2013年-IMF国际货币组织全球_Italy_Detailed_Assessment_of_Observance_of_Basel_Core_Principles_for_Effective_Banking_Supervision_179页_2mb

Detailed Summary of the 2013 Basel Core Principles Assessment for Italy

Core Content Overview

This document presents a detailed assessment of the observance of the Basel Core Principles (BCP) for effective banking supervision in Italy, conducted by the International Monetary Fund (IMF) in January 2013 as part of a Financial Sector Assessment Program (FSAP) update. It evaluates the regulatory and supervisory framework in place at the time, highlighting both strengths and areas requiring improvement. The assessment is based on the 2012 Revised Core Principles, which reflect post-crisis regulatory developments and a heightened focus on risk management, systemic risk, and crisis resolution.

Main Findings and Key Points

1. Supervisory Framework and Practices

• The Banca d'Italia (BI) has a strong and integrated supervisory approach, including offsite analysis, onsite inspections, and analytical data.
• The Supervisory Review and Evaluation Process (SREP) is a key mechanism used to assess banks on a range of risk areas, including credit, financial, operational, profitability, capital, strategic, and governance risks.
• The risk ratings from SREP serve as the foundation for supervisory plans and corrective actions.

2. Progress on Previous Recommendations

• Authorities have made progress on addressing recommendations from the 2006 FSAP, but some issues remain, such as:
  • Legal protection of supervisors (e.g., lack of clear procedures for covering legal costs).
  • Limited powers to remove board members, senior officials, and external auditors.
• Legal amendments in 2005, 2006, and 2012 have improved the framework, especially regarding non-performing loans (NPLs) and related party lending.

3. Compliance with the Basel Core Principles

• Italy was the first country to be assessed under the 2012 Revised BCP, and the first to be rated on both essential and additional criteria.
• The assessment methodology was updated, leading to a non-comparable result with previous assessments due to the higher standards set by the revised BCP.
• Compliance is evaluated on a qualitative basis using a four-tier grading system:
  • Compliant
  • Largely compliant
  • Materially noncompliant
  • Noncompliant
• The assessment is not an exact science, requiring judgment due to the complexity and volatility of the Italian and European banking systems at the time.

4. Supervisory Challenges and Recommendations

• Lack of powers to remove directors and senior managers hampers timely corrective action and corporate governance.
• Legal framework for NPLs is influenced by fiscal and judicial requirements, with provisioning practices constrained by long court processes and tax rules.
• Related party lending regulations, though updated in 2013, still have deficiencies such as:
  • No explicit requirement for equal terms for related and non-related parties.
  • Connected parties are defined differently than in the large exposure regime.
• Supervisory practice may mitigate these issues, but implementation is still in its early stages.

5. Market Structure and Financial System

• The Italian financial system includes banks, insurance companies, pension funds, and asset management firms.
• Banks hold 75% of total system assets, while Central Bank and insurance companies account for 9.8% and 9.7%, respectively.
• Total lending to GDP is 125%, lower than the Euro area average, due to low household debt and high real estate holdings.
• Banking sector concentration has increased slightly, with the top two and five banking groups holding 31% and 49% of total assets by 2011.
• Pension funds have seen the largest asset growth (74%), followed by banks (53%), while insurance assets have remained stable relative to GDP.

Key Recommendations

• Clarify legal procedures for covering the legal costs of supervisors.
• Enhance the powers of the BI to remove board members, senior officials, and external auditors.
• Revise the legal framework for related party lending to ensure equal terms and clear definitions.
• Issue guidance on country and transfer risk, especially for non-systemically important banks.
• Improve the large exposure regime to better reflect risk concentration across industry, region, and market.
• Ensure consistent application of provisioning rules across all banks, especially in light of tax and judicial constraints.
• Strengthen corporate governance and internal controls as part of the supervisory process.

Methodology and Context

• The assessment was conducted using the 2012 Revised Core Principles, which emphasize:
  • Supervisory intensity and resource allocation.
  • Macro-prudential approaches to identify and mitigate systemic risk.
  • Crisis preparedness and resolution.
  • Market discipline through disclosure and transparency.
• The proportionality concept is central to the BCP, ensuring that supervisory standards are tailored to the risk profile and systemic importance of banks.
• The assessment is not directly comparable to previous ones or other countries due to the evolution of standards and regulatory environment.

Conclusion

Despite a strong supervisory framework, Italy faces challenges in aligning its legal and regulatory environment with the enhanced requirements of the revised BCP. The BI has made significant progress in risk management and supervision, but gaps remain in corporate governance, legal protections, and crisis management. The assessment highlights the need for further reforms to ensure effective and robust banking supervision in line with international standards.