2011年-IMF国际货币组织全球_United_Kingdom_Observance_by_CHAPS_of_CPSS_Core_Principles_for_Systemically_Important_Payment_Systems_Detailed_Assessment_of_Observance_36页_547kb

报告摘要

Summary of Observance by CHAPS of CPSS Core Principles for Systemically Important Payment Systems

Core Content

This document provides a detailed assessment of the UK's Clearing House Automated Payment System (CHAPS) in relation to the Core Principles for Systemically Important Payment Systems (CPSS Core Principles). The assessment was conducted as part of the IMF Financial Sector Assessment Program (FSAP) in 2011 and evaluates how well CHAPS adheres to the principles, as well as outlines recommendations for improvement.

CHAPS is a large-value payment system that supports real-time gross settlement (RTGS) for sterling-denominated transactions. It is managed by CHAPSCo, with the Bank of England (BoE) operating the underlying RTGS infrastructure. The system is robust and efficient, but there are areas where further improvements are needed to ensure full compliance with the CPSS Core Principles.

Main Findings

Legal Framework (CP I)

CHAPS operates under a well-founded legal basis, reinforced by its designation under the Financial Markets and Insolvency Regulations (FMIR 1999).
The BoE has a statutory role in overseeing CHAPS under the Banking Act 2009.
A binding contract between the BoE and CHAPSCo is not in place, and the Memorandum of Understanding (MoU) is not legally binding.
The BoE has indicated that a supplementary legal review of the MoU's non-binding nature is underway.

Understanding and Management of Risks (CP II-III)

CHAPS provides members with clear understanding of financial risks, including liquidity and operational risks.
In normal operations, members do not face credit risk, but in Bypass mode, which is used as a contingency, there is potential exposure to credit risk.
There are no clear procedures for allocating losses in the event of a default by a member in a net debit position during Bypass mode.
CHAPSCo is working on developing such procedures and is expected to complete them in 2011.

Settlement (CP IV-VI)

Settlement finality occurs in real time using central bank money.
In Bypass mode, settlement is done on a multilateral net basis, which could introduce credit risk.
A significant portion of large-value payments settles in commercial bank money, which is a potential vulnerability.
The BoE has been encouraging banks to become direct members to reduce this concentration.

Operational Reliability and Efficiency (CP VII-VIII)

CHAPS is highly reliable and secure, with members and suppliers required to comply with strict security policies.
The BoE operates a hot back-up site, but the two processing sites are only 12 miles apart, making them vulnerable to wide-area events.
CHAPSCo and the BoE are considering the implementation of a generic RTGS backup system (Market Infrastructure Resilience Service) to replace Bypass mode in case of a system outage.
This project is still in the planning phase, with a potential delivery date of 2013/2014.

Access and Governance (CP IX-X)

Membership in CHAPS is fair and open, but the criteria are not publicly disclosed.
CHAPSCo manages both CHAPS and FPS, which are at different stages of development, raising governance concerns.
Succession planning for the Company Manager is an area requiring improvement.
Governance arrangements are being reviewed externally, and a report has been completed with implementation plans underway.

Central Bank Responsibilities (A-D)

The BoE has clear objectives for payment system oversight and has disclosed its role and policies.
It ensures that systems it operates comply with the Core Principles.
It oversees systems it does not operate, demonstrating its ability to carry out this function.
The BoE collaborates with other central banks and domestic/foreign authorities to promote payment system safety and efficiency.

Key Recommendations

Recommended Actions

Core Principle/Responsibility	Recommended Action
Core Principle III	CHAPSCo should develop procedures to allocate losses in case of a default in Bypass mode. This is expected to be completed by 2011.
Core Principle X	CHAPSCo should improve transparency in governance and demonstrate the ability to manage both CHAPS and FPS.
Central Bank Responsibility B	The BoE should conduct a direct and unified assessment of the RTGS infrastructure against the Core Principles.
Core Principle I	The BoE should conduct a legal review of the non-binding nature of the MoU with CHAPSCo.
Core Principle VI	The BoE should continue to raise awareness of the risks associated with tiering and encourage direct participation.
Core Principle VII	CHAPSCo and the BoE should proceed with the implementation of a back-up RTGS system to replace Bypass mode.
Core Principle IX	CHAPSCo should make the CHAPS rules and fees publicly available.

Conclusion

The assessment concludes that CHAPS is generally compliant with the CPSS Core Principles, with some areas requiring further attention. The BoE's oversight is effective, but a direct and unified assessment of the RTGS infrastructure is recommended. CHAPSCo needs to improve governance transparency and demonstrate its capacity to manage both CHAPS and FPS. These recommendations aim to enhance the resilience, efficiency, and safety of the UK's payment system.

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