2016年-FCA英国金融行为监管局_occasional_paper_18_62页_1mb

报告摘要

Summary of "Market-Based Finance: Its Contributions and Emerging Issues"

Core Content

This paper explores the concept of Market-Based Finance (MBF), its evolution, contributions to consumer welfare, and the risks it poses to financial stability. It aims to provide a framework for understanding MBF and its implications for securities and conduct regulators like the FCA.

Main Objectives

To better understand the factors that have transformed traditional banking into a more global and market-based system.
To develop an analytical framework to assess MBF's contributions to consumer welfare and identify its potential risks.
To gather insights on recent developments in MBF and their significance for financial regulators.

Key Findings

Benefits of MBF

Reduces the cost of capital and improves resource allocation.
Provides an alternative credit source to companies and households, especially when traditional banks are unwilling or unable to lend.
Enhances economic resilience by diversifying the financial institutions involved in funding the real economy.
Improves efficiency through competition with traditional banks, leading to better services and lower costs for consumers and businesses.
Expands access to larger markets for successful niche products by leveraging a diverse pool of investors.

Risks and Challenges

Complexity and lack of understanding of MBF make it prone to instability, especially in areas where regulators have limited data.
Unsolved market failures exist for certain products, which could lead to systemic instability.
Regulatory arbitrage is not the main driver of MBF growth, though it played a role in the financial crisis.
Emerging risks from MBF activities require more sophisticated regulatory tools that are tailored to the unique market-based nature of the system.

Evolution of MBF

Drivers of MBF Growth

Advances in financial engineering – particularly securitisation and risk management.
Globalisation of funding and capital markets – enabling a more diversified and interconnected financial system.

Characteristics of MBF

MBF is not just an alternative to traditional banking but represents a more efficient and modern way of creating, distributing, and managing money, credit, and risk globally.
It operates through dealer intermediation, where cash portfolio managers and risk portfolio managers are linked via market mechanisms rather than direct banking relationships.
The system relies heavily on well-functioning global markets for both funding and asset pricing, distinguishing it from the traditional bank-based model.

Nascent MBF

These are smaller, less integrated non-bank entities and activities that may eventually evolve into MBF.
Examples include buy-to-let and corporate lending.
They are not yet part of the MBF ecosystem, but have the potential to become so if they grow in size and interconnectedness.
Risks from nascent MBF are localized and less likely to spill over into the broader financial system, but monitoring is still necessary due to their evolutionary potential.

Regulatory Implications

The FCA and other securities regulators should focus on the market-based risks inherent in MBF, such as liquidity and integrity risks, rather than treating it like traditional banking.
A comprehensive regulatory approach is needed to ensure the stability and efficiency of the system.
Regulatory tools should be updated to reflect the new structure and functions of MBF, rather than relying on outdated, bank-centric models.
The evolution of MBF is a natural process driven by financial innovation and global market integration, not solely by regulatory arbitrage.

Conclusion

MBF is a fundamental shift in how financial services are provided, emphasizing market mechanisms over traditional banking.
It has benefits for consumer welfare and economic efficiency, but also presents unique risks that require specialized regulatory attention.
The FCA should develop a market-based regulatory perspective to better understand and manage the risks and opportunities associated with MBF.

Glossary

ABCP: Asset-Backed Commercial Paper
ABS: Asset-Backed Security
AIMA: Alternative Investment Management Association
AUM: Assets under Management
BDC: Business Development Company
BTL: Buy To Let
CCP: Central Counterparties
CDO: Collateralised Debt Obligation
CDS: Credit Default Swap
CGFS: Committee on the Global Financial System
CLO: Collateralised Loan Obligation
ESRB: European Systemic Risk Board
FCA: Financial Conduct Authority
FSB: Financial Stability Board
HQLA: High-Quality Liquid Assets
IMF: International Monetary Fund
IOSCO: International Organization of Securities Commissions
IRS: Interest Rate Swap
LTCM: Long-Term Capital Management
MBF: Market-Based Finance
OTC: Over-the-Counter
P2P: Peer-to-Peer
REIT: Real Investment Trust
RMBS: Residential Mortgage-Backed Security
SIV: Structured Investment Vehicle
SPV: Special Purpose Vehicle
ZIRP: Zero Interest Rate Policy

Equality and Diversity Considerations

The proposals in this paper do not adversely impact any group with protected characteristics, such as age, disability, sex, race, or sexual orientation.

Annexes

Annex 1: A qualitative model of MBF, illustrating its key operational mechanics.
Annex 2: Summary of issues in MBF and nascent MBF.
Annex 3: References to supporting literature.
Annex 4: Bibliography of cited works.

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