2017年-世界发展银行全球_Bulgaria_Financial_Sector_Assessment_35页_400kb
报告摘要
Bulgaria Financial Sector Assessment Summary (May 2017)
Core Content
This report presents the findings of the Financial Sector Assessment Program (FSAP) conducted by an IMF and World Bank team in Bulgaria in 2016 and 2017. It evaluates the financial system's stability, oversight, and resilience, and provides key recommendations for improving the sector's governance and risk management.
Main Recommendations
| Category | Recommendation | Timeframe |
|---|---|---|
| Financial Sector Oversight and Regulation | Ensure adequate staffing and resources for all financial oversight authorities. | NT |
| Financial Sector Oversight and Regulation | Strengthen the legal and operational framework for legal protection of financial oversight staff. | NT |
| Banking Sector Supervision and Regulation | Adopt a multi-year Action Plan to strengthen the Bank Supervision Department (BSD). | NT |
| Banking Sector Supervision and Regulation | Implement a comprehensive supervisory strategy for target banks under the AQR. | I |
| Banking Sector Supervision and Regulation | Introduce regulation on related parties to prevent circumvention. | I |
| Banking Sector Supervision and Regulation | Enforce remedies to concentration and related party risks based on 2017 inspections. | NT |
| Banking Sector Corporate Governance | Enhance the role of the Supervisory Board (SB) by stricter definition of independent members. | NT |
| Banking Sector Corporate Governance | Elevate the audit committee function to the SB level. | NT |
| Banking Sector Corporate Governance | Review the process of approval of related-party exposures. | I |
| Banking Sector Corporate Governance | Review the appointment process of the head of internal audit to ensure SB oversight. | NT |
| Banking Sector Corporate Governance | Develop new operational manuals to improve supervision of corporate governance. | I |
| Insurance and Pensions Supervision and Regulation | Amend the Financial Supervision Commission (FSC) Act to improve independence and transparency. | NT |
| Insurance and Pensions Supervision and Regulation | Expand and equip the insurance supervision team for Solvency II implementation. | I |
| Insurance and Pensions Supervision and Regulation | Review FSC's methodology for both offsite and onsite reviews to improve efficiency and risk focus. | I |
| Insurance and Pensions Supervision and Regulation | Conduct thematic onsite reviews of general insurers and insurance intermediaries. | I |
| Nonperforming Loans Oversight and Strategy | Implement a comprehensive NPL reduction strategy with supervisory tools. | I |
| Nonperforming Loans Oversight and Strategy | Enforce robust provisioning under IAS 39 and IFRS 9. | I |
| Nonperforming Loans Oversight and Strategy | Oblige write-offs of NPLs where collection is unlikely. | I |
| Nonperforming Loans Oversight and Strategy | Issue supervisory guidance for early warning systems (EWS) and collateral valuation. | I |
| Nonperforming Loans Oversight and Strategy | Enhance supervisory reporting and disclosure. | I |
| Nonperforming Loans Oversight and Strategy | Improve NPL market and remove impediments through collaboration with other authorities. | NT |
| Financial Safety Net and Crisis Management | Prioritize recovery and resolution plans (RRP) for capital-shortfall banks and D-SIBs. | I |
| Financial Safety Net and Crisis Management | Ensure a smooth transition from early intervention to resolution. | NT |
| Financial Safety Net and Crisis Management | Define joint BNB-MoF strategies for liquidity assistance. | I |
| Financial Safety Net and Crisis Management | Strengthen the crisis management framework under the FSAC. | NT |
Key Findings
1. Macroeconomic Developments
- Bulgaria has shown resilience to recent financial shocks, including the 2014 collapse of a large bank.
- GDP growth reached 3.4% in 2016, with a significant current account surplus.
- Public debt remains among the lowest in Europe, although nonfinancial corporate debt is high.
- The Currency Board Arrangement (CBA) has contributed to macroeconomic stability.
2. Financial System Structure
- The financial system is dominated by banks, with foreign banks holding 74% of total bank assets.
- There are 27 banks in total, including 13 subsidiaries and 5 branches of foreign banks.
- The top five banks account for 59% of total bank assets.
- The banking sector has strong capital and liquidity buffers, with Tier 1 and total capital adequacy ratios at 21.2% and 22.7% respectively as of June 2016.
- NPL levels remain high, with 19.7% under BNB's measure and 13.7% under EBA's measure.
3. Nonbank Financial Institutions (NBFI)
- The NBFI sector is relatively small, with the insurance industry dominated by foreign subsidiaries.
- Pension system is a traditional three-pillar model, with Pillar I being the largest contributor to the system.
- The government contributes about 50% of pension payments, raising concerns about long-term sustainability.
- The FSC conducted a balance sheet review and stress test for the insurance and pension sectors, identifying minor adjustments and capital deficiencies in some insurers.
4. Stability Risks and Resilience
- The banking system is resilient overall, with strong capital and liquidity buffers.
- Key vulnerabilities include high NPLs, concentrated exposures, and high corporate indebtedness.
- A protracted European slowdown, loss of investor confidence, geopolitical tensions, and NPL price uncertainty are potential risks.
- Stress tests show that while the system remains strong, some banks may fall below regulatory capital thresholds.
5. Banking Sector Oversight
- The BNB has made progress in implementing the 2015 BCP recommendations.
- A new governance model for the BSD has been introduced, enhancing supervision effectiveness.
- The BNB needs to improve accountability and formalize processes for risk assessment and escalation.
- The BSD is being restructured, with a new Offsite Directorate and increased inspection teams.
6. Corporate Governance
- The role of the SB should be enhanced, including stricter independence criteria and stronger internal audit oversight.
- Related-party exposure processes need to be reviewed and monitored more closely.
- New operational manuals are being developed to improve corporate governance supervision.
7. Insurance and Pensions
- The FSC needs to be reformed for greater independence and effectiveness.
- The insurance sector faces capital shortfalls, with 13 insurers identified as undercapitalized in 2016.
- The pension system's sustainability should be independently reviewed due to demographic changes.
8. Nonperforming Loans (NPLs)
- NPL levels are high, and a targeted strategy is needed to reduce them.
- The BNB should extend its macroprudential mandate to improve provisioning, write-offs, and collateral valuation practices.
- Collaboration with other authorities and the private sector is essential for improving the NPL market.
9. Financial Safety Net and Crisis Management
- The financial safety net is based on sound foundations but requires further development.
- Early intervention and resolution frameworks need to be strengthened.
- A joint BNB-MoF strategy for liquidity assistance should be formalized.
Conclusion
Bulgaria's financial system has stabilized following the 2014 bank collapse, but challenges remain in terms of NPLs, corporate governance, and supervision effectiveness. The authorities should focus on strengthening the banking sector through targeted reforms, improving the supervision of NBFI, and enhancing the financial safety net. The implementation of the recommendations will require coordination between the BNB, MoF, and other relevant bodies, as well as continued capacity building and training.
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