EXECUTIVE SUMMARY
The global financial system remains under severe stress as the crisis broadens to include households,corporations, and the banking sectors in both advanced and emerging market countries. Shrinking economicactivity has put further pressure on banks’ balance sheets as asset values continue to degrade, threatening their capital adequacy and further discouraging fresh lending. Thus,credit growth is slowing, and even turning negative, adding even more downward pressure on economic activity. Substantial private sector adjustment and public support packages are already being implemented and are contributing to some early signs of stabilization. Even so, further decisive and effective policy actions and international coordination are needed to sustain this improvement, to restore public confidence in financial institutions, and to normalize conditions in markets. The key challenge is to break the downward spiral between the financial system and the global economy. Promising efforts are already under way for the redesign of the global financial system that should provide a more stable and resilient platform for sustained economic growth.
To mend the financial sector, policies are needed to remove strains in funding markets forbanks and corporates, repair bank balance sheets, restore cross-border capital flows (particularly to emerging market countries); and limit the unintended side effects of the policies being implementedto combat the crisis. All these objectives will require strong political commitment under difficult circumstances and further enhancement of international cooperation. Such international commitment and determination to address the challenges posed by the crisis are growing, as displayed by the outcome of the G-20 summit in early April.
A wide range of nonbank financial institutions has come under strain during the crisis as asset prices have fallen. Pension funds have been hit hard—their assets have rapidly declined in value while the lower government bond yields that many use to discount their liabilities have simultaneously expanded their degree of underfunding. Life insurance companies have suffered losses on equity and corporate bond holdings, in some cases significantly depleting their regulatory capital surpluses. While perhaps most of these institutions managed their risks prudently, some took on more risk without fully appreciating that potential stressful episodes may lie ahead.
The retrenchment from foreign markets is now outpacing the overall deleveraging process,with a sharp decline of cross-border funding intensifying the crisis in several emerging market countries. Indeed, the withdrawal of foreign investors and banks together with the collapse in
export markets create funding pressures in emerging market economies that require urgent attention. Therefinancing needs of emerging markets are large, estimated at some $1.6 trillion in 2009, with the bulk coming from corporates, including financial institutions. Though notoriously difficult to forecast,current estimates are that net private capital flows to emerging markets will be negative in 2009, and that inflows are not likely to return to their pre-crisis levels in the future. Already, emerging market economies that have relied on such flows are weakening, increasing the importance of compensatory official support.
Despite unprecedented official initiatives to stop the downward spiral in advanced economies—including massive amounts of fiscal support and an array of liquidity facilities—furtherdetermined policy action will be required to help restore confidence and to relieve the financial markets of the uncertainties that are undermining the prospects for an economic recovery. However,the transfer of financial risks from the private to the public sector poses challenges. There are continuing concerns about unintended distortions and whether the short-term stimulus costs, including open-ended bank support packages, will combine with longer-term pressures from aging populations to put strong upward pressure on government debt burdens in some advanced economies. Home bias is also setting in as officials are encouraging banks to lend locally and consumers to keep their spending domestically oriented.
These risks, discussed in Chapter 1, represent some of the most difficult issues that the public sector has faced in half a century. We outline below what we believe are the key elements to break the downward spiral between the financial sector and the real economy. Immediate Policy Recommendations
Even if policy actions are taken expeditiously and implemented as intended, the deleveraging process will be slow and painful, with the economic recovery likely to be protracted. The accompanying deleveraging and economic contraction are estimated to cause credit growth in the United States, United Kingdom, and euro area to contract and even turn negative in the near term and only recover after a number of years.
