FSB全球金融稳定委员会-Evaluation-of-the-effects-of-too_137页_4mb

报告摘要

Summary of the Evaluation of the Effects of Too-Big-to-Fail Reforms

Core Content

This consultation report evaluates the effects of too-big-to-fail (TBTF) reforms on systemically important banks (SIBs), including their impact on systemic risk, moral hazard, market discipline, and the broader financial system. The reforms were introduced by the G20 in response to the 2007-08 global financial crisis and have been implemented in FSB jurisdictions over the past decade. The report does not make specific policy recommendations but aims to provide an evidence-based assessment of the reforms' effectiveness and identify remaining challenges.

Main Findings

1. Reduction in Systemic and Moral Hazard Risks

Systemic risk indicators have moved in the right direction since the implementation of TBTF reforms.
Moral hazard has been reduced as banks are now more capitalised, less leveraged, and more liquid.
The reforms have improved the resolvability of SIBs, allowing authorities to resolve failing banks without taxpayer support.
TLAC requirements have been largely met by G-SIBs, with most now on track to meet final requirements by 2022.
Market discipline has improved, as evidenced by higher sensitivity of CDS prices to bank risk and the pricing of TLAC-eligible debt.

2. Net Benefits to Society

The reforms are associated with net social benefits, including increased financial system resilience and no significant rise in funding costs.
Credit supply has not been materially affected by the reforms, with aggregate credit and GDP growing at similar rates post-reform.
SIBs have lost domestic market share, indicating a shift in financial services provision to other institutions.

3. Remaining Gaps and Challenges

Obstacles to resolvability still exist, including issues with TLAC implementation, resolution funding mechanisms, and asset valuation in resolution scenarios.
State support for failing banks continues, suggesting that resolution frameworks are not yet fully effective in all jurisdictions.
Transparency and data availability remain insufficient, limiting the ability of authorities and the FSB to monitor and evaluate the reforms effectively.
D-SIBs (Domestic Systemically Important Banks) require further monitoring, as they are not yet as well-documented as G-SIBs.
Non-bank financial intermediaries are becoming more prominent in credit intermediation, introducing new risks that need to be closely monitored.

Key Information

Reforms Overview

The TBTF reforms include:

Capital surcharges and TLAC requirements to ensure banks can absorb losses during resolution.
Enhanced supervision and higher supervisory expectations to improve risk management.
Effective resolution regimes and resolution planning to enable orderly bank resolution.

These reforms are designed to reduce the likelihood of taxpayer bailouts and promote market discipline.

Implementation Status

G-SIBs (Global Systemically Important Banks) have made significant progress in meeting TLAC requirements.
Resolution planning and cross-border cooperation agreements have been established for most G-SIBs.
Market responses have generally been positive, with TLAC-eligible debt being issued and absorbed without significant disruption.

Market Perceptions

Funding cost advantages of SIBs have decreased since the reforms, though they remain higher than pre-crisis levels.
Credit rating agencies have started to reflect the credibility of resolution reforms, assigning lower ratings to holding companies than their subsidiaries.
Market discipline has improved, as evidenced by increased sensitivity of CDS prices to bank risk.

Banks' Responses

SIBs have become more capitalised and resilient, but their profitability has declined.
D-SIBs have also increased their capital ratios, though there are no material differences in other balance sheet items compared to non-SIBs.
The structure of the financial system has not changed significantly in terms of credit supply, as other financial institutions have compensated for reduced lending by SIBs.

Broader Impacts

Global financial integration has continued despite the 2007-08 crisis, with cross-border connectedness returning to pre-crisis levels.
Central counterparties (CCPs) have become more important for financial stability, and their resilience is a key focus of ongoing work.
Market-based systemic risk measures have declined, suggesting that the financial system is less vulnerable to shocks.

Conclusion

The evaluation concludes that TBTF reforms have made progress in reducing systemic and moral hazard risks, and that they bring net benefits to society. However, gaps remain, particularly in resolution feasibility, data transparency, and cross-border coordination. The FSB continues to monitor the effects of these reforms and is committed to addressing these challenges to ensure the long-term stability of the global financial system.

Recommendations for Further Work

Enhance transparency and data availability to support better monitoring and evaluation of resolution regimes.
Continue improving the resolvability of SIBs, especially for D-SIBs.
Monitor the shift to non-bank financial intermediaries and assess the associated risks.
Extend the consultation period to incorporate pandemic-related developments and update the analysis accordingly.

Appendix Highlights

Annex A provides a detailed overview of TBTF reforms and their implementation.
Annex B outlines the elements of resolution reforms.
Annex C summarises public feedback and workshop discussions.
Annex D introduces the resolution reform index.
Annex E includes a literature review.
Annex F discusses credit rating agencies' views on resolution reforms.
Annex G presents case studies of bank resolutions.
Annex H describes the testing of bank behavior under resolution scenarios.
Annex I lists the members of the evaluation working group.