2012年-世界发展银行全球_Brazil___Risk-based_Supervision_of_Brazilian_Closed_Pension_Funds_180页_2mb

Summary of the World Bank Report on Risk-Based Supervision of Brazilian Closed Pension Funds

Core Content

This report outlines the World Bank's project, funded by FIRST, aimed at supporting the implementation of Risk-Based Supervision (RBS) for closed pension funds (EFPCs) in Brazil. The project was conducted in collaboration with PREVIC, the National Superintendent for Pension Funds, established in January 2010. The goal was to develop and implement a risk-based supervisory framework tailored to the Brazilian environment, drawing on international experience and best practices.

Main Objectives

The project had four key objectives:

• Assess the current supervisory framework against global RBS best practices.
• Develop a roadmap for implementing RBS in the Brazilian closed pension system.
• Propose regulatory changes to support the RBS framework.
• Provide training to supervisors and senior executives of closed pension funds.

Key Findings and Recommendations

1. Risk-Based Supervision (RBS) Framework

• RBS enables supervisors to focus on the most intense risks while reducing the effort on lower risks.
• It relies on pension fund fiduciaries to manage risks, provided their governance and risk management are robust.
• The most intense risks in the Brazilian system are related to:
  • Actuarial risk: Misalignment between actuarial valuation assumptions and actual outcomes.
  • Investment risk: The challenge of managing returns in a low-interest rate environment.
  • Governance risk: Weak oversight by the top governance bodies (Conselho Deliberativo and Conselho Fiscal).

2. Implementation Roadmap

• The roadmap was developed through a seven-stage value chain for RBS (Figure 12).
• The process was evolutionary and faced delays due to resource constraints.
• Key milestones included:
  • Preparation and publication of the first module of the Guide on Best Practices in August 2010.
  • Development of the on-site supervision manual by the end of 2011.
  • Transition from monthly to quarterly reporting by pension funds.
  • Implementation of a central risk analysis function and risk committee to coordinate RBS across PREVIC.

3. Regulatory and Legislative Changes

• The project identified the need to revise Resolution 18 (actuarial valuation regulation) to encourage best practices.
• Changes to Decree 4942 (governing regulation) were proposed to strengthen enforcement mechanisms.
• CMN3792 (investment regulation) should be updated to include investment profiles and life-cycling.
• Regulatory changes were also recommended to address governance risks in multi-sponsored pension funds and to improve the effectiveness of blocking harmful license amendments.

4. Training and Education

• The RBS team developed 14 principles specific to the Brazilian context.
• These principles included:
  • Educate: Clarify expectations for pension funds and raise standards through certification and training.
  • Orientate: Provide one-on-one guidance to help pension funds implement RBS.
  • Enforce: Take proportionate action against non-compliance, especially in cases of serious risk or wrong-doing.
• A self-assessment questionnaire for conselheiros was developed to support fiduciary education.

5. Supervisory Tools and Functions

• The SIAD tool was developed to support data access and analysis for RBS.
• A central risk analysis function was established to coordinate RBS implementation and information flow.
• Off-site analysis and on-site inspections were refined to better assess and manage risks.
• A traffic light model was proposed to categorize risk levels and guide supervisory responses.

Implementation Progress

By the end of the project (March 2012), the following had been achieved:

• A revised on-site inspection manual was developed and piloted successfully.
• The Guide on Best Practices was in progress, with some modules published and others in draft.
• A central risk analysis committee was established to support RBS coordination.
• The reporting frequency was changed from monthly to quarterly.
• IT development was underway to improve supervisory tools.

Challenges and Next Steps

• Personnel changes and resource constraints affected the implementation process.
• The need for a dedicated education unit was identified, as the current approach lacked a centralized role for training.
• The project emphasized the importance of ongoing education and enforcement to ensure long-term success.

Conclusion

The report highlights the successful development and partial implementation of RBS in Brazil, with a focus on governance, actuarial, and investment risks. It provides a detailed framework for future supervision and regulatory improvements, aiming to align the Brazilian pension system with international standards. The project laid the groundwork for a more targeted, effective, and transparent supervisory approach, with a clear pathway for full implementation.