This difficult outlook argues for assertive implementation of already-established policies and more decisive action on the policy front where needed. The political support for such action,however, is waning as the public is becoming disillusioned by what it perceives as abuses of taxpayer funds in some headline cases. There is a real risk that governments will be reluctant to allocate enough resources to solve the problem. Moreover, uncertainty about political reactions may undermine the likelihood that the private sector will constructively engage in finding orderly solutions to financial stress. Hence, an important component to restoring confidence will be clarity,consistency, and the reliability of policy responses. Past episodes of financial crisis have
shown that restoring the banking system to normal operation takes several years, and that recessions tend to be deeper and longer lasting when associated with a financial crisis (see Chapter 3 of the April 2009World Economic Outlook). This same experience shows that when policies are unclear and not implemented forcefully and promptly, or are not aimed at the underlying problem, the recovery process is even more delayed and the costs, both in terms of taxpayer money and economic activity,are even greater.
Given the global reach of this crisis, the effect of national policies can be strengthened if implemented in a coordinated fashion among affected countries. Coordination and collaboration should build upon the positive momentum created by the recent G-20 summit, and is particularly important with respect to financial policies to avoid adverse international spillovers from national actions. Specifically, cross-border coordination that results in a more consistent approach to address banking system problems, including dealing with bad assets, is more likely to build confidence and avoid regulatory arbitrage and competitive distortions.
In the short run, the three priorities identified in previous GFSRs and explicitly recognized in the February 2009 G-7 Communiqué remain appropriate: (i) ensure that the banking system has access to liquidity; (ii) identify and deal with impaired assets; and (iii) recapitalize weak but viable institutions and promptly resolve nonviable banks. In general, the first task is for central banks, while the latter two are the responsibility of supervisors and governments. Progress has been made in the first area, but policy initiatives in the other two areas appear to be more piecemeal and reactive to circumstances. Recent announcements by authorities in various countries recognize the need to deal with problem assets and to assess banks’ resilience to the further deteriorating global economy in order to determine recapitalization needs. These are welcome steps and as details become available will likely help reduce uncertainty and public skepticism. Lessons from past crises suggest the need for more forceful and effective measures by the authorities to address and resolve weaknesses in the financial sector.
Assure that emerging market economies have adequate protection against the deleveraging and risk aversion of advanced economy investors.
The problems of the advanced country banking sectors and the global contraction are now having severe effects on emerging market countries. We project annual cross-border portfolio outflows of around 1 percent of emerging market GDP over the next few years. Under reasonable scenarios, private capital flows to emerging markets could see net outflows in 2009, with slimchances of a recovery in 2010 and 2011.
As in advanced economies, emerging market central banks will need to assure adequate liquidity in their banking systems. However, in many cases the domestic interbank market is not a
major source of funding, as much bank funding has been sourced externally in recent years. Thus,central banks may well need to provide foreign currency though swaps or outright sales. Those central banks with large foreign exchange reserves can draw on this buffer, but other means, such as swap lines with advanced country central banks or the use of IMF facilities, should also be a line of defense. The greater resources available to the IMF following the G-20 summit can help countries buffer the impact of the financial crisis on real activity and, particularly in the developing countries, limit the effect on the poor. Moreover, IMF programs can play a useful role in catalyzing support from others in some cases.
Coordinate policies across countries to avoid beggar-thy-neighbor treatment.
*Pressure to support domestic lending may lead to financial protectionism.When countries act unilaterally to support their own financial systems, there may be adverse consequences for other countries. In a number of countries, authorities have stated that banks receiving support should maintain (or preferably expand) their domestic lending. This could crowd out foreign lending as banks face ongoing pressure to delever their overall balance sheets, sell foreign operations, and seek to remove their riskier assets, with damaging consequences for emerging market countries and hence for the wider global economy. At the same time, recent agreements among the parents of banks in some countries to continue to supply their subsidiaries in host countries with credit are heartening.
Macroeconomic Policy Consistency and Reinforcement
In order to provide a foundation for a sustainable economic recovery, it is critical to stabilize the global financial system. As also noted in the April 2009 World Economic Outlook, policies aimed at the financial sector will also be more effective if they are reinforced by appropriate fiscal and monetary policies.
Promote fiscal and financial policies that reinforce each other.
