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Jos Jos é é De Luna Mart De Luna Mart í í nez nez The World Bank The World Bank Supervision of Financial Conglomerates Supervision of Financial Conglomerates US Federal Reserve System/IMF/World Bank US Federal Reserve System/IMF/World Bank Seminar for Senior Bank Supervisors Seminar for Senior Bank Supervisors Washington, DC, October 2005 Washington, DC, October 2005

Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

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Page 1: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

JosJoséé De Luna MartDe Luna MartííneznezThe World Bank The World Bank

Supervision of Financial ConglomeratesSupervision of Financial Conglomerates

US Federal Reserve System/IMF/World Bank US Federal Reserve System/IMF/World Bank Seminar for Senior Bank Supervisors Seminar for Senior Bank Supervisors

Washington, DC, October 2005Washington, DC, October 2005

Page 2: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

ContentsContents1.1. What is a financial conglomerate?What is a financial conglomerate?

2.2. Why is supervision of financial conglomerates Why is supervision of financial conglomerates important?important?

3.3. International best practices on the supervision of International best practices on the supervision of financial conglomerates.financial conglomerates.

4.4. How to supervise financial conglomerates.How to supervise financial conglomerates.

5.5. Findings of the Financial Sector Assessment Program Findings of the Financial Sector Assessment Program (FSAP) in relation to consolidated supervision(FSAP) in relation to consolidated supervision

Page 3: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

Recent Developments Recent Developments in the Financial Sector Industryin the Financial Sector Industry

Insurancecompanies

Banks

Securities firms Financial

Conglomerates

Factors Fostering ConglomerationFactors Fostering ConglomerationSearch for efficiency (lower costs, reduced prices, improved

innovation in products and services)

Search for diversification of revenues and risk profiles

Search for market power

Page 4: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

500 Largest Financial Firms Worldwide500 Largest Financial Firms Worldwide

Conglomeration among the largest 500 firms worldwide has increased both in terms of number of firms and assets heldAbout 87 percent of conglomerates are led by banksThe trend in conglomeration is global (industrialized and emerging market countries).

Source: G. de Nicolo and M. Kwast (2002): Systemic Risk and Financial Consolidation: Are they Related? Washington, DC, IMF Staff Papers 02/55.

0%

20%

40%

60%

80%

100%

1995 2000

Conglomerates Non-Conglomerates

Conglomerates vs. Non-Conglomerates

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Mixed Groups, Financial Mixed Groups, Financial Conglomerates and Banking GroupsConglomerates and Banking Groups

CommercialCommercialfirmsfirms

Banking Banking InstitutionInstitution

IndustrialIndustrialfirmsfirms

Banking Banking InstitutionInstitution

Securities Securities CompanyCompany

InsuranceInsuranceFirmFirm

At least two typesAt least two typesof intermediariesof intermediaries

in the conglomeratein the conglomerate

MixedMixedGroupGroup

FinancialFinancialConglomerateConglomerate

Banking Banking InstitutionInstitution

Financial Financial SubsidiarySubsidiary

Financial Financial SubsidiarySubsidiary

BankingBankingGroupGroup

Page 6: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

Examples of Bank Led Examples of Bank Led Financial ConglomerateFinancial Conglomerate

Type A:Type A:Full IntegrationFull IntegrationUniversal BankUniversal Bank

Type B:Type B:Partial IntegrationPartial Integration

Type C:Type C:Partial IntegrationPartial Integration

Type D:Type D:Holding CompanyHolding Company

StructureStructure

BankBankSecurities,Securities,InsuranceInsuranceand otherand other

Bank Bank and and

SecuritiesSecuritiesBank Bank

HoldingHoldingCompany Company

Ban

kB

ank

Secu

ritie

sSe

curit

ies

Insu

ranc

eIn

sura

nce

Oth

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Secu

ritie

sSe

curit

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Insu

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sura

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Insu

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sura

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Page 7: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

2. Why is supervision of financial 2. Why is supervision of financial conglomerates important?conglomerates important?

Page 8: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

Potential Problems Potential Problems Posed by Financial ConglomeratePosed by Financial Conglomerate

