2018年-FSB全球金融稳定委员会_RCG_for_the_Americas_Working_Group_on_Shadow_Banking_Fourth_Report_35页_1mb

Summary of the Financial Stability Board Regional Consultative Group for the Americas Working Group on Shadow Banking Fourth Report

Core Content

The Financial Stability Board (FSB) defines shadow banking (SB) as "credit intermediation involving entities and activities (fully or partly) outside the regular banking system." The report presents the findings of the Fourth Monitoring Exercise on SB in the Americas, conducted by the Working Group on Shadow Banking (WGSB) under the Regional Consultative Group for the Americas (RCGA).

The exercise aimed to:

• Assess the scope and structure of non-bank credit intermediation in the region.
• Monitor the development of these activities over time.
• Identify potential systemic risks by narrowing the focus to entities and activities that may resemble bank-like risks.
• Collect data on offshore activities in International Financial Centers (IFCs).
• Include a questionnaire on finance companies from 9 jurisdictions.

The report is based on data up to end-2016, sourced from national financial account statistics, sectoral balance sheet data, and regulatory or private sector data. It is important to note that the views expressed are those of the RCGA, not the FSB itself.

Main Objectives

• Understand the structure and growth of non-bank financial intermediation.
• Evaluate the systemic risk potential of entities outside the traditional banking system.
• Compare the narrow measure of SB with the broad measure (MUNFI) to identify risks more accurately.
• Improve data comparability and regulatory consistency across jurisdictions.

Key Findings

1. Macro-Mapping Exercise Results

• Onshore MUNFI (comprising pension funds, insurers, and OFIs) reached USD 65.3 trillion in the Americas at end-2016.
• Offshore MUNFI (including OFIs and insurance companies in IFCs) reached USD 7.4 trillion in 2016.
  • Cayman Islands had the largest offshore OFI assets at USD 6.4 trillion in 2016.
  • Insurance companies in IFCs contributed USD 0.65 trillion to offshore MUNFI.
• Narrow Measure (based on FSB’s 5 economic functions) is:
  • USD 16.7 trillion for onshore assets (26% of MUNFI).
  • USD 4.7 trillion for offshore assets (64% of offshore MUNFI).

2. Growth of Financial Entities

• OFIs (excluding broker-dealers) saw real growth of 10.3% on average across jurisdictions in 2016.
  • Uruguay had the fastest growth at 39%.
  • Panama had the second-fastest growth at 17%.
• Investment funds are the primary driver of OFI growth, particularly non-public funds and Structured Finance Vehicles (SFVs).
• Finance companies are also significant, especially in Panama and Mexico, and are the third-largest subsector in the OFI sector.
• Broker-dealers account for over 35% of OFI assets in Jamaica.

3. Pension Funds and Insurers

• The combined assets of pension funds and insurers reached USD 31.1 trillion in 2016.
  • Insurance assets grew at an average rate of 7.8%.
  • Pension fund assets grew at 4.2%.
• Real growth was observed in all WGSB jurisdictions for insurance assets.
  • Panama had the highest real growth rate in insurance assets (35%).
  • Uruguay had the highest real growth rate in pension funds (19%).
• The relative size of insurance and pension funds varies significantly across jurisdictions:
  • In Bermuda, they accounted for 59% of total financial system assets.
  • In Chile and the US, they accounted for 37% and 31%, respectively.
  • In Panama and the Cayman Islands, they accounted for 4% and 3%, respectively.
• The simple average across WGSB jurisdictions is 22%.

4. OFI Connections with the Banking System

• Interconnections between banks and OFIs vary significantly across jurisdictions.
• In Cayman Islands, Brazil, and Colombia, banks rely heavily on OFIs for funding, typically through investment funds.
• In other jurisdictions, interconnectedness is low.
• The measurements sometimes underestimate the true level of interconnections, as they do not always include off-balance sheet positions like derivatives.

5. International Financial Centers (IFCs)

• Six jurisdictions (Bahamas, Barbados, Bermuda, British Virgin Islands, Cayman Islands, Panama) are identified as IFCs.
• Offshore activities in IFCs are significant, especially in the case of large investment funds.
• Cayman Islands:
  • Offshore assets include special license banks (USD 1,019 billion), insurance companies (USD 56 billion), and OFIs (USD 6,325 billion).
• Bermuda:
  • Has a large insurance sector (USD 594 billion), specializing in catastrophe reinsurance.
• British Virgin Islands:
  • Offshore assets are primarily composed of OFIs (USD 152 billion), with a small international banking sector (USD 28 million).

6. Finance Companies Questionnaire

• Nine jurisdictions responded to the questionnaire, highlighting:
  • A diverse range of finance company types.
  • Finance companies account for 10-24% of OFI assets in Argentina, Brazil, Chile, and Mexico.
  • Lending assets make up a significant portion of finance company assets, with many jurisdictions reporting over 70% of total financial assets being lending-related.
  • Maturity transformation and leverage indicators are low to moderate, with some exceptions.
  • Regulatory restrictions on finance companies' capital, liquidity, and leverage are limited, but disclosures of SB risks (like maturity transformation and credit risk transfer) are more common.

Recommendations for Future RCGA Exercises

• Continue using the narrowing down methodology from the FSB Policy Framework (2013).
• Enhance data consistency and granularity across jurisdictions.
• Improve methodologies for identifying systemic risks from non-bank financial entities.
• Expand the coverage of IFCs and ensure more accurate classification of entities and activities.
• Encourage greater transparency and disclosure of SB-related risks by financial entities.

Conclusion

The report highlights the growing importance of non-bank financial intermediation in the Americas, particularly through OFIs, investment funds, and finance companies. While these entities provide innovation, efficiency, and competition, they also carry systemic risk potential, especially when they engage in bank-like activities. The narrow measure of SB is a more accurate reflection of systemic risk, and its application has improved comparability with FSB’s global assessments. However, data limitations and methodological challenges remain, especially in IFCs and offshore entities, which require further attention in future monitoring exercises.