2013年-IMF国际货币组织全球_European_Union_Publication_of_Financial_Sector_Assessment_Program_DocumentationTechnical_Note_on_Deposit_Insurance_16页_600kb

Summary of the European Union: Financial Sector Assessment Program Documentation – Technical Note on Deposit Insurance

Core Content

This document provides an analysis of the deposit insurance arrangements within the European Union (EU), focusing on the harmonization process, principles and best practices, and recommendations for improving the credibility and effectiveness of deposit guarantee schemes (DGS).

The document is part of the IMF's Financial Sector Assessment Program (FSAP) and was prepared as background for the periodic consultation with EU member states. It is based on data available up to February 22, 2013 and reflects the views of the IMF staff, not necessarily those of the EU or its Executive Board.

Main Purposes of Deposit Insurance

• To provide a safety net for small depositors.
• To enhance financial stability by reducing the risk of bank runs.
• To limit financial contagion across borders by ensuring timely and credible payouts.

Overview of Existing Deposit Insurance Arrangements in the EU

• The EU has a variety of national deposit guarantee schemes, with significant differences in coverage, funding, and operational structure.
• Some countries, such as Austria and Germany, have multiple schemes.
• Most schemes rely on ex-post funding mechanisms, with limited prefunding.
• Germany's DGS provides up to 30% of bank capital per depositor, effectively offering unlimited coverage for many depositors.
• Mutualization of liabilities among participating banks is a feature in some systems, particularly in savings and cooperative banks.

Harmonization of DGS

• The harmonization process began in 1994 with the EU Directive on Deposit Guarantee Schemes.

• The 2009/14/EC Directive introduced minimum coverage limits of €50,000 (mid-2009) and €100,000 (end-2010) per depositor per bank.

• The maximum payout period was reduced to 20 working days by end-2010.

• Further harmonization was proposed in 2010, including:

  • Common standards on financing and coverage.
  • Target fund size of 1.5% of eligible deposits.
  • Risk-based contributions.
  • Shorter payout periods (up to 7 working days).
  • Clarification of responsibilities for cross-border banks.
  • Limited cross-border borrowing arrangements between DGSs.

• However, harmonization was suspended until the adoption of the EU bank resolution arrangements through a new Directive.

Principles and Best Practices for DGS

1. Appropriate Coverage

• Coverage should be sufficient to prevent destabilizing bank runs but not so extensive as to eliminate market discipline.
• The €100,000 coverage limit is considered broadly appropriate for most EU member states.
• Coverage should exclude interbank and insider deposits to limit moral hazard.

2. Timely Payouts

• Timely payouts are essential to prevent panic and ensure financial stability.
• In some jurisdictions, payouts occur within 48 hours of a bank failure.
• Depositor preference (priority rights over the estate of a failed bank) is missing in some EU countries, which could delay payouts and increase resolution costs.

3. Adequate Funding

• DGSs can be funded through ex-ante (pre-funded) or ex-post (emergency) mechanisms.
• Ex-ante funding is preferred as it enhances stability and reduces moral hazard.
• Ex-post funding may induce market discipline but has pro-cyclical effects.
• Government back-up funding is necessary to lend credibility to the system and deal with systemic crises.

4. Legal and Institutional Framework

• DGSs should operate under a clear legal mandate and appropriate legal framework.
• The role of the DGS must be well-defined and coordinated with other agencies in the resolution framework.
• Public awareness and outreach are critical to stabilize depositor fears.

5. Risk-Based Premiums

• Insurance premiums should reflect the risk of individual banks.
• Currently, most EU DGSs do not adjust premiums for risk, leading to disproportionate burden on smaller and deposit-rich banks.
• The proposed recast of the DGS Directive would introduce non-risk and risk-based contributions.

6. Mandatory Schemes

• National DGSs should be mandatory, not voluntary, to:
  • Ensure a level playing field.
  • Reduce adverse selection.
  • Expand the insurance pool, which enhances actuarial reliability and reduces the probability of insolvency.

Key Recommendations

• Harmonization of DGSs is essential for financial integration and internal market functioning.
• Coverage, pricing, and funding should be aligned across EU member states to limit regulatory arbitrage.
• Prefunding is necessary to ensure credible resolution of bank failures, especially in cross-border scenarios.
• Common funding for DGSs should be considered as part of the banking union.
• A common or linked deposit insurance system could be designed as a reinsurance scheme, funded at the EU level through industry levies and member state contributions.
• Government backstops are required to support DGSs in the event of systemic crises.
• Resolution frameworks need to be enhanced and harmonized, including granting priority rights to insured depositors and DGSs.

Conclusion

The document highlights the importance of harmonization in the EU's deposit insurance system to support financial stability, reduce moral hazard, and enhance cross-border cooperation. It emphasizes the need for common funding, risk-based premiums, and clear legal mandates to ensure credible and effective deposit insurance schemes. The banking union is seen as a critical platform for achieving these objectives, with deposit insurance harmonization being a long-term goal.