2015年-数据局_德勤：监管改革亚太国家进展情况_16页_1mb

Regulatory Reform in the Asia Pacific: State of Play (September 2015)

Core Content

This document outlines the current state of regulatory reform in the Asia Pacific region, focusing on key international initiatives and their local implications. It emphasizes the ongoing evolution of post-crisis reforms, including Basel III and IV, the elimination of "too-big-to-fail" risks, OTC derivatives regulation, shadow banking transformation, and conduct and wholesale markets reforms.

Main Regulatory Workstreams

1. Building Resilient Financial Institutions

• Basel III Implementation:

  • Basel III introduced new capital, liquidity, and leverage requirements.
  • Key components include the Leverage Ratio, Liquidity Coverage Ratio (LCR), and Net Stable Funding Ratio (NSFR).
  • The Leverage Ratio is expected to be finalized in 2015 with mandatory implementation in 2018.
  • The LCR is being phased in from 2015 over five years.
  • The NSFR was finalized in October 2014 and will be a minimum standard by 2018.
  • Transition periods exist for some aspects, with uncertainty around the counter-cyclical capital buffer.

• Asia Pacific Progress:

  • Most jurisdictions in the region have implemented Basel III standards ahead of other major countries.
  • Implementation timelines for key reforms vary, with full implementation likely to extend beyond 2016.

2. Moving to Basel IV?

• Proposed Revisions:

  • Basel IV includes new standardised models for credit, market, and operational risk.
  • Reduces variance in capital calculations and constrains bank discretion.
  • Includes the Fundamental Review of the Trading Book (FRTB), which is still under review with a fourth quantitative impact study launched.

• Capital Floors:

  • Capital floors for internal model outputs will be based on new standardised approaches.
  • These floors aim to ensure capital levels do not fall below a yet-to-be-calibrated threshold.

• Interest Rate Risk:

  • Revisions to the regulatory treatment of interest rate risk are being considered.
  • Options include a new Pillar 1 approach or a revised Pillar 2 approach with more standardisation.

3. Global Capital Standard for Insurers

• Insurance Capital Standard (ICS):
  • The ICS initiative, part of the Common Framework (ComFrame), aims to develop a global capital standard for insurers.
  • A second ICS consultation and field testing are scheduled for mid-2016.

4. OTC Derivatives Regulation

• G20 Commitments:

  • By 2012, all OTC derivatives should be reported to trade repositories.
  • Standardised contracts should be traded on exchanges or cleared through CCPs.
  • Non-centrally cleared contracts face higher capital and margin requirements.

• Asia Pacific Implementation:

  • Full implementation of OTC derivatives reforms is expected beyond 2016.
  • Hong Kong: Reporting starts in H2 2016, clearing in H2 2016, margin requirements in Q3 2015.
  • Singapore: FX trade reporting started in Q2 2015, clearing in Q4 2015, margin requirements in Q3 2015.
  • Japan: Full reporting implemented, clearing expanded in H1 2016, mandatory trading of yen-denominated swaps in Q3 2015.
  • Australia: Reporting fully implemented in Q4 2015, clearing for major interest rate swaps expected in H1 2016, margin requirements in H1 2016.

• Challenges:

  • Extra-territoriality and inconsistent implementation across jurisdictions.
  • Fragmentation of previously integrated markets.

5. Transforming Shadow Banking into Resilient Market-Based Financing

• Definition:

  • Shadow banking refers to credit intermediation outside the regulated banking sector.
  • Concerns exist that risky activities may migrate to less regulated areas.

• FSB Initiatives:

  • Focus on assessing the implementation of existing reforms and data collection.
  • Work includes monitoring money market funds and other shadow banking activities.

6. Conduct and Wholesale Markets

• Conduct as a Key Issue:

  • Poor conduct in the financial system is seen as a systemic risk.
  • FSB has focused on interest rate and foreign exchange benchmarks, moving from inter-bank offer rates to transaction-based and risk-free rates by 2016.

• Future Workstreams:

  • The UK's Fair and Effective Markets Review (FEMR) recommends a code of conduct for spot foreign exchange markets and standards for FICC markets.
  • The FSB is expected to report to the G20 on findings and make policy recommendations by northern spring 2016.

Key Information

• Regulatory Agenda:

  • Regulatory reform remains a major strategic consideration for financial services firms.
  • The agenda is expected to continue with recalibrations of existing standards and new areas of focus.

• Asia Pacific Challenges:

  • Each regulatory framework brings unique challenges, especially for multinational firms.
  • Implementation timelines and methods vary across jurisdictions, leading to cross-border compliance complexities.

• Global Coordination:

  • There is a need for harmonisation of trade reporting and cross-border mutual recognition.
  • The FSB is working on global aggregation of trade data and the development of international standards.

Conclusion

The Asia Pacific region is actively implementing and adapting to the international regulatory reform agenda, which includes Basel III and IV, ending too-big-to-fail, OTC derivatives regulation, shadow banking transformation, and conduct reforms. While progress has been made, the complexity and evolving nature of these reforms continue to challenge financial institutions and regulators alike. The region is expected to see further regulatory developments and adjustments in the coming years, requiring ongoing monitoring and strategic adaptation.