2016年-世界发展银行全球_Financial_Sector_Assessment_Program___Montenegro_Deposit_Insurance_System_43页_718kb

Summary of the Financial Sector Assessment Program (FSAP) on Montenegro's Deposit Insurance System

Core Content

The Financial Sector Assessment Program (FSAP) conducted by the World Bank and IMF in Montenegro during September 2015 assessed the deposit insurance system (DIS) against the BCBS-IADI Core Principles from 2009, with a reference to the revised 2014 principles. The assessment aimed to evaluate the effectiveness of the financial safety-net arrangements, including the Deposit Insurance Fund (DPF), and identify areas for improvement.

Main Findings

The deposit insurance system in Montenegro is relatively well-developed, with the DPF established in 2006 and operating under a narrow "pay box" mandate. The DPF is financed through annual premiums from member banks, a standby credit line with EBRD, and a statutory provision for government back-up funding. It currently insures 99.26% of depositors and 36.38% of deposits fully, with a coverage level of EUR 50,000 per depositor per bank. The system has never been triggered, indicating a lack of bank failures requiring intervention.

Strengths of the System

• Prompt payout mechanisms: DPF has developed infrastructure for 15 working days deposit reimbursement.
• Information exchange: A Memorandum of Understanding (MoU) with the Central Bank of Montenegro (CBM) supports coordination.
• Legal framework: The DPF is an independent legal entity under the Deposit Protection Law (DPL), with clear powers and responsibilities.

Areas for Improvement

• Payout timeframe: Should be shortened to 7 working days to align with international best practice.
• Risk-based premiums: Currently not implemented, but DPF is in the process of developing such a system.
• Resolution framework: Needs strengthening, particularly through the transposition of the BRRD (expected by 2017).
• Public awareness: Current programs should be critically assessed and enhanced with a long-term strategy.
• Internal governance: The Managing Board should adopt a multi-annual strategic plan and internal audit function.
• Contingency planning: A system-wide crisis simulation is lacking and should be conducted.
• Coordination with other safety-net participants: The MoU with the MoF and CBM should be improved.
• Cross-border cooperation: DPF should engage with foreign deposit insurance systems to improve information exchange.
• Legal consistency: Definitions of "deposit" in the DPL and Banking Law should be aligned.
• Investment policies: The DPF should abolish investments in commercial bank securities.
• Tax exemption: DPF’s income should remain exempt from taxes.

Key Recommendations

Immediate (I)

• DPF should become a member of the Financial Stability Council (FSC) to be involved in crisis management.
• DPF should be given early warning of potential bank failures through its FSC membership.
• Bankruptcy administrator should provide DPF with necessary data within 5–7 days for accurate reimbursement calculations.
• DPF should pre-arrange the use of agent banks, call-centers, and other contractors for efficient payout procedures.

Near-Term (NT)

• Amend the DPL to allow DPF to finance the transfer of insured deposits to another bank.
• Enhance DPF's powers to make interim or advanced payments and use alternative reimbursement methods.
• Establish a formal internal review process in the DPF By-Law and a formal external review in the DPL.
• Amend the DPL to define deposit in line with the Banking Law and ensure separate coverage for deposits in merged banks for a limited period.
• Introduce risk-based premiums and stop investing DPF funds in commercial bank securities.
• Amend the DPL to include legal protection for DPF staff and ensure clear rules prevent other safety-net participants from acquiring assets from failed banks.
• Revise internal guidelines and MoUs to align with the transposition of EU directives (DGSD and BRRD).
• Develop a resolution manual and system-wide crisis simulation.
• Amend the DPL to include a long-term public awareness strategy and allocate budget for future activities.

Medium-Term (MT)

• DPF should explore repo-agreements and pre-arrange supplementary back-up funding from the state budget.
• DPF should be aligned with the EU's DGSD and BRRD to ensure full compliance with international standards.
• DPF should be considered for membership in the FSC to enhance system-wide coordination.
• DPF should be prepared to manage a future resolution fund once Montenegro joins the EU, leveraging its existing premium collection experience.

Conclusion

The DPF in Montenegro is a well-established and functional deposit insurance system, with sufficient funding to cover deposits in small banks and efficient payout procedures. However, to fully align with international best practices and the revised IADI Core Principles, the system requires enhancements in governance, legal framework, public awareness, and coordination with other financial safety-net participants and foreign deposit insurance systems. These improvements will ensure greater resilience and effective crisis management in the future.