2013年-世界发展银行全球_Poland___BCBS-IADI_Core_Principles_for_Effective_Deposit_Insurance_Systems_78页_1mb

报告摘要

Summary, Key Findings and Recommendations for Poland's Deposit Insurance System

Core Content

This report is part of the World Bank's Financial Sector Assessment Program (FSAP) and evaluates the compliance of Poland's Bank Guarantee Fund (BFG) with the BCBS-IADI Core Principles for Effective Deposit Insurance Systems. The assessment was conducted in 2013 by a team of experts from the World Bank and IMF, and it highlights both the strengths and areas for improvement in Poland's deposit insurance framework.

Key Findings

The BFG is Compliant or Largely Compliant with 16 out of 17 applicable Core Principles, but is Materially Non-Compliant with one.
The BFG has a well-developed reimbursement system capable of prompt payouts within 20 working days, with the potential for even faster processing.
The legal framework for the BFG is comprehensive but needs improvements in areas such as corporate governance, resolution, and insolvency.
The governance structure of the BFG is sound but has conflict of interest issues due to the presence of PBA representatives on the Fund Council.
The funding model is hybrid, with five funds and emergency back-up from the NBP and MoF, though the complexity of multiple funds could be reduced.
The resolution framework is underdeveloped, with fragmented tools and limited powers, but draft legislation aims to address these deficiencies.
The financial system in Poland is well capitalized and liquid, with banks playing a dominant role, but NPLs have increased due to the economic slowdown and loose underwriting standards.
The supervisory framework (KNF) is intensive, but needs to tighten credit and lending policies and enhance on-site supervision.
The BFG is well integrated with other financial safety-net participants and has robust information-sharing mechanisms.

Key Recommendations

Governance: Remove PBA representation from the BFG Council and consider involving the PBA through an external advisory committee to reduce conflict of interest risks.
Funding: Rationalize the number of funds in place to reduce complexity, while ensuring sufficient resources to meet the EU-mandated coverage increase and the planned expansion of the BFG's resolution powers.
Resolution Framework: Enhance the resolution regime by developing new tools such as receivership powers, purchase and assumption, and bridge institutions, and by updating coordination mechanisms with the KNF, NBP, and MoF.
Supervision: Improve the KNF's powers to issue binding resolutions and enhance on-site supervision to better mitigate moral hazard.
Public Awareness: Continue and expand public awareness initiatives, including the use of innovative communication tools like social media.
Legal Protection: Address gaps in codes of conduct for BFG employees regarding employment in member institutions by introducing specific statutory prohibitions.

Detailed Assessment of Compliance with the Core Principles

Core Principle	Grade	Comments
1. Public policy objectives	C	Public policy objectives are formally specified in legislation and integrated into the design of the BFG.
2. Mitigating moral hazard	LC	The BFG has design features to mitigate moral hazard, but the high coverage level and deficiencies in the supervisory system reduce its effectiveness.
3. Mandate	C	The BFG's mandate is clearly and formally specified in legislation.
4. Powers	C	The BFG is provided with the necessary powers to fulfill its mandate.
5. Governance	LC	The governance framework is sound and effective, but the presence of PBA members on the Council raises conflict of interest concerns.
6. Relationships with other safety-net participants	C	Effective formal information sharing and coordination agreements have been developed.
7. Cross-border issues	C	The BFG is in compliance with EU cross-border provisions and has developed MOUs with other countries.
8. Compulsory membership	C	Membership is compulsory for all domestic banks and foreign branches not covered by a home country system.
9. Coverage	C	Coverage is defined in law, credible, limited, and meets the public policy objectives.
10. Transitioning from a blanket guarantee to a limited coverage DIS	NA	Not applicable.
11. Funding	C	The BFG uses a hybrid ex-ante and ex-post model with sufficient funding mechanisms, though the complexity of multiple funds is an issue.
12. Public awareness	C	The BFG engages in a wide range of public awareness activities.
13. Legal protection	LC	Legal protection arrangements are generally effective, but codes of conduct for employees are incomplete.
14. Dealing with parties at fault in a bank failure	C	Relevant authorities have the power to seek legal redress against those at fault.
15. Early detection and timely intervention and resolution	LC	The BFG is well integrated into the early warning and risk assessment system, but the supervisory framework and resolution tools are inadequate.
16. Effective resolution processes	MNC	The resolution framework is fragmented and lacks key elements such as asset transfers and receivership powers, though draft legislation is expected to address these.
17. Reimbursing depositors	C	The BFG is capable of prompt reimbursement of insured deposits.
18. Recoveries	C	The BFG shares in the proceeds of recoveries from failed banks, with commercial considerations guiding asset management.

Aggregate Compliance

Compliant (C): 12 principles
Largely Compliant (LC): 4 principles
Materially Non-Compliant (MNC): 1 principle
Non-Compliant (NC): 0 principles
Not Applicable (NA): 1 principle

Conclusion

The BFG has made significant progress in establishing an effective deposit insurance system, with a strong reimbursement framework, governance structure, and public awareness initiatives. However, there are areas for improvement, particularly in governance, funding structure, and resolution capabilities. The draft legislation being developed is expected to enhance the system's compliance with international standards.

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