Restoring credit growth is necessary to sustain economic activity. Fiscal stimulus to support economic activity and limit the degradation of asset values should improve the creditworthiness of borrowers and the collateral underpinning loans, and combined with the financial policies to bolster banks’ balance sheets would enable sound credit extension. Also, seed funds for private-public partnerships for infrastructure projects could raise demand for loans.
For those countries where there is fiscal room to maneuver, fiscal stimulus will be looked at positively by markets, potentially helping to restore overall confidence. However, for governments already suffering large deficits or poor policymaking institutions, the markets may be less
welcoming.Already, market concern at the potential fiscal cost of public support of the banking systems is evident in countries where explicit or implicit support has been provided, especially where the financial system is large compared to the economic size of the country. Although there has been some improvement recently, higher government bond yields, widening credit default swap spreads,or weakening currencies are all manifestations of this concern. Authorities should reduce their refinancing risks by lengthening their government debt maturity structure, to the extent that investor demand allows.
It is clear that stimulative policies are needed now, but careful attention must be paid to the degree of fiscal sustainability and implications for the government’s funding needs in any stimulus *package, particularly given the contingent risks to the government’s balance sheet.1 Where stimulus packages suggest fiscal targets may be missed, packages need to be accompanied by credible medium-term fiscal frameworks for lowering deficits and debt levels.2 Without such policies, governments may risk a loss in confidence in the governments’ solvency. Setting the Stage for a More Robust Global Financial System
The immediate priority of policymakers is to address the current crisis. At the same time,work is continuing to develop a more robust financial system for the longer term. In addition to providing for a more resilient and efficient financial system after the crisis clears, a clear sense of direction about longer-term financial policies can also contribute to removing uncertainties and improving market confidence in the short term. While many of the proposals below may appear conceptual, their implications are real. Their proper implementation will require significant changes in structures and resources, while international consistency will be essential.3
There is little doubt that the crisis will require far-reaching changes in the shape and functioning of financial markets, and that the financial system will be characterized by lower levels of leverage, reduced funding mismatches, less counterparty risk, and more transparent and simpler financial instruments than the pre-crisis period. The private sector has a central responsibility to contribute to this new environment by improving risk management, including through attention to governance and remuneration policies.
Since neither market discipline nor public oversight were sufficient to properly assess and contain the buildup of systemic risks, improved financial regulation and supervision are key components to preventing future crises. The emphasis should be on how to detect and mitigate systemic risks through better regulation.
While attempts to eliminate all systemic risk would not only be impossible, but also would slow economic growth and constrain creativity and innovation, the current crisis demonstrates that
greater emphasis should be placed on systemically focused surveillance and regulation. At the same time, a better macroprudential framework for monetary policy would also help to mitigate systemic risks. While we should strive for regulation that provides incentives for private institutions, wherever possible, to take actions that reinforce financial stability, we should recognize that system-wide stability is a public good that will be undervalued by private institutions and regulations will need to force systemically important firms to better internalize the overall societal costs of instability. For this to occur, the mandates of central banks, regulators, and supervisors should include financial stability.A clear framework to assess and act upon systemic risks will need to be in place, with a clear delineation of who is the lead systemic regulator. To be able to mitigate systemic risks, those risks will need to be better defined and measured. Chapters 2 and 3 both shed light on various metrics to help identify systemically important institutions by observing both direct and indirect linkages. In some cases, the measures could be viewed as a starting point for the consideration of an additional capital surcharge that could be designed as a deterrent to firms becoming “too-connected-to-fail.” Even if not formally used, the proposed measures could guide policymakers to limit the size of various risk exposures across institutions. Clearly, such methods would require very careful consideration and application in order to avoid outcomes whereby institutions find other means of taking profitable exposures. More discussion and research is needed before regulations based on this work could be put into place.