Insurance company

BankSecurities

firm

Other

Financial Conglomerate

DoubleDouble--leveraging of capitalleveraging of capitalLoopholes and opportunities for Loopholes and opportunities for regulatory arbitrage due to:regulatory arbitrage due to:–– Inconsistencies in legislation Inconsistencies in legislation

across sectorsacross sectors–– Different prudential rules and Different prudential rules and

supervisory requirements across supervisory requirements across national jurisdictionsnational jurisdictions

Contagion from one subsidiary to Contagion from one subsidiary to the rest of the groupthe rest of the groupConflicts of interestsConflicts of interestsLarger systemic risksLarger systemic risks““Solo supervisionSolo supervision”” alone is no alone is no longer effectivelonger effective

Page 9: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

What is Financial Conglomerate What is Financial Conglomerate Supervision?Supervision?

““It is a comprehensive It is a comprehensive approach to banking approach to banking supervision which seeks supervision which seeks to evaluate the strength of to evaluate the strength of an entire group, taking into an entire group, taking into account all the risks which account all the risks which may affect a bank, may affect a bank, regardless of whether regardless of whether these risks are carried in these risks are carried in the books of the bank or the books of the bank or related entities.related entities.”” (Bank of (Bank of England, 1998). England, 1998).

Insurance company

Bank Securities firm

Other

FINANCIAL CONGLOMERATE

Supervision of financial Supervision of financial conglomerate is a conglomerate is a complement to, not a complement to, not a substitute for, solo substitute for, solo supervision.supervision.

Page 10: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

3. International organizations3. International organizations’’core principles for supervision core principles for supervision

of financial conglomeratesof financial conglomerates

Page 11: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

International Organizations Involved in International Organizations Involved in Supervision of Financial ConglomeratesSupervision of Financial Conglomerates

International Association of International Association of Insurance Supervisors (IAIS)Insurance Supervisors (IAIS)International Organization of International Organization of Securities Commission Securities Commission (IOSCO)(IOSCO)Basel Committee on Basel Committee on Banking SupervisionBanking Supervision

JointJointForumForum

Page 12: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

Mandate of Joint ForumMandate of Joint ForumConduct study of issues of common interest to Conduct study of issues of common interest to banks, insurance companies, and securities firms banks, insurance companies, and securities firms (internal controls, outsourcing, corporate (internal controls, outsourcing, corporate governance, etc.)governance, etc.)Undertake work on risk assessments and capital Undertake work on risk assessments and capital

(risk aggregation, operational risk, credit risk).(risk aggregation, operational risk, credit risk).Provide a forum for bank, insurance, and Provide a forum for bank, insurance, and securities supervisors to share information on securities supervisors to share information on various issues.various issues.Conduct study of financial conglomerate and Conduct study of financial conglomerate and develop guidance and principles and/or identify develop guidance and principles and/or identify best practices. best practices.

Page 13: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

Criteria to Assess Compliance with Best Criteria to Assess Compliance with Best Practices on Supervision of Bank Led Practices on Supervision of Bank Led

Financial ConglomerateFinancial ConglomerateBasel Core Principles for Effective Banking SupervisionBasel Core Principles for Effective Banking Supervision

Core Principles MethodologyCore Principles Methodology

Same Criteria for All CountriesSame Criteria for All Countries

Principle 20:Principle 20:““An essential An essential element of element of banking banking supervision is the supervision is the ability of the ability of the supervisors to supervisors to supervise the supervise the banking group on banking group on a consolidated a consolidated basis.basis.””

Principle 23Principle 23Requires home Requires home supervisor to practice supervisor to practice consolidated consolidated supervision.supervision.

Principle 24Principle 24Requires home Requires home supervisor to supervisor to contact and contact and exchange exchange information with information with other relevant other relevant supervisors.supervisors.

Principle 25:Principle 25:Requires host Requires host supervisor to apply supervisor to apply local standards to local standards to foreign banks, and foreign banks, and have power to share have power to share information.information.

