2017年-FSB全球金融稳定委员会_Peer_review_of_France_70页_1mb

Summary of the Peer Review of France

Core Content

The peer review of France, conducted by the Financial Stability Board (FSB) in 2017, focused on two key areas: macroprudential policy framework and public disclosures of financial sector data. The review aimed to evaluate the implementation and effectiveness of reforms in these areas, particularly in light of the Financial Sector Assessment Program (FSAP) and FSB recommendations.

Main Findings

• Significant progress has been made in developing a comprehensive macroprudential policy framework and enhancing financial sector disclosures.
• Macroprudential initiatives have been supported by both EU and national-level efforts, with the HCSF (Haut Conseil de Stabilité Financière) playing a central role.
• Disclosure improvements have been achieved, but further work is needed to enhance transparency and comparability, especially for insurance and asset management sectors.

Key Areas of Focus

1. Macroprudential Policy Framework

• Legal and institutional basis: The July 2013 Banking Reforms Act established the HCSF with a clear mandate for financial stability and macroprudential powers. The HCSF has been operational and has improved cooperation and information sharing with member authorities.
• Scope of macroprudential policy: While the HCSF has focused on the banking sector, there is a need to expand its scope to other sectors such as insurance and asset management.
• Systemic risk assessments: The BdF and ACPR use network analysis to assess interconnectedness and risks within the financial system. This tool is being extended to other sectors like asset management and corporate finance.
• Data transparency: There is limited public disclosure of the data, methodologies, and assumptions used in systemic risk assessments. Enhanced transparency could improve market understanding and confidence.
• Communication strategy: The HCSF and its member authorities have published reports on financial stability, but the timing and content of these reports may lead to overlapping or conflicting messages. A more coordinated communication strategy is recommended.

2. Public Disclosures of Financial Sector Data

• Enhanced disclosure requirements: Since the FSAP, France has implemented improved disclosure standards for banks (CRR), insurers (Solvency II), and other financial institutions (UCITS and AIFMD).
• Complex banking groups: While some concerns from the FSAP regarding capital treatment in mutual banking groups have been addressed, internal solidarity mechanisms still require detailed disclosures.
• Solvency and Financial Condition Reports (SFCRs): Over 500 insurers apply Solvency II, which requires annual SFCR disclosures. The ACPR is responsible for overseeing compliance, but the process is resource-intensive.
• Recommendations for SFCRs: A risk-based review program is needed to assess and prioritize SFCR submissions. There should also be a formal process to identify deficiencies and ensure their correction.
• Transparency in insurance sector: Unlike the banking sector, the insurance sector does not benefit from a comparable transparency exercise. The ACPR should consider enhancing transparency by publishing regular, comparable data on a representative sample of insurers or by developing common templates and interfaces for data disclosure.

Recommendations

Macroprudential Policy Framework

1. Extend macroprudential approach: The HCSF should continue to expand its macroprudential policy framework to include the insurance and asset management sectors.
2. Enhance systemic risk analysis: The BdF should improve its analysis of systemic risks beyond banks and insurers, including cross-border and corporate exposures.
3. Improve transparency: The HCSF, BdF, and AMF should disclose the data, methodologies, and assumptions used in systemic risk assessments in their reports.
4. Coordinate communication: These authorities should examine the coordination of their publications and consider publishing a calendar of meetings and report dates.

Public Disclosures of Financial Sector Data

5. Apply EBA guidance: The ACPR should support the application of the EBA’s guidance on disclosure requirements to improve transparency in the treatment of insurance undertakings within banking groups.
6. Implement a risk-based SFCR review program: The ACPR should develop a program to assess, communicate, and follow up on deficiencies in SFCR submissions.
7. Enhance transparency in insurance sector: The ACPR should consider publishing regular, comparable financial and prudential data for a representative sample of French insurers, or facilitate such disclosures through common templates and standard interfaces.

Conclusion

The peer review of France highlights the country's progress in strengthening its macroprudential policy and improving financial sector disclosures. However, further steps are needed to ensure that the framework is comprehensive, transparent, and effectively communicates financial stability risks to market participants. The recommendations focus on expanding the scope of macroprudential oversight, improving transparency and consistency in disclosures, and enhancing coordination among financial stability authorities.