2012年-IMF国际货币组织全球_Turkey_Financial_System_Stability_Assessment_50页_1mb
报告摘要
Summary of Turkey: Financial System Stability Assessment
Core Content
This document is a Financial System Stability Assessment (FSAS) report on Turkey, prepared by the IMF staff team in November 2011. It outlines the findings of a joint IMF-World Bank mission conducted in March to April 2011, which assessed the stability of Turkey’s financial system and provided recommendations for improvement.
Main Findings
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Macro-financial Risks: Despite weathering the 2008-09 global financial crisis well due to strong capital buffers, effective fiscal and monetary management, and conservative banking practices, Turkey has faced new macro-financial risks. These are driven by wide current account deficits and rapid credit growth, which have increased systemic vulnerabilities.
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Banking System Resilience: Stress tests based on end-2010 data suggest that the banking system has sufficient capital buffers to withstand a deep but brief shock, but protracted shocks or further credit growth could lead to capital and liquidity strains.
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Macroprudential Policy: Turkey has made progress in establishing a macroprudential policy framework, which is designed to monitor and mitigate systemic risks. A Financial Stability Committee (FSC) was formed in mid-2011. However, the report recommends clearer separation of macroprudential policy and crisis management functions, with the CBRT playing a leading role in systemic risk monitoring.
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Banking and Insurance Regulation: While banking supervision and regulation have been strengthened since the 2007 FSAP, material gaps remain in implementation, especially in consolidated supervision, risk management, and liquidity oversight. Similarly, insurance regulation has improved, but the supervisory framework still lacks transparency, consultative processes, and accountability.
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AML/CFT Framework: Turkey has made progress in its Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) legal and regulatory framework, but significant shortcomings remain. The FATF included Turkey on a list of countries not making sufficient progress in strategic AML/CFT deficiencies in June 2011. The report calls for a new law to adequately criminalize terrorism, strengthened institutional supervision, and alignment with FATF standards.
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Financial System Structure: Banks continue to dominate the financial system, with their assets accounting for over 90% of GDP by August 2011. Public banks still play a major role, with the state-owned banks holding close to a third of total banking sector assets. Non-bank financial institutions have grown, but banking remains central.
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Credit Growth and Risk Profile: Loan growth has been very rapid, especially in the consumer and SME segments, which are more profitable but riskier. Corporate foreign exchange (FX) exposure is at a record high, and banks are increasingly reliant on short-term foreign funding, increasing liquidity risk.
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NPLs and Loan Performance: While NPLs increased during the crisis, particularly in SME and consumer loans, they have substantially improved post-crisis. The system average NPL ratio fell to 2.8%, an historical low, but shortcomings in asset classification and provisioning may result in higher actual NPLs.
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Crisis Management Framework: Turkey has a well-designed banking resolution and deposit insurance framework, including tools like mergers, deposit transfers, and bank liquidation. The Savings Deposit Insurance Fund (SDIF) is in line with EU and international standards. However, the CBRT's FX liquidity provision is limited due to insufficient official reserves.
Key Recommendations
| Recommendation | Priority | Timing |
|---|---|---|
| Overall financial sector oversight | High | Near term |
| - Consider further prudential action to ensure strong capital positions and stability of funding. <br> - Ensure data are available to assess the risk from unhedged corporate net short FX positions and take corrective action as necessary. <br> - Consider further measures to address the risk of worsening lending standards in the consumer and SME segments. <br> - Develop an approach to risk identification that combines the monitoring of key indicators with qualitative information. Better leverage the expert resources of the BRSA and CBRT by jointly developing databases and modeling frameworks for financial stability analysis. | - | - |
| Macro-prudential policy framework | Medium | Medium term |
| - Ensure appropriate communication and accountability of the FSC and strengthen its mandate and powers through primary legislation. <br> - Consider separating macroprudential policy and crisis management arrangements and ensuring a leading role of the CBRT in systemic risk monitoring and prevention. | - | - |
| Micro-prudential regulation and supervision (Banking) | High | Near term |
| - Review and revise key aspects of the supervisory and regulatory framework to bring it fully into line with the Basel Core Principles (BCP), especially as regards the supervision of key risks and the definition of capital. <br> - Implement consolidated banking supervision and enhance the coverage of risks emanating from non-banking entities in the group. <br> - Revise the Banking Law to enhance the operational and organizational autonomy of the Banking Regulation and Supervision Agency (BRSA) for banking supervision. | - | - |
| Micro-prudential regulation and supervision (Insurance) | High | Medium term |
| - Reform the current insurance regulation and supervision processes by making them more transparent, consultative, and accountable to the industry. <br> - Improve the "early warning" system for the required solvency margin. <br> - Transfer the responsibilities for insurance regulation and supervision to an independent integrated insurance supervisory body. | - | - |
| AML/CFT regime | High | Near term |
| - Adopt a new Law on Combating the Financing of Terrorism (CFT) to address the deficiencies identified by the FATF. <br> - Strengthen and integrate the institutional supervisory framework for AML/CFT to include participation of sector supervisors within the monitoring, selection, planning, and coordination of AML/CFT activities. <br> - Establish a definition for Politically Exposed Persons (PEP) and requirements for reporting entities in line with FATF standards. | - | - |
Conclusion
The report highlights that while Turkey has made significant progress in financial sector regulation and stability since the 2000-01 crisis, new macro-financial risks have emerged. These risks are primarily driven by rapid credit growth, increased reliance on short-term foreign funding, and high corporate FX exposure. The report emphasizes the need for improved macroprudential oversight, better implementation of regulatory frameworks, and enhanced AML/CFT measures to ensure long-term financial stability.
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