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Assessing Consolidated SupervisionAssessing Consolidated SupervisionEssential Criteria (BCPEssential Criteria (BCP--20)20)

1. The supervisor is aware of the overall structure of banking 1. The supervisor is aware of the overall structure of banking organizations (i.e., the bank and its subsidiaries) or groups anorganizations (i.e., the bank and its subsidiaries) or groups and d has an understanding of the activities of all material parts of has an understanding of the activities of all material parts of these groups, including those that are supervised directly by these groups, including those that are supervised directly by other agencies.other agencies.

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2. The supervisor has a supervisory framework that evaluates the2. The supervisor has a supervisory framework that evaluates therisks that nonrisks that non--banking activities conducted by a bank or banking banking activities conducted by a bank or banking group may pose to the bank or banking group.group may pose to the bank or banking group.

Assessing Consolidated SupervisionAssessing Consolidated SupervisionEssential Criteria (BCPEssential Criteria (BCP--20)20)

CommercialCommercialBankingBanking

Life and Life and NonNon--life Insurancelife Insurance

Securities and Securities and derivatives tradingderivatives trading

OtherOther

Special purposeSpecial purposevehiclesvehicles

Asset managementAsset management

LeasingLeasing

PensionPensionFundsFunds

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3. The supervisor has the legal authority to review the overall 3. The supervisor has the legal authority to review the overall activities of a bank, whether the activities are conducted direcactivities of a bank, whether the activities are conducted directly tly (including those conducted at overseas offices), or indirectly, (including those conducted at overseas offices), or indirectly, through subsidiaries and affiliates of the bank.through subsidiaries and affiliates of the bank.

4. There are no impediments to the direct or indirect supervisio4. There are no impediments to the direct or indirect supervision of n of all affiliates and subsidiaries of a banking organization.all affiliates and subsidiaries of a banking organization.

Assessing Consolidated SupervisionAssessing Consolidated SupervisionEssential Criteria (BCPEssential Criteria (BCP--20)20)

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5. Laws or regulations establish, or the supervisor has the auth5. Laws or regulations establish, or the supervisor has the authority to ority to impose, prudential standards on a consolidated basis for the impose, prudential standards on a consolidated basis for the banking organization. The supervisor uses its authority to estabbanking organization. The supervisor uses its authority to establish lish prudential standards on a consolidated basis to cover such areasprudential standards on a consolidated basis to cover such areas as as capital adequacy, large exposures and lending limits.capital adequacy, large exposures and lending limits.

Assessing Consolidated SupervisionAssessing Consolidated SupervisionEssential Criteria (BCPEssential Criteria (BCP--20)20)

Page 18: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

6. The supervisor collects consolidated financial information fo6. The supervisor collects consolidated financial information for each r each banking organization.banking organization.

Assessing Consolidated SupervisionAssessing Consolidated SupervisionEssential Criteria (BCPEssential Criteria (BCP--20)20)

Page 19: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

7. The supervisor has arrangements with functional regulators of7. The supervisor has arrangements with functional regulators ofindividual business vehicles within the banking organization groindividual business vehicles within the banking organization group, up, if material, to receive information on the financial condition aif material, to receive information on the financial condition and nd adequacy of risk management and controls of such business adequacy of risk management and controls of such business vehicles.vehicles.

Insurance regulatorInsurance regulator

Other regulators (Other regulators (NBFIsNBFIs))

Banking regulatorBanking regulator

Securities regulatorSecurities regulator

Assessing Consolidated SupervisionAssessing Consolidated SupervisionEssential Criteria (BCPEssential Criteria (BCP--20)20)

Page 20: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

International Trends in Regulatory StructureInternational Trends in Regulatory Structure

0%

50%

100%

1999 2000 2002 2004

Multiple Supervisors (USA model)

Partially Unified Supervisors (Mexican, Canadian and South African Models)

Single Supervisor (UK and Singapore Models)

Page 21: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

Agency supervising 2 types of fin. Agency supervising 2 types of fin. interminterm..Single SupervisorSingle Supervisorfor all financial for all financial

systemsystembanks and banks and insurersinsurers

banks and banks and securities firmssecurities firms

securities firms securities firms and insurersand insurers

Multiple Supervisors Multiple Supervisors (at least (at least one for banks, one for one for banks, one for seciritiessecirities

firms and one for insurers)firms and one for insurers)

