IMF国际货币组织全球-Singapore_Financial-Sector-Assessment-Program-Detailed-Assessment-Of-Observance_130页_1mb

报告摘要

Singapore Financial Sector Assessment Program: Detailed Assessment of Observance of CPSS-IOSCO Principles for Financial Market Infrastructures

Core Content

This report is a Detailed Assessment of Observance of the CPSS-IOSCO Principles for Financial Market Infrastructures (PFMI) for Singapore, prepared by the IMF staff team as part of the Financial Sector Assessment Program (FSAP) mission in 2018. It provides an in-depth analysis of Singapore's financial market infrastructures (FMIs), particularly the MEPS+ system and the Monetary Authority of Singapore (MAS) responsibilities.

Main Points and Key Information

Overview of Payment, Clearing, and Settlement Landscape

Singapore has a well-developed and diverse FMI landscape, including:

Payment Systems: MEPS+ (Interbank Funds Transfer), FAST, SGDCCS, USDCCS, IBG, and NETS EFTPOS.
Securities Settlement Systems: MEPS+ SGS (Singapore Government Securities), CDP-SSS/CSD (Central Depository).
Central Counterparties (CCPs): CDP-CCP, SGX-DC, ICSG, and APEX Clear.
Trade Repository: DDRS (DTCC Data Repository Singapore).

The report emphasizes the importance of systemic risk management, cyber resilience, and regulatory oversight in maintaining the stability and efficiency of these systems.

Observance of CPSS-IOSCO Principles

MEPS+ Observance

MEPS+ observes 17 out of 24 PFMI principles, with broad observance of one principle (operational risk).
Six principles are not applicable to MEPS+.
The report identifies opportunities for improvement in line with international best practices.

Key Recommendations for MEPS+

Governance (Principle 2): Clarify the role and reporting line of the Chief Cyber Security Officer, ensuring the independence of the Technology Risk and Payments Department (TRPD) from operational responsibilities.
Comprehensive Risk Management (Principle 3): MAS should analyze the potential risks associated with the adoption of distributed ledger technology (DLT) in the context of MEPS+.
Operational Risk (Principle 17): Enhance enterprise-level cyber resilience through mandatory information security training, ratings for critical service providers, and compliance monitoring with the SWIFT Customer Security Program.
Disclosure (Principle 23): Expand public disclosure of key data such as system availability, daily liquidity, and throughput time to improve transparency and public confidence.

Observance of Authorities' Responsibilities

MAS Responsibilities

MAS is responsible for supervising and overseeing all FMIs in Singapore.
It is assessed against Responsibilities A to E of the PFMI.
The report finds broad observance of most responsibilities, though Responsibility B (powers and resources) is assessed as having limited observance due to resource constraints.

Key Recommendations for MAS

Powers and Resources (Responsibility B): Increase resources for the TRPD to support detailed annual assessments of MEPS+ and other payment systems.
Disclosure of Policies (Responsibility C): Publish an annual report on FMI and payments, including policies, assessment results, and risk analysis.
Application of PFMI (Responsibility D): Clarify the application of PFMI to system-wide important payment systems by revising the Supervision Monograph and conducting annual risk assessments.

Regulatory and Supervisory Framework

The legal basis for MEPS+ is supported by four main laws and five agreements.
These include the MAS Act, Payment Systems (Oversight) Act (PS(O)A), Payment and Settlement Systems (Finality and Netting) Act (FNA), and Electronic Transactions Act.
MAS supervises systemically important payment systems (SIPS) and system-wide important payment systems (SWIPS) under the PS(O)A.
SIPS are subject to the PFMI, while SWIPS are subject to an internal risk assessment framework.

Cyber Resilience

MAS has taken a proactive approach to cyber resilience, including:
- Appointing a Chief Cyber Security Officer.
- Establishing a Cyber Resiliency Framework that covers MEPS+.
- Creating a Cyber Security Advisory Panel with international experts.
MAS' cyber practices exceed minimum requirements, which is crucial for a modern financial center.

Technology and Innovation

Singapore is actively adopting new technologies, including DLT, to enhance efficiency and transparency in its FMI landscape.
The report recommends ongoing analysis of DLT-related risks and risk implications for FMIs.

Conclusion

Singapore's financial market infrastructures continue to operate safely and efficiently, with MAS playing a central role in regulation, supervision, and cyber resilience. While most principles and responsibilities are observed, there are opportunities for improvement, particularly in governance, risk management, and transparency. The FSAP mission highlights the importance of international cooperation, legal reforms, and technology-driven improvements to maintain and enhance financial stability and systemic resilience in Singapore.