As regards regulatory reforms, we see five priority areas: extending the perimeter of regulation to cover all systemically important institutions and activities, preventing excessive leverage and reducing procyclicality, addressing market discipline and information gaps, improving cross-border and cross-functional regulation, and strengthening systemic liquidity management. The main lessons can be summarized as follows.
Define systemically important institutions and the perimeter of prudential regulation.
As recognized by the recent G-20 Communiqué, this crisis has demonstrated that regulation needs to encompass all systemically important institutions. Traditionally, only a core set of large banks has been regarded as systemically relevant, but the crisis has shown that other nonbank financial intermediaries can be systemically important and their failure can cause destabilizing effects.Not only does an institution’s size matter for its systemic importance—its interconnectedness and the vulnerability of its business models to excess leverage or a risky funding structure matter as well.
In order to better capture systemic risks, regulation needs to be expanded to a wider range of institutions and markets. While certainly not all financial institutions need to be regulated,
prudential supervision will need to cover some institutions that had previously been viewed as outside the core institutions (e.g., investment banks). Moreover, certain activities (such as credit derivatives and insurance) will need to be overseen by regulators regardless of the type of legal structure in which they are placed.
A two-tiered approach may work best. A wider tier would be required to provide information from which supervisors would determine which institutions are systemically important.The other tier would be a narrower—though wider than at present—perimeter of more intensified prudential regulation and oversight that would include all systemically important institutions. While these institutions would receive more intense scrutiny given their systemic importance, other institutions would continue to be overseen as participants in the payments or banking system or for consumer or investor protection purposes. Chapters 2 and 3 provide methodologies that could be used to discern how close institutions are to each other and thus the contours of an inner tier. These methods will be further explored as the IMF works toward a practical definition of a systemically important institution as requested by the G-20. Prevent excessive leverage and curb procyclicality.
New regulatory approaches are needed to avoid the buildup of systemic risk and the subsequent and difficult deleveraging process. Finding solutions for how to limit leverage going forward and reduce the procyclical tendencies inherent in business practices and existing regulation remains challenging. Regulation should attempt to reinforce financial institutions’ sound risk-based decision-making, whereas deterring risk-taking in the global economy would be unhelpful. Regulation should provide incentives that support systemic stability, while discouraging regulatory arbitrage and short-termism, but the higher standards should be phased in gradually over time so that they do not exacerbate the present situation.
Capital regulation and accounting standards should include incentives and guidance that permit the accumulation of additional capital buffers during upswings when risks tend to accumulate and are typically underestimated. This would better reflect the risks through the cycle and thus add to capital and provisions that could be used to absorb losses during the downswings. Ideally, these countercyclical capital requirements would not be discretionary, but act as automatic stabilizers and be built into regulations. This would not limit the capacity of supervisors to act with supplementary measures if needed. An upper limit on leverage based on a simple measure could be useful as a supplementary restriction to more robust risk-weighted capital calculations. Accounting rules and valuation practices should be strengthened to reflect a broader range of available information on the evolution of risks through the cycle. Accounting standard setters and prudential authorities should collaborate to achieve these objectives, with particular emphasis on
enabling higher loan loss provisions during periods of rapid credit expansion, evaluating approaches to valuation reserves or adjustments when valuation of assets on the trading book are highly uncertain, and examining other ways to dampen adverse dynamics potentially associated with fairvalue accounting.
It is also necessary to reduce the procyclicality of liquidity risk by taking measures to improve liquidity buffers and funding risk management. During upswings, greater attention needs to be given to funding maturity structures and the reliability of funding sources that can prove vulnerable during downturns.
Strengthen cross-border and cross-functional regulation.
Enhanced cross-border and cross-functional regulation will require improvements in institutional and legal settings. Progress is needed in reducing unnecessary differences, tackling impediments to supervision of globally and regionally important firms, with more harmonized early remedial action, bank resolution legal frameworks, and supervisory practices to oversee cross-border firms. An appointment of a lead regulator, in principle the home authority, by the college of regulators overseeing a firm would be essential to ensure adequate oversight. Home countries should endeavor to strengthen cooperation with host countries so as to assure lines of communication are open when rapid responses are required—contingency planning should involve all relevant parties.
