2014年-世界发展银行全球_Moldova_Financial_Sector_Assessment_Program___Core_Principles_for_Effective_Deposit_Insurance_Systems_65页_1mb

Financial Sector Assessment Program (FSAP) - Moldova Deposit Insurance System

Core Principles Overview

The FSAP assessment evaluated the Deposit Guarantee Fund (DGF) in Moldova against the BCBS-IADI Core Principles for Effective Deposit Insurance Systems. The DGF was found to be:

• Compliant (C) with 4 principles
• Largely Compliant (LC) with 8 principles
• Materially Non-Compliant (MNC) with 4 principles
• Non-Compliant (NC) with 1 principle
• Not Applicable (NA) with 1 principle

The DGF has made progress in protecting depositors and maintaining financial stability, but several areas require improvement.

Key Findings

A. Macroeconomic Environment and Banking System

• Moldova's economy is recovering from the 2012 recession, with GDP growth resuming in 2013.
• The banking system is small and concentrated, with the top 5 banks holding about 70% of the sector's assets.
• Lending constitutes 40% of GDP, and deposits have grown faster than credit, reaching about 46% of GDP.
• Banks remain liquid and profitable, but non-performing loans (NPLs) are still high, at 12.4%, with slow resolution due to collateral issues and reluctance to accept losses.
• The state-owned BEM is facing chronic asset quality and undercapitalization problems.

B. Governance of Financial Safety Net and Prudential Regulation

• The National Bank of Moldova (NBM) and National Commission for Financial Markets (NCFM) are responsible for prudential supervision and financial stability.
• The DGF has a sound governance framework and is governed by a 5-member Administrative Council.
• However, the NBM lacks sufficient operational independence, and its intervention and enforcement powers are weak, leading to "raider" attacks on banks.
• Supervisory forbearance and opaque shareholding structures are concerns that may exacerbate bank fragility.

C. Legal Framework

• The DGF operates under the Law on Guaranteeing Individual Deposits.
• The legal framework is being updated to align with international standards, but there are concerns regarding the Constitutional Court ruling that allows courts to suspend NBM decisions, except for those related to bank liquidation.
• There is no formal process to review the DGF's performance in meeting its policy objectives.
• The DGF lacks clear legal authority to establish MOUs with deposit insurers in other countries.

D. Accounting and Disclosure Regime

• Accounting and disclosure laws have been updated, with banks now using IFRS for financial reporting.
• The financial statements are generally of good quality, reflecting intensive NBM supervision.
• However, implementation and enforcement are hampered by limited capacity and resources.
• Public oversight and awareness of financial transparency remain inadequate, especially for non-bank institutions.

Key Recommendations

• Clarify and formalize public policy objectives of the DGF in the DGF Law and introduce a regular review process.
• Enhance the DGF's operational capacity by increasing the operating budget and establishing a strategic planning process.
• Improve information sharing by amending the Law on Financial Institutions to allow the DGF to access detailed depositor information earlier and more effectively.
• Amend the DGF Law to include the ability to make advance, interim, or partial payments to depositors.
• Raise the coverage limit to better protect depositors and support financial stability. A thorough analysis is recommended before any increase, considering the impact on coverage, funding requirements, and premium rates.
• Establish a line-of-credit from the Ministry of Finance (MOF) for the DGF and amend laws to allow the NBM to act as an emergency liquidity back-up for the DGF.
• Improve public awareness through regular evaluation of the effectiveness of awareness campaigns.
• Ensure legal protection for the DGF and its staff, including comprehensive codes of conduct and ethics.
• Strengthen the early warning and resolution system by addressing deficiencies in the supervisory framework, including operational independence, transparency, and legal authority for establishing bridge banks.

Summary of Compliance

Aggregate Compliance

• Compliant (C): 4 principles
• Largely Compliant (LC): 8 principles
• Materially Non-Compliant (MNC): 4 principles
• Non-Compliant (NC): 1 principle
• Not Applicable (NA): 1 principle

Conclusion

The DGF has made strides in protecting depositors and maintaining financial stability, but there are significant gaps in its legal authority, governance, and operational capacity. Strengthening these areas is essential to ensure the DGF can effectively fulfill its mandate and contribute to the overall resilience of Moldova's financial system.