47.47.AlbaniaAlbania48.48.ArgentinaArgentina49.49.BahamasBahamas50.50.BarbadosBarbados51.51.BotswanaBotswana52.52.BrazilBrazil53.53.BulgariaBulgaria54.54.ChinaChina55.55.CroatiaCroatia56.56.CyprusCyprus57.57.Dominican Dominican Rep.Rep.58.58.EgyptEgypt59.59.FranceFrance60.60.GreeceGreece61.61.Hong KongHong Kong62.62.IndiaIndia63.63.IndonesiaIndonesia

1.1.AustriaAustria2.2.BahrainBahrain3.3.BermudaBermuda4.4.Cayman Cayman IslandsIslands5.5.DenmarkDenmark6.6.EstoniaEstonia7.7.GermanyGermany8.8.GibraltarGibraltar9.9.HungaryHungary10.10.IcelandIceland11.11.IrelandIreland12.12.JapanJapan

13.13.KazakhshtanKazakhshtan14.14.LatviaLatvia15.15.MaldivesMaldives16.16.MaltaMalta17.17.NicaraguaNicaragua18.18.NorwayNorway19.19.SingaporeSingapore20.20.South South KoreaKorea21.21.SwedenSweden22.22.UAEUAE23.23.UKUK24.24.UruguayUruguay

25.25.AustraliaAustralia26.26.BelgiumBelgium27.27.CanadaCanada28.28.ColombiaColombia29.29.EcuadorEcuador30.30. El SalvadorEl Salvador31.31. GuatemalaGuatemala32.32.MalaysiaMalaysia33.33.PeruPeru34.34.VenezuelaVenezuela

35.35.FinlandFinland36.36.LuxembourgLuxembourg37.37.MexicoMexico38.38.SwitzerlandSwitzerland

39.39.BoliviaBolivia40.40.BulgariaBulgaria41.41.ChileChile42.42.JamaicaJamaica43.43.MauritiusMauritius44.44.SlovakiaSlovakia45.45.South South

AfricaAfrica46.46.UkraineUkraine

64.64. IsraelIsrael65.65. ItalyItaly63.63. JordanJordan64.64. LithuaniaLithuania65.65. NetherlandsNetherlands66.66. New New

ZealandZealand67.67. PanamaPanama68.68. PhilippinesPhilippines69.69. PolandPoland70.70. PortugalPortugal71.71. RussiaRussia72.72. SloveniaSlovenia73.73. Sri LankaSri Lanka74.74. SpainSpain75.75. ThailandThailand76.76. TunisiaTunisia77.77. TurkeyTurkey78.78. USAUSA

Institutional Arrangements Institutional Arrangements for Financial Sector Supervision (as of 2003)for Financial Sector Supervision (as of 2003)

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8. The supervisor has the authority to limit or circumscribe the8. The supervisor has the authority to limit or circumscribe the range range of activities the consolidated banking group may conduct and theof activities the consolidated banking group may conduct and theoverseas locations in which activities can be conducted; the overseas locations in which activities can be conducted; the supervisor uses this authority to determine that the activities supervisor uses this authority to determine that the activities are are properly supervised and that the safety and soundness of the properly supervised and that the safety and soundness of the banking organization is not compromised.banking organization is not compromised.

Assessing Consolidated SupervisionAssessing Consolidated SupervisionEssential Criteria (BCPEssential Criteria (BCP--20)20)

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Criteria to Assess the Effectiveness Criteria to Assess the Effectiveness of Consolidated Supervisionof Consolidated Supervision

Additional criteriaAdditional criteriaFor those countries that allow corporate ownership of banking coFor those countries that allow corporate ownership of banking companies:mpanies:

1.1. The supervisor has the authority to review the activities of parThe supervisor has the authority to review the activities of parent ent companies and of companies affiliated with the parent companies,companies and of companies affiliated with the parent companies, and and utilizes the authority in practice to determine the safety and sutilizes the authority in practice to determine the safety and soundness of oundness of the bank;the bank;

2.2. The supervisor has the authority to take remedial actions, incluThe supervisor has the authority to take remedial actions, including ringding ring--fencing, regarding parent companies and nonfencing, regarding parent companies and non--bank affiliates concerning bank affiliates concerning matters that could impact the safety and soundness of the bank; matters that could impact the safety and soundness of the bank; andand

3.3. The supervisor has the authority to establish and enforce fit anThe supervisor has the authority to establish and enforce fit and proper d proper standards for owners and senior management of parent companies.standards for owners and senior management of parent companies.

