2013年-IMF国际货币组织全球_Nigeria_Publication_of_Financial_Sector_Assessment_Program_Documentation––Technical_Note_on_Crisis_Management_and_Crisis_Preparedness_Frameworks_50页_996kb

Summary of Nigeria: Financial Sector Assessment Program Documentation—Technical Note on Crisis Management and Crisis Preparedness Frameworks

Core Content

This technical note, prepared by the International Monetary Fund (IMF) and the World Bank in May 2013, outlines the findings and recommendations of the Financial Sector Assessment Program (FSAP) for Nigeria. It focuses on the country's crisis management and preparedness frameworks, particularly in response to the 2008–2009 banking crisis. The document serves as background material for policy consultations and is based on legal and policy documents, as well as discussions with Nigerian authorities and private sector representatives.

Main Views and Key Information

1. Nigerian Banking Crisis of 2008–2009

• The crisis was triggered by the global financial crisis and domestic issues, including excessive credit growth, speculative investments, and poor governance.
• A special audit revealed that 10 banks, accounting for about a third of the banking system’s assets, were either insolvent or undercapitalized.
• These banks had high levels of nonperforming loans (NPLs), with some reporting NPLs at 65% of total loans.
• The Central Bank of Nigeria (CBN) took decisive action by injecting €620 billion in liquidity, providing guarantees for interbank deposits and foreign credit lines, and replacing management in eight banks.

2. Policy Response

• The CBN and the Nigeria Deposit Insurance Corporation (NDIC) implemented a range of measures, including liquidity injections, guarantees, and restructuring.
• The Asset Management Corporation of Nigeria (AMCON) was established to purchase NPLs and recapitalize banks.
• AMCON issued tradable zero-coupon bonds to facilitate the purchase of NPLs and helped stabilize the banking sector.

3. Crisis Management and Preparedness Frameworks

• The CBN remains the primary agency for financial stability, but the Financial Services Regulation Coordinating Committee (FSRCC) should be expanded to include financial stability and crisis preparedness.
• The FSRCC should be the platform for inter-agency coordination and information exchange on systemic risks and crisis management.
• A Prompt Corrective Action (PCA) framework should be formalized under the Bank and Other Financial Institutions Act (BOFIA) and the NDIC Act to ensure a statutory basis for early intervention.
• The CBN should be empowered to appoint the NDIC as a liquidator immediately upon revocation of a bank's license and exempt banks from the Company Winding Up Rules.

4. Crisis Management Tools

• The CBN and NDIC have a broad resolution toolkit, including mergers and acquisitions (M&A), bridge banks, and asset management companies (AMCs).
• The resolution toolkit should be strengthened with powers to override shareholder rights, prevent suspension of proceedings, and implement statutory bail-in mechanisms.
• The Emergency Liquidity Assistance (ELA) framework should be developed for the CBN, and the Ministry of Finance (MoF) should be able to provide solvency support.

5. Deposit Insurance Framework

• The deposit insurance scheme is structured to minimize risk and is ex-ante funded.
• The NDIC should be exempted from the Fiscal Responsibility Act to build up the Deposit Insurance Fund (DIF).
• The NDIC should have a credit line to the MoF rather than the CBN.
• The statutory payout period for insured deposits should be shortened to 15 days and changed to a gross payout mechanism.

6. AMCON

• AMCON was a key tool in the crisis response but should have a temporary mandate.
• It should stop acquiring problem assets and focus on the disposal of NPLs and assets with clear targets.
• A sunset clause should be introduced to ensure that AMCON winds down its operations by the end of 2017.
• The bill establishing the Resolution Cost Fund should be approved to ensure that AMCON’s bond repayments are properly funded.

7. Legal Protection

• Legal protection for the CBN, NDIC, and AMCON should be enhanced.
• Recommendations include reversing the burden of proof, raising the threshold for commencing action, and providing express indemnity for legal costs.

Key Recommendations

Conclusion

The document emphasizes the need to transition from crisis response to exit strategies and long-term preparedness. It highlights the importance of legal clarity, inter-agency coordination, and systemic risk monitoring. The recommendations are aligned with international best practices and aim to reduce moral hazard, ensure the financial system's resilience, and promote private sector solutions. The CBN, NDIC, and AMCON are central to these efforts, with a focus on legal protection, statutory mandates, and transparent mechanisms for crisis resolution and management.