Improve systemic liquidity management.
In terms of systemic liquidity management, central banks can learn some lessons from the crisis in terms of the flexibility of their operational frameworks, the infrastructure underlying key money markets, and the need for better mechanisms for providing cross-border liquidity.
Another way of limiting systemic linkages and the risks of multiple-institution distress is to provide clearing facilities that mitigate counterparty risk by netting trades and making the clearing facility a counterparty to every trade. Recent attempts to provide some of these services for the credit default swap market are welcome. However, allowing a large number of proposed institutions risks diluting much-needed counterparty risk mitigation by splitting up the volumes and reducing netting opportunities. A competitive environment could potentially lead to cost-cutting measures that may compromise risk management systems. Thus, if multiple clearing facilities are permitted, they should be subject to strong oversight using globally accepted standards, ensuring the ability to clear and settle across borders and in multiple currencies.
《全球金融稳定报告》概要 2009年4月期
全球金融体系仍处于严重压力之下,因为危机正扩大到包括先进和新兴市场国家的住户、公司和银行部门。经济活动的收缩正在对银行的资产负债表造成进一步压力,因为资产价值继续下降,威胁到银行的资本充足率,并进一步阻碍新的贷款。因此,信贷增长正在放缓甚至变为负增长,对经济活动进一步造成向下的压力。私人部门大幅调整和公共支持计划已经在实施,促使出现了一些早期的稳定迹象。即便如此,需要进一步采取果断和有效的政策行动和国际协调,以便恢复公众对金融机构的信心,并恢复市场的正常状况。主要的挑战是打破金融体系与全球经济之间的螺旋式下降趋势。在重新设计全球金融体系方面已经做出了可喜的努力,这应为持续经济增长提供一个更加稳定、更有弹力的平台。 为了修复金融部门,需要采取政策消除银行和公司融资市场的压力,修复银行的资产负债表,恢复跨境资本流动(特别是流向新兴市场国家的资本),并限制为抗击危机而实施的政策所产生的非计划中的副作用。所有这些目标都需要在困难的形势下做出强有力的政治承诺,并进一步加强国际合作。应对危机挑战的这种国际承诺和决心正在增强,正如二十国集团4月初峰会的成果所显示的。
