2013年-IMF国际货币组织全球_Singapore_Detailed_Assessment_of_Observance_300页_1mb

Singapore Detailed Assessment of Observance of CPSS-IOSCO Principles for Financial Market Infrastructures (2013)

Core Content

Singapore has a well-developed financial market infrastructure (FMI), including two central counterparties (CCPs): the Central Depository (CDP) and the Singapore Exchange Derivatives Clearing Limited (SGX-DC). These CCPs are part of the broader FMI ecosystem, which is regulated and supervised by the Monetary Authority of Singapore (MAS). The assessment was conducted as part of the IMF Financial Sector Assessment Program (FSAP) in 2013, focusing on the observance of the CPSS-IOSCO Principles for Financial Market Infrastructures (PFMI).

Main Points

• Financial Market Infrastructure Overview: Singapore has a robust payment, clearing, and settlement system, with CDP and SGX-DC being key CCPs. The system includes a real-time gross settlement (RTGS) system, securities settlement systems, and collateral management frameworks.

• Regulatory Framework: The MAS oversees the regulation and supervision of FMIs and CCPs, using the Securities and Futures Act (SFA) and its regulations. The MAS has publicly adopted the PFMI and ensures transparency in its regulatory approach.

• CDP (Central Depository):

  • CDP is a systemically important FMI, providing clearing, settlement, and depository services for equities and fixed income instruments.
  • It cleared S$327,281 million in securities trades in 2012, with shares accounting for 88% of the value and 81% of the volume.
  • CDP operates under a T+3 settlement cycle and uses a clearing fund and margin requirements to manage credit and liquidity risks.
  • It accepts SGD, USD cash, and government securities as collateral, though cash is predominantly used.
  • CDP is not currently considered a CCP of systemic importance in multiple jurisdictions, but this may change with increasing transaction volumes.

• SGX-DC (Singapore Exchange Derivatives Clearing Limited):

  • SGX-DC is the main CCP for exchange-traded and OTC derivatives in Singapore.
  • It is expected to grow in systemic importance due to the G20 reforms requiring mandatory clearing of standardized OTC derivatives.
  • In 2012, SGX-DC had an average daily clearing value of USD 25 billion and an average daily outstanding notional value of USD 300 billion.
  • It uses a risk management waterfall that includes margin, clearing fund, and own capital to address credit losses.
  • SGX-DC operates a collateral submission management and optimization system (COSMOS) and uses Calypso technology for its clearing system.

• Regulatory and Operational Risks:

  • The assessment highlights the need for enhanced recovery and resolution plans to cover extreme scenarios such as the simultaneous default of settlement banks or custodians.
  • The use of non-cash collateral, such as Singapore government securities, is encouraged to improve access to central bank liquidity.
  • Legal risks due to conflicts of laws, especially with U.S. and EU regulations, may affect SGX-DC, and MAS is advised to collaborate closely with foreign authorities to mitigate these risks.

• Competition and Market Evolution:

  • Increased competition from foreign CCPs may lead to reduced clearing fees and improved services, but also pose pressure on collateral requirements.
  • The MAS and SGX are encouraged to maintain international standards and ensure the safety and efficiency of the CCPs.

• Recommendations:

  • For CDP: Review legal structure to separate CCP and CSD functions, and enhance recovery and resolution frameworks.
  • For SGX-DC: Improve recovery plans to cover a broader range of scenarios, and explore the use of non-cash collateral.
  • For MAS: Strengthen cooperation with foreign regulators to address legal conflicts, and ensure continued oversight of CCPs and FMIs.

Key Information

• Legal Entities and Oversight: CDP and SGX-DC are wholly owned subsidiaries of the SGX Group, which is regulated as an approved holding company under the SFA. CDP is also regulated under the Companies Act.

• Collateral Management: Both CDP and SGX-DC use COSMOS for collateral management. CDP accepts SGD and USD cash, Singapore government securities, and U.S. treasuries as collateral, though cash is most commonly used.

• Settlement Process: CDP uses a T+3 settlement cycle, with money settlement in commercial bank money and final settlement in central bank money. SGX-DC uses real-time clearing for exchange-traded derivatives and OTC commodities, and a multi-step process for OTC financial derivatives.

• Systemic Importance: With the implementation of G20 reforms, SGX-DC is expected to increase in systemic importance due to the mandatory clearing of standardized OTC derivatives.

• Risk Management: Both CCPs have robust risk management frameworks, including daily stress testing, margin calculations with a confidence level of at least 99%, and a clearing fund to cover potential losses.

Summary of Findings

• CDP and SGX-DC are assessed as sound and efficient CCPs that comply with international standards.
• The MAS has an effective regulatory framework in place for FMIs and CCPs, with clear powers and oversight mechanisms.
• The need for enhanced recovery and resolution frameworks, particularly for extreme scenarios, is emphasized.
• The use of non-cash collateral is recommended to improve access to central bank liquidity.
• Legal conflicts and cross-border regulatory implications require closer cooperation between MAS and foreign authorities.
• CDP is advised to review its legal structure to better separate CCP and CSD functions.
• The potential for increased competition and market pressures on collateral requirements is noted, with a call to maintain safety and compliance.