2014年-世界发展银行全球_Financial_Sector_Assessment___Poland_35页_875kb
报告摘要
Financial Sector Assessment of Poland (January 2014)
Core Content
Poland's financial system is considered resilient, with sound macroeconomic management and strong fundamentals helping it weather the global financial crisis and Euro Area turmoil. However, vulnerabilities exist due to its exposure to foreign exchange (FX) risk, foreign investors, and the potential for asset quality deterioration. The report outlines key financial sector challenges and provides recommendations for strengthening oversight, improving asset quality, and promoting long-term financial development.
Main Findings and Vulnerabilities
1. Macroeconomic Setting
- Economic Performance: Poland's economy performed well despite a challenging environment, with strong fundamentals and macroeconomic stability preventing recession through 2012.
- Financial System Growth: The financial system has expanded rapidly, with total assets reaching 124% of GDP by 2012.
- Bank Dominance: Banks account for about 70% of financial assets, while nonbank institutions, including pension and mutual funds, have grown to 30% of total assets.
2. Financial Vulnerabilities
- Foreign Exchange Loans: FX mortgages account for 22% of total loans and over half of all mortgages. Despite a decline in issuance, the proportion of impaired FX mortgages has increased slightly to 1.8% by end-2012.
- Loan-to-Value (LTV) Ratios: LTV ratios for some mortgages remain high, with 25% of FX housing loans having LTVs over 130%. The average LTV for new mortgages is about 70%, but some banks continue to offer 100% LTV.
- Capital Flows: Increased foreign investment in domestic bond markets has raised Poland's vulnerability to shifts in market sentiment. Nonresidents now hold 36% of sovereign bonds.
- Asset Quality: Nonperforming loans (NPLs) have increased significantly, particularly in the consumer loan sector, due to relaxed underwriting standards and increased competition. The overall provisioning coverage for NPLs is 54%, but it varies across sectors, with lower coverage in SMEs and housing.
3. Key Risk Drivers
- Slow Growth: Both domestic and foreign economic growth has slowed.
- Unemployment: Rising unemployment is a concern.
- Residential Real Estate Prices: Declining property prices affect mortgage portfolios and asset quality.
Financial Sector Oversight
1. Microprudential Supervision
- Supervisory Improvements: Banking supervision has improved with more frequent inspections and better coordination between onsite and offsite methods.
- Challenges: The supervisory framework lacks sufficient powers, independence, and resources, especially as its mandate expands.
- Credit Unions: SKOKs (credit unions) are a small but growing part of the system. They are poorly capitalized and have high NPLs, requiring stronger regulation and supervision.
2. Macroprudential Policies
- Macroprudential Oversight: A systemic risk board is being established as part of an explicit macroprudential policy framework.
- Policy Objectives: Clear macroprudential objectives should be defined to differentiate from monetary and microprudential policies.
- Regulatory Reforms: Strengthening the macroprudential supervisory law is necessary to ensure the independence and accountability of the Systemic Risk Board (SRB).
Crisis Management and Safety Nets
- Bank Resolution Framework: The deposit guarantee fund (BFG) is set to become the designated resolution agency, with a range of resolution tools available.
- Deposit Insurance: The BFG needs to ensure adequate funding, capacity, and resources. A new code of conduct should restrict employment in member institutions for all employees.
- Insolvency and Creditor Rights: The 2008 ICR ROSC found some improvements, but enforcement and out-of-court restructuring remain problematic.
Financial Development and Market Structure
- Pension System: A stable and well-diversified pension system is crucial for financial development and intergenerational fairness. Lifecycle strategies can encourage long-term investment in pension funds.
- Mortgage Market: The mortgage-backed securities (RMBS) market has not developed significantly, and initiatives to promote mortgage covered bonds (MCBs) and securitization are ongoing.
- Nonbank Financial Intermediation: Despite growth, nonbank financial intermediation remains underdeveloped, with potential for improvement through regulatory reforms.
Policy Recommendations
| Objective | Recommendation | Responsible Parties | Timeframe |
|---|---|---|---|
| Addressing Impaired Loans | Intensify oversight of credit risk management and restructuring practices. | KNF | Short Term (ST) |
| Addressing Impaired Loans | Standardize and enhance transparency of bank accounting practices. | MOF, KNF | Short Term (ST) |
| Addressing Impaired Loans | Standardize debt-to-income ratio calculation. | KNF | Short Term (ST) |
| Strengthening Banking Supervision | Amend the Banking Act to expand KNF's regulatory powers. | MOF, KNF | Medium Term (MT) |
| Strengthening Banking Supervision | Enhance KNF's budgetary and staff resources. | MOF, KNF | Medium Term (MT) |
| Strengthening Credit Unions | Amend the Credit Union Law to mandate a solvency ratio of 8% within 5 years. | MOF, KNF, NASCU | Short Term (ST) |
| Strengthening Credit Unions | Develop and implement an inclusive set of SKOK regulations. | MOF, KNF, NASCU | Medium Term (MT) |
| Strengthening Credit Unions | Develop capital rehabilitation plans for weak SKOKs. | KNF, NASCU | Short Term (ST) |
| Developing Sound Macroprudential Policies | Ensure the macroprudential supervisory law supports SRB's independence and accountability. | MOF, NBP, KNF, BFG | Short Term (ST) |
| Developing Sound Macroprudential Policies | Define clear macroprudential policy objectives. | MOF | Short Term (ST) |
| Improving Bank Resolution Framework | Ensure administrative powers take precedence over corporate insolvency procedures. | MOF, KNF, BFG | Short Term (ST) |
| Improving Bank Resolution Framework | Clarify creditor claims hierarchy to protect BFG's interests. | MOF, KNF, BFG | Short Term (ST) |
| Improving Bank Resolution Framework | Allow prudential adjustment of asset valuations. | MOF, KNF, BFG | Short Term (ST) |
| Improving Deposit Insurance System | Remove PBA from the BFG Council. | MOF, BFG | Short Term (ST) |
| Improving Deposit Insurance System | Ensure adequate funding and capacity for the BFG. | MOF, BFG, KNF | Medium Term (MT) |
| Strengthening Pension Reform | Manage risks from pension reforms announced in September 2013. | MOF, MOL | Short Term (ST) |
| Strengthening Pension Reform | Allow lifecycle strategies and measure performance against benchmark portfolios. | MOF, MOL, KNF | Short Term (ST) |
| Developing Long-Term Mortgage Funding | Tighten LTV requirements and restrict FX loans to clients with adequate FX income. | KNF | Short Term (ST) |
| Developing Long-Term Mortgage Funding | Allow universal banks to issue MCBs and adopt a legal framework for mortgage securitization. | MOF, KNF, MOJ | Medium Term (MT) |
| Strengthening Insolvency and Credit Rights | Strengthen enforcement of security interests and judicial decisions. | MOJ, Judiciary | Medium Term (MT) |
| Strengthening Insolvency and Credit Rights | Create an enabling legal framework for out-of-court restructuring. | MOF, MOJ, KNF | Short Term (ST) |
| Strengthening Insolvency and Credit Rights | Improve insolvency legislation to enhance creditor participation and judicial effectiveness. | MOJ | Short Term (ST) |
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