因资产价格下跌,各类非银行金融机构在危机期间面临压力。养老基金受到严重打击——其资产价值迅速下跌,而政府债券收益率下降(许多养老基金用该收益率对其负债进行贴现)同时增加了其融资不足的程度。人寿保险公司所持有的股票和公司债券遭受损失,在某些情况下显著消耗了其监管资本盈余。尽管这些机构的大多数可能审慎地管理风险,但一些机构承担了更大风险,而没有充分意识到前面可能出现的潜在压力。
从国外市场撤资的步伐目前超过了总体去杠杆化过程,跨境融资的急剧下降加剧了几个新兴市场国家的危机。事实上,外国投资者和银行的撤资加上出口市场的崩溃,给新兴市场经济体造成了融资压力,需要迫切予以关注。新兴市场的再融资需求很大,估计2009 年大约为 1.6 万亿美元,其中大部分需求来自公司,包括金融机构。虽然很难预测,目前的估计是,2009年流向新兴市场的净私人资本将为负值,并且今后资本流入不太可能回到危机前的水平。依赖这种资本流动的新兴市场经济体已经在削弱,使官方补偿性支持变得更加重要。
尽管先进经济体采取了前所未有的官方行动来制止螺旋式下降趋势,包括提供大规模财政支持和一系列流动性贷款机制,但需要进一步采取果断的政策行动,帮助恢复信心,并减轻金融市场的不确定性,这种不确定性正在破坏经济复苏的前景。但是,金融风险从私人部门向公共部门的转移带来挑战。人们继续担心意外的扭曲,以及短期刺激成本(包括开放式银行支持计划)是否会与人口老龄化带来的较长期压力合在一起,对一些先进经济体的政府债务负担造成强大的向上压力。另外,本国偏向正在形成,因为政府鼓励银行在本地贷款,并鼓励消费者保持本国导向的消费。
第一章讨论的这些风险代表了公共部门半个世纪以来面临的最困难的问题。我们在下面概述我们所认为的打破金融部门与实际经济之间的螺旋式下降趋势的关键要素。
当前的政策建议
即使迅速采取政策行动,并以预想方式实施计划,去杠杆化过程将是缓慢而痛苦的,经济复苏可能会旷日持久。估计伴随发生的去杠杆化和经济收缩在近期内将使美国、英国和欧元区的信贷增长收缩甚至变为负增长,在若干年后才会恢复。
鉴于这种困难的前景,需要果断地实施既定政策,并在必要的政策领域采取更为果断的行动。然而,对这种行动的政治支持正在减弱,因为在某些情况下,公众因认为纳税人资金被滥用而日益感到失望。确实存在这样一种风险,即政府将不愿拨出足够的资金来解决这个问题。此外,政治反应的不确定性可能会降低私人部门为有序缓解金融压力而建设性地参与融资的可能性。因此,恢复信心的一个重要部分是政策回应的明确性、一致性和可靠性。过去发生的金融危机已经表明,恢复银行体系正常运作需**要数年,伴随金融危机的经济衰退往往更深入和更持久(见2009 年4月期《世界经济展望》第三章)。同样的经历表明,如果政策不明确,未得到有力和迅速的实施,或未针对根本问题,那么,恢复过程会进一步拖延,按纳税人资金和经济活动衡量的成本会更大。
鉴于本次危机触及全球,如果受影响的国家以协调方式实施本国政策,则能增强政策效果。协调与合作应建立在最近二十国集团首脑会议创造的积极势头上。金融政策方面的协调与合作尤为重要,以避免各国行动带来不利的国际外溢效应。具体而言,开展跨境协调时,如果能以更加一致的方法解决银行体系的问题,包括处理不良资产,那么更容易建立信心,并避免监管套利和竞争扭曲。
从短期来看,上一期《全球金融稳定报告》确定的、2009年2月七国集团公报明确认可的三个优先事项仍然是适当的:(一)确保银行体系能够获得流动性;(二)确定和处理受损资产;(三)对薄弱但有生存力的银行进行注资,并迅速清理无生存力的银行。一般而言,第一项任务是针对中央银行的,而后两者是监管者和政府的责任。第一个领域已经取得进展,但其他两个领域的政策举措似乎比较零碎和被动。最近各国当局宣布的政策认识到需要处理问题资产,并评估银行对全球经济进一步恶化的抵御能力,以确定注资需要。这些是值得欢迎的步骤,随着详细措施出台,可能有助于减少不确定性和公众的怀疑。以往危机的教训表明,当局需要采取更有力和有效的措施,来处理和解决金融部门的薄弱环节。
