2005年-世界发展银行全球_Financial_Sector_Assessment___Moldova_15页_1mb

Moldova Financial Sector Assessment Summary (March 2005)

I. Background

• The Financial Sector Assessment Program (FSAP), a joint initiative by the IMF and World Bank, was conducted in Moldova by two teams in 2004.
• The assessment focused on three areas: short-term stability and resilience, compliance with international standards, and medium-term and developmental issues.
• The Anti-Money Laundering (AML)/Combating the Financing of Terrorism (CFT) section was based on an IMF technical assistance mission in April 2004.
• A full AML/CFT assessment by MONEYVAL (a FATF-style regional body) is scheduled for early 2005.
• During the IMF Article IV mission in October 2004, further discussions were held with Moldovan authorities, leading to the development of a technical assistance program to support the implementation of recommendations, particularly in banking supervision, insurance sector reform, and corporate governance.

II. Strategic Assessment

Core Content and Main Issues

• Moldova, despite being the poorest country in Europe, has made progress in establishing a market economy framework, especially in the banking sector, though implementation remains weak.
• Quantitative indicators suggest a sound banking system, but qualitative concerns are significant:
  • Governance problems due to increasing government involvement in banking and insurance.
  • Opaque ownership structures in financial institutions and corporations, with limited strategic investors.
  • Exchange rate appreciation and credit boom pose risks to banks’ balance sheets.
• Stress tests were conducted, but data reliability is limited due to political constraints on supervisors and lack of transparency in ownership and beneficial ownership.
• Systemic vulnerabilities are high, especially due to government intervention, opaque ownership, and absence of fit-and-proper investors.

Key Recommendations

III. Financial Sector and Regulatory Context

Financial Sector Structure

• The banking sector is small in terms of assets (US$ 780 million as of end-2003, or 38% of GDP), but has 16 banks, with six largest banks controlling 77% of assets, 80% of deposits, and 63% of capital.
• The state-owned bank (second largest) holds 56% of shares, with increased government influence.
• Foreign ownership is present in three banks, but no first-tier foreign banks are directly involved.
• Offshore-controlled banks make up the majority, with no offshore shareholder exceeding the 10% threshold requiring NBM approval.
• The insurance sector is underdeveloped, with 50 insurance companies but low insurance penetration (only 0.8% of GDP in 2003).
• SME financing remains limited, with leasing and microfinance underdeveloped due to tax disadvantages.

Banking Sector Performance

• The banking sector shows impressive earnings and capitalization, with low NPLs (6.2% of total loans in 2003).
• However, smaller banks lag behind, with higher NPL rates (12.7% vs. 6.2% for the sector).
• The NBM has introduced a "loans under supervision" category (35.3% of total loans), which may indicate future risks.
• Dollarization remains high (around 50% of total assets and deposits), with foreign currency deposits at 45% and foreign exchange lending at 42%.
• Liquidity management is challenging due to limited secondary markets, and excess reserves held at the NBM increase loan pricing pressures.

IV. Systemic Vulnerabilities

Macroeconomic Risks

• Fiscal and external arrears are major risks, with the NBM financing the budget leading to loss of independence and reduced access to external financing.
• Workers’ remittances have increased to 24% of GDP in 2003, but consumption-driven growth leads to import growth and trade deficits.
• Exchange rate appreciation (4.5% in 2003, 13% in 2004) threatens competitiveness and bank balance sheets.
• Dollarization and exchange rate volatility increase financial vulnerability.
• Credit growth may lead to loose lending standards and self-reinforcing cycles, which could reverse in case of economic downturn.

Financial Soundness and Stress Testing

• Stress tests did not reveal systemic vulnerabilities, but some banks were found to be more vulnerable.
• Key risks include:
  • Credit risk and exchange rate risk.
  • Liquidity risk from selling government securities to meet withdrawal demands.
  • Insurance subsidiaries of banks not being consolidated, leading to inaccurate stress test results.
• State-owned banks and offshore-controlled banks are at higher risk due to opaque ownership, limited accountability, and weak governance.
• The NBM lacks effective tools to monitor connected lending and large exposures, and cannot hold controlling shareholders accountable.
• Government policies, such as mandatory dividends and state-owned enterprise lending, further weaken bank capital and risk management.

V. Supervision and Regulation

• The supervisory framework is reasonably comprehensive, but implementation is weak.
• Supervisory independence is formally present but practically constrained by government participation in NBM decisions.
• Legal protection for supervisors is lacking.
• Inter-agency cooperation and information sharing are limited, reducing the effectiveness of financial system oversight.
• Shareholder identification below the 10% threshold is inadequate, making it difficult to enforce prudential regulations.
• Insider lending and large exposures are not effectively monitored, and banks lack reserves for potential insurance-related losses.

Conclusion

Moldova’s financial sector shows positive indicators in terms of capitalization and low NPLs, but faces significant systemic vulnerabilities due to opaque ownership, government intervention, and weak governance. Structural reforms and improved regulatory frameworks are essential to address these issues and ensure long-term financial stability.