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4. How to supervise financial 4. How to supervise financial conglomerates?conglomerates?

Page 25: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

Consolidated SupervisionConsolidated SupervisionKey ComponentsKey Components

1.1. Consolidation of AccountsConsolidation of Accounts2.2. Consolidated Regulation (Quantitative)Consolidated Regulation (Quantitative)

--Capital AdequacyCapital Adequacy--Limits to large exposuresLimits to large exposures--Connected exposuresConnected exposures--Market risksMarket risks

3.3. ConsolidatedConsolidated Supervision (Qualitative)Supervision (Qualitative)--Overall risk management system (e.g. internal controls)Overall risk management system (e.g. internal controls)--Changes in ownership structureChanges in ownership structure--RingRing--fencingfencing

Page 26: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

Scope of Consolidation of Banking Groups: Scope of Consolidation of Banking Groups: Which Companies Need to be Consolidated?Which Companies Need to be Consolidated?

ParentParent(bank or financial firm)(bank or financial firm)

Subs

idia

ry

Subs

idia

ry

Subs

idia

ry

Subs

idia

ry

Subs

idia

ry

CONSOLIDATIONCONSOLIDATION

Oth

erO

ther

NO NO -- CONSOLIDATIONCONSOLIDATION

Oth

erO

ther

Subsidiary is nota financial institution

Parent or subsidiary have a participation of less than 20% in the ownership

or capital of the firm

Oth

erO

ther

Oth

erO

ther

Oth

erO

ther

Oth

erO

ther

Page 27: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

The examination of financial institution is The examination of financial institution is conducted on a solo basis.conducted on a solo basis.Each supervisor discusses its findings with Each supervisor discusses its findings with its respective institution.its respective institution.A lead supervisor is appointed.A lead supervisor is appointed.The lead supervisor for financial The lead supervisor for financial conglomerates collects all relevant findings conglomerates collects all relevant findings from other supervisors. from other supervisors.

Supervision of Financial Conglomerates Supervision of Financial Conglomerates --ContinuedContinued

Page 28: Supervision of Financial Conglomerates - World Banksiteresources.worldbank.org/EXTFINANCIALSECTOR/Resources/...Contents 1. What is a financial conglomerate? 2. Why is supervision of

The lead supervisor reviews the minutes of The lead supervisor reviews the minutes of meetings of various institution and management meetings of various institution and management reports to identify potential issues.reports to identify potential issues.The lead supervisor meets with individual The lead supervisor meets with individual institutioninstitution’’s shareholders auditors to discuss their s shareholders auditors to discuss their audit results and audit results and ““management lettermanagement letter””..The lead supervisor summarizes the main findings The lead supervisor summarizes the main findings to the management and BOD of the top company.to the management and BOD of the top company.

Supervision of Financial Conglomerates Supervision of Financial Conglomerates --ContinuedContinued

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Supervision of Financial Conglomerates Supervision of Financial Conglomerates --ContinuedContinued

The lead supervisor coordinates with other The lead supervisor coordinates with other supervisors to ensure deficiencies are supervisors to ensure deficiencies are addressed.addressed.The lead supervisor communicates/shares The lead supervisor communicates/shares information with other supervisors as part of information with other supervisors as part of ongoing monitoring of financial ongoing monitoring of financial conglomerate. conglomerate.

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Analysis of Results Analysis of Results -- Supervision Supervision of Financial Conglomerate of Financial Conglomerate

At the completion of supervisory review, At the completion of supervisory review, the supervisor needs to ask the following the supervisor needs to ask the following questions:questions:–– Has the review identified any potential systemic Has the review identified any potential systemic

problems?problems?–– Has the review identified any emerging trend Has the review identified any emerging trend

and/or issues that will have an impact on the and/or issues that will have an impact on the financial conglomerate?financial conglomerate?