确保新兴市场经济体受到充分的保护,减少因先进经济体投资者去杠杆化和风险回避而受到的影响。
先进国家银行部门的问题和全球经济收缩目前正在对新兴市场国家造成严重影响。我们预测,今后几年内,每年跨境证券资本外流约为新兴市场GDP的1%。在合理的预测情景下,流向新兴市场的私人资本在2009 年可能为净流出,2010 年和2011 年恢复的可能性很小。
同先进经济体一样,新兴市场的中央银行将需要确保其银行体系有充足的流动性。然而,在许多情况下,国内银行间市场不是主要的融资来源,因为近年来银行的很多资金是从外部获得的。因此,中央银行很可能需要通过互换或直接出售提供外币。拥有大量外汇储备的中央银行可以利用这种缓冲,但其他手段(如与先进国家中央银行的互换安排或使用基金组织贷款机制)也应作为一道防线。二十国集团首脑会议之后,基金组织获得更多可用资金,这有助于帮助各国缓解金融危机对实际活动的影响,并限制对贫困人口的影响,尤其是在发展中国家。此外,在某些情况下,基金组织的规划在动员其他渠道的支持方面可以发挥有益的作用。
协调各国政策,避免以邻为壑的处理方法。 支持国内贷款的压力可能导致金融保护主义。当各国单方面采取行动以支持本国金融体系时,可能对其他国家造成不良后果。在一些国家,当局表示,获得支持的银行应维持(或最好扩大)国内贷款。这可能挤出外国贷款,因为银行面临持续压力降低整体资产负债表的杠杆率、出售海外业务以及设法处理高风险资产,对新兴市场国家、从而对更广泛的全球经济造成破坏性影响。与此同时,最近一些国家母银行之间达成的继续向东道国子银行提供信贷的协议令人振奋。
宏观经济政策的一致和强化
为了为可持续的经济复苏奠定基础,稳定全球金融体系至关重要。如2009年4月期《世界经济展望》指出的,着眼于金融部门的政策如果得到适当的财政和货币政策的配合,将更加有效。
促进相辅相成的财政和金融政策。
恢复信贷增长对于维持经济活动是必要的。为支持经济活动和限制资产贬值而采取的财政刺激应能改善借款人和支撑贷款的抵押品的信誉,加上为增强银行资产负债表而实施的金融政策,将带来稳健的信贷扩张。另外,基础设施项目公私合作伙伴关系的
为更强健的全球金融体系奠定基础
政策制定者的当务之急是解决目前的危机。与此同时,正在继续努力建立一个长期内更加强健的金融体系。除了在危机结束后建立抗冲击力更强、更有效的金融体系外,对长期金融政策的明确方向感也有助于在短期内消除不确定因素和改善市场信心。虽然下面提到的许多建议似乎是概念性的,但其影响是实际存在的。为正确实施这些建议,需要对结构和资源做出重大调整,而国际一致性将是至关重要的。
毫无疑问,这场危机要求对金融市场的形式和运作进行深远的变革。相比危机之前的时期,金融体系的特点将是杠杆率降低、融资不匹配状况减少、交易对手方风险下降,以及更透明和更简单的金融工具。在促进这一新的环境方面,私人部门具有核心责任,这将通过改善风险管理(包括关注治理和薪酬政策)而实现。
无论市场纪律还是公共监督都不足以正确评估和控制系统性风险的积累,因此,改善金融监管是防范未来危机的关键。重点应当是如何通过更好的监管来察觉和减轻系统性风险。
试图消除所有系统性风险不仅是不可能的,而且也将减缓经济增长和限制创造力和创新,但当前的危机表明,应当更加强调着眼于系统的监管。与此同时,货币政策宏观审慎框架的改善也有助于减轻系统性风险。虽然我们在监管时应当尽量鼓励私人机构采取加强金融稳定的行动,我们应当认识到整个系统的稳定是一种公共产品,私人机构将低估其价值,监管需要迫使具有系统重要性的公司更好地内部化不稳定带来的总体社会成本。为此,中央银行和监管机构的职能应包括金融稳定。应当具备对系统性风险进行评估和采取行动的明确的框架,明确界定谁是牵头的系统性监管者。
