2015年-IMF国际货币组织全球_Slovenia_Technical_Assistance_Report_39页_778kb

Summary of the Technical Assistance Report on Slovenia: Bank Intervention and Resolution and the Deposit Guarantee System

Core Content

This report, prepared by the International Monetary Fund (IMF) Monetary and Capital Markets Department (MCM) in October 2015, provides technical assistance to Slovenia on strengthening its bank resolution framework and deposit guarantee scheme (DGS). It builds on the findings of a previous mission in December 2014, which assessed Slovenia’s financial system and recommended the creation of a Resolution Unit within the Bank of Slovenia (BOS) and the development of an ex ante funded DGS.

The report outlines a set of recommendations aimed at improving the efficiency and effectiveness of bank intervention and resolution, ensuring the DGS is robust and sustainable, and aligning Slovenia's financial regulations with EU directives and international best practices.

Main Views and Key Information

1. Effective Bank Resolution Requirements

Three key requirements for effective bank resolution are identified:

• Special Resolution Regime (SRR): Ensures that resolution decisions cannot be reversed by courts.
• Advance Preparation: Involves early monitoring and gathering of information to facilitate intervention and resolution.
• Adequately Funded DGS: Must be ex ante funded to ensure it can act quickly and effectively in case of bank failure.

Slovenia already has a legal basis for SRR and has created a Resolution Unit within BOS. However, the DGS remains ex post funded and needs to be reformed in line with the EU Deposit Guarantee Scheme Directive (DGSD).

2. Problem Bank Resolution Process

The report emphasizes the need for early intervention and preventive measures to avoid bank failure. It recommends:

• Establishing a Problem Bank Committee (PBC) to be convened when banks enter problem status (CAMELS 3, 4, or 5).
• Appointing a Temporary Administrator (TA) for banks in 4 and 5 CAMELS ratings, and for 3-rated banks showing no improvement.
• The TA should monitor insider and large transactions, ensure compliance with corrective measures, and gather data for resolution planning.

The report also highlights the importance of early corrective actions and Prompt Corrective Action (PCA) policies, which should be implemented to prevent capital erosion and license revocation before capital reaches zero.

3. Recommendations for Bank Resolution

• Create a Problem Bank Committee (PBC) within BOS with the Head of the Resolution Unit and senior DGS representatives.
• Appoint a Temporary Administrator (TA) to monitor and prepare for resolution.
• Implement a policy of early intervention based on PCA principles.
• Use Purchase and Assumption (P&A) as the preferred resolution tool for non-systemic banks.
• Develop an Intervention Action Plan and use checklists to ensure no steps are missed.
• Utilize a team approach for bank intervention and resolution, including staff from BOS and failed-bank employees.
• Ensure the IT system is capable of sorting and aggregating accounts, coding deposit types, and managing data during intervention.

4. Recommendations for the Deposit Guarantee Scheme (DGS)

• Enshrine the public policy objectives of the DGS in legislation or regulation.
• Grant the DGS a separate legal personality and ensure it has independent accounting and funding.
• Establish a target reserve fund based on clear, consistent, and transparent criteria, with a target greater than the 0.8% of insured deposits mandated by DGSD.
• Implement ex ante funding for the DGS and explore seed funding from the government.
• Introduce periodic risk-based assessments and the ability to temporarily raise premiums to replenish the fund.
• Develop a formal investment policy for the DGS reserve fund.
• Ensure that DGS outlays are limited to administrative costs and reimbursement of depositors.
• Conduct a public awareness program and be prepared to counsel depositors after bank failures.

Key Recommendations

Conclusion

The report outlines a comprehensive set of actions to improve Slovenia’s bank resolution framework and DGS. It stresses the importance of early preparation, efficient resolution tools, and ex ante funding for the DGS. These measures are designed to ensure financial stability, effective crisis management, and public confidence in the banking system. The recommendations are aligned with the EU Bank Recovery and Resolution Directive (BRRD), the DGSD, and the Core Principles for Effective Deposit Insurance Systems (DICPs). The implementation of these recommendations will provide a solid foundation for the second follow-up mission, which will focus on crisis preparedness and management.