanisms for cross-border crisis management should be developed.

Main Recommendations

Key Issues Identified

Financial System Vulnerabilities

• Economic Slowdown: Prolonged slow growth in Germany and major export markets could exacerbate financial vulnerabilities, especially if accompanied by low interest rates.
• Recession Risk: A renewed recession in advanced and emerging economies, particularly those importing German goods, poses a threat.
• Sovereign Risk Concerns: Intensification or widening of concerns over sovereign risk in Europe, especially with some countries having IMF-supported programs, may lead to broader fiscal instability.
• Funding Market Strains: The reemergence of funding market strains, possibly linked to other vulnerabilities, remains a concern.
• Regulatory Uncertainty: The implementation of Basel III and other regulatory changes may increase compliance burdens and affect financial stability.

Banking Sector

• Profitability Issues: Return on equity (ROE) has been persistently low, especially for Landesbanken.
• Capitalization: German banks are adequately capitalized, but their high leverage remains a concern compared to European peers.
• Nonperforming Loans (NPLs): NPLs are comparable to those of peers, but net of provisions, they are substantially higher.
• Stress Testing Results: Solvency tests under two scenarios (a sharp double-dip recession and prolonged low growth) suggest that the banking system is vulnerable, especially under liquidity stress.
• Liquidity Risk: Larger banks and some private banks are vulnerable to liquidity risk due to their reliance on wholesale funding.

Regulatory and Supervisory System

• Supervisory Gaps: Data gaps and reliance on external auditors delay the identification of problematic cases.
• Forward-Looking Supervision: Supervisory actions should be more forward-looking, with a consistent and well-documented ladder of actions based on risk assessment.
• Macroprudential Responsibilities: The Bundesbank’s macroprudential responsibilities need to be clearly defined, including the formulation of recommendations to mitigate systemic risks.
• Cooperation and Information Sharing: German supervisory authorities should take a leadership role in enhancing cooperation and information sharing at the national and European levels.

Crisis Management and Bank Resolution

• New Restructuring Law: The new bank restructuring law strengthens the crisis management framework, but full implementation requires integration of deposit guarantee schemes and mutual protection schemes, as well as pre-defined procedures for large institutions.
• Restructuring Fund: The new restructuring fund is an important resource for bank resolution, but it will accumulate slowly.
• Deposit Guarantee Scheme (DGS): The current DGS and mutual protection schemes are fragmented and nontransparent. A harmonized and legally binding DGS of €100,000 with adequate prefunding is recommended.
• Resolution Plans: Concrete procedures and tools need to be developed for handling the potential failure of German global banks, including burden-sharing arrangements.

Conclusion

The German financial system has shown resilience and recovery since the global crisis, but structural and regulatory weaknesses persist. Addressing these issues is essential to ensure long-term stability, particularly in the face of global economic uncertainties and evolving regulatory requirements. The recommendations focus on improving governance, enhancing supervision, and strengthening crisis management frameworks.