–– Are there any supervisory and/or regulatory Are there any supervisory and/or regulatory gaps that needs to be addressed? gaps that needs to be addressed?

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5. 5. What are the main findings What are the main findings of the of the FSAPsFSAPs in relation to in relation to consolidated supervision?consolidated supervision?

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Countries that Have Participated in the FSAP Countries that Have Participated in the FSAP (as of December 2004)(as of December 2004)

RegionRegion CountriesCountries No. of No. of CountriesCountries

AfricaAfrica Cameroon, Cote d Ivoire, Gabon, Ghana, Kenya, Mauritius, Cameroon, Cote d Ivoire, Gabon, Ghana, Kenya, Mauritius, Mozambique, Nigeria, Senegal, South Africa, Tanzania, Uganda, Mozambique, Nigeria, Senegal, South Africa, Tanzania, Uganda, Zambia Zambia

1313

AsiaAsia Bangladesh, Hong Kong, India, Japan, Korea, Philippines, PakistaBangladesh, Hong Kong, India, Japan, Korea, Philippines, Pakistan, n, Singapore, Sri Lanka, New Zealand, Singapore, Sri Lanka, New Zealand,

1010

EuropeEurope Armenia, Bulgaria, Croatia, Czech Rep., Estonia, Finland, FranceArmenia, Bulgaria, Croatia, Czech Rep., Estonia, Finland, France, , Georgia, Germany, Hungary, Iceland, Ireland, Kazakhstan, Kyrgyz Georgia, Germany, Hungary, Iceland, Ireland, Kazakhstan, Kyrgyz Republic, Latvia, Lithuania, Luxemburg, Macedonia, Malta, Republic, Latvia, Lithuania, Luxemburg, Macedonia, Malta, Moldova, Netherlands, Poland, Romania, Russia, Slovak Republic,Moldova, Netherlands, Poland, Romania, Russia, Slovak Republic,Slovenia, Sweden, Switzerland, Ukraine, United KingdomSlovenia, Sweden, Switzerland, Ukraine, United Kingdom

3030

AmericasAmericas Barbados, Brazil, Canada, Chile, Colombia, Costa Rica, DominicanBarbados, Brazil, Canada, Chile, Colombia, Costa Rica, DominicanRepublic, El Salvador, Guatemala, Honduras, Mexico, Nicaragua, Republic, El Salvador, Guatemala, Honduras, Mexico, Nicaragua, PeruPeru

1313

Middle Middle EastEast

Algeria, Egypt, Iran, Israel, Jordan, Kuwait, Lebanon, Morocco, Algeria, Egypt, Iran, Israel, Jordan, Kuwait, Lebanon, Morocco, Oman, Tunisia, UAE, Yemen, Oman, Tunisia, UAE, Yemen,

1212

Total: 78 countriesTotal: 78 countries

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Developing Country Compliance with Best Developing Country Compliance with Best Practices on Consolidated SupervisionPractices on Consolidated Supervision

(BCP 20)(BCP 20)

Largely Compliant17%

Materially non compliant

42%

Non-compliant20%

Not applicable14%

Compliant7%

Based on information from 60 developing countries that have partBased on information from 60 developing countries that have participated in the FSAP icipated in the FSAP program between 1999 and 2004program between 1999 and 2004

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Weaknesses Observed in Countries Classified Weaknesses Observed in Countries Classified as nonas non--Compliant or Materially nonCompliant or Materially non--CompliantCompliant

Weak legal basis for consolidated supervisionWeak legal basis for consolidated supervision–– Bank supervisor is not empowered to review the activity Bank supervisor is not empowered to review the activity

or financial reports of a bank affiliate, subsidiary or or financial reports of a bank affiliate, subsidiary or parent company in a holding company structure. parent company in a holding company structure.

–– Banking law does not require banks to submit Banking law does not require banks to submit consolidated information.consolidated information.