为了能减轻系统性风险,需要更好地界定和衡量这些风险。第二章和第三章探讨了各种衡量指标,通过观察直接和间接联系来帮助识别具有系统重要性的机构。在某些情况下,这些衡量指标可以被看作一个起始点,考虑实行额外的资本附加要求,作为对那些变得“联系太紧密而不能倒闭”的公司的警戒措施。即使不正式使用,所提出的衡量指标也可以指导政策制定者限制各机构间各种风险暴露的规模。显然,这种方法需要非常仔细的考虑和应用,以避免各机构寻找其他途径承担风险而盈利。需要进行更多讨论和研究,之后才能在这项工作的基础上进行监管。
在监管改革方面,我们认为有四个优先领域:防止过高杠杆率和减轻顺周期性,解决市场纪律和信息缺口问题,改善跨境和跨职能监管,以及加强系统流动性管理。主要经验教训可以归纳如下。
防止过高杠杆率和抑制顺周期性。 需要采取新的监管方法,避免系统性风险的积累以及随后发生的困难的去杠杆化过程。对于今后如何限制杠杆程度并减少商业做法和现行监管固有的顺周期倾向,找到解决办法仍然具有挑战性。监管应力图加强金融机构以风险为基础的稳健决策,而在全球经济中阻止承担风险将是无益的。监管应提供支持系统性稳定的激励机制,同时阻止监管套利和短期行为,但应逐步采用更高标准,以免加剧当前形势。
应当加强会计规则和定值做法,以反映关于整个周期内风险演变的更广泛的现有信息。会计标准制定机构和审慎监管当局应合作实现这些目标,特别是强调以下方面,即在信贷迅速扩张时期能够提取更高的贷款损失准备金,评估当交易账簿上的资产定值高度不确定时定值储备或调整的方法,以及研究有哪些其他方式可以阻止可能与公允价值会计有关的不利动向。
此外,还有必要采取措施改善流动性缓冲和融资风险管理,从而减少流动性风险的顺周期性。在经济上行期,需要更多地关注融资期限结构和资金来源的可靠性,这些因素在经济衰退期可能是脆弱的。
解决市场纪律和信息缺口问题。
必须解决危机揭示的信息缺口问题。在许多情况下,察觉系统性风险所需的信息要么未被收集,要么在分析时未考虑系统性风险,特别是分析系统性联系所需的那些数据,因为这要求各机构之间相互风险暴露的信息。然而,除了在收集这些数据并正式衡量风险暴露方面存在一些技术困难外,在一国内部不同类型机构之间和不同国家之间收集这些信息存在法律障碍。需要保证各国报告和定义的一致性,并加强信息共享,从而着手在这一领域取得进展。
需要改善关于表外风险暴露、复杂结构性产品、衍生工具、杠杆率以及跨境和对手方风险暴露的信息,来补充早期预警框架中使用的一套现有指标。应当加强具有系统重要性的金融机构的披露做法,包括定值方法和风险管理做法,经修订的一套财务健全性指标,以及政策制定者对系统性风险的更有效评估。第二章和第三章的分析强化了这些要素。同时,应当提供更多可靠的公共信息,这将帮助投资者进行适当的尽职调查,尽职调查的失效在很大程度上促成了当前的危机。加强跨境和跨职能监管,必须改善体制和法律安排。需要在以下领域取得进展,即减少不必要的差异,克服对具有全球和地区重要性的公司的监管障碍,采取更协调的早期补救行动、银行清理法律框架和监管做法来监督跨境公司。监管者协会指定一个牵头监管机构(原则上是母国当局)对于确保充分监督非常必要。母国应努力加强与东道国的合作,以确保在需要迅速反应时有畅通的沟通渠道。应急计划应包括所有相关当事方。
改善系统流动性管理。 在系统流动性管理方面,中央银行可以从危机中汲取一些教训,包括其操作框架的灵活性、关键货币市场的基础设施以及改善提供跨境流动性机制的必要性等方面。
限制系统性联系和多家机构陷入困境的风险的另一个途径是提供有关清算机制,通过对交易进行轧差并使清算机制成为每项交易的对手方来减轻对手方风险。最近为信用违约掉期市场提供某些此类服务的努力是令人欢迎的。然而,允许众多所建议的机构参与,将分割交易量并减少轧差机会,从而可能削弱亟需的对手方风险缓解措施。竞争的环境可能导致损害风险管理系统的削减成本措施。因此,如果允许多个清算机制,则应当运用全球认可的标准对它们实施强有力的监督,确保有能力进行跨境、多币种的清算和结算。
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