–– Bank supervisor has only partial authority to conduct Bank supervisor has only partial authority to conduct consolidated supervision (for instance, bank supervisor is consolidated supervision (for instance, bank supervisor is empowered to collect information on a consolidated empowered to collect information on a consolidated basis, but it can not impose prudential requirements on a basis, but it can not impose prudential requirements on a consolidated basis).consolidated basis).

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Inadequate framework and tools for assessing risks on a Inadequate framework and tools for assessing risks on a consolidated basisconsolidated basis–– There is no consolidated accountingThere is no consolidated accounting–– Bank supervisor has little understanding of the risks posed by Bank supervisor has little understanding of the risks posed by

nonnon--bank activities.bank activities.–– OffOff--site surveillance is limited to financial statement collection site surveillance is limited to financial statement collection

and checking.and checking.–– OnOn--site inspections focus on compliance with laws and site inspections focus on compliance with laws and

regulations.regulations.–– Inadequate frequency of offInadequate frequency of off--site monitoring of banking groups.site monitoring of banking groups.–– Lack of secondary regulation specifying rules for consolidation,Lack of secondary regulation specifying rules for consolidation,

as well as key prudential requirements for financial groups.as well as key prudential requirements for financial groups.

Weaknesses Observed in Countries Classified Weaknesses Observed in Countries Classified as nonas non--Compliant or Materially nonCompliant or Materially non--CompliantCompliant

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Weak institutional arrangements among Weak institutional arrangements among supervisorssupervisors

–– There are no formal arrangements allowing cooperation There are no formal arrangements allowing cooperation and informationand information--sharing among domestic supervisors sharing among domestic supervisors (bank, securities and insurance).(bank, securities and insurance).

–– There are only adThere are only ad--hoc arrangements between bank hoc arrangements between bank supervisor and its foreign counterparts (lack of supervisor and its foreign counterparts (lack of MoUsMoUs). ).

Weaknesses Observed in Countries Classified Weaknesses Observed in Countries Classified as nonas non--Compliant or Materially nonCompliant or Materially non--CompliantCompliant

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OtherOther–– Ownership issues.Ownership issues. Lack of transparency in the Lack of transparency in the

ownership structure of a bank (supervisor is not ownership structure of a bank (supervisor is not required to approve changes in right of control of a required to approve changes in right of control of a bank, as stated in BCP 4).bank, as stated in BCP 4).

–– RingRing--fencingfencing. No authority to limit or circumscribe the . No authority to limit or circumscribe the range of activities the banking group may conduct and range of activities the banking group may conduct and the overseas location in which activities can be the overseas location in which activities can be conducted.conducted.

–– No authority over a bankNo authority over a bank’’s parent companys parent company. The . The SupervisorSupervisor’’ authority extends over a bankauthority extends over a bank’’s s subsidiaries, but not over a banksubsidiaries, but not over a bank’’s parent company or s parent company or any affiliates of the parent). any affiliates of the parent).

Weaknesses Observed in Countries Classified Weaknesses Observed in Countries Classified as nonas non--Compliant or Materially nonCompliant or Materially non--CompliantCompliant

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Financial conglomerates have increased rapidly in Financial conglomerates have increased rapidly in recent years.recent years.Adequate supervision of conglomerates is Adequate supervision of conglomerates is important for systemic stability, given their size important for systemic stability, given their size and scope of operations across the financial and scope of operations across the financial system.system.Consolidated supervision is a complement, not a Consolidated supervision is a complement, not a substitute, of solo supervision.substitute, of solo supervision.Consolidated supervision involves a set Consolidated supervision involves a set quantitative and qualitative parameters.quantitative and qualitative parameters.Coordination and information sharing among Coordination and information sharing among financial sector supervisors is crucial. financial sector supervisors is crucial.

Supervision of Financial ConglomeratesSupervision of Financial ConglomeratesSummarySummary

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JosJoséé De Luna MartDe Luna MartííneznezThe World Bank The World Bank

Supervision of Financial ConglomeratesSupervision of Financial Conglomerates

US Federal Reserve System/IMF/World Bank US Federal Reserve System/IMF/World Bank Seminar for Senior Bank Supervisors Seminar for Senior Bank Supervisors

Washington, DC, October 2005Washington, DC, October 2005