2018年-IMF国际货币组织全球_Belgium_Financial_System_Stability_Assessment_67页_1mb

Belgium Financial Sector Assessment Program: Banking, Insurance, and Financial Conglomerate Supervision

Core Content

This document is a Technical Note prepared by the International Monetary Fund (IMF) as part of the Financial Sector Assessment Program (FSAP) for Belgium, completed on February 26, 2018. It evaluates the regulatory and supervisory framework for banks, insurance companies, and financial conglomerates (FCs), with a focus on supervisory effectiveness, risk management, and financial stability.

Main Findings

• The regulatory framework in Belgium has been significantly strengthened since the 2013 FSAP, with the introduction of new banking and insurance laws, the implementation of Solvency II, and the designation of the National Bank of Belgium (NBB) as the macroprudential authority.
• The Single Supervisory Mechanism (SSM), under the European Central Bank (ECB), oversees over 90% of the Belgian banking sector, leading to more intrusive, forward-looking, and effective supervision.
• Supervisory practices for less significant institutions (LSIs) have improved, with NBB aligning its approach with that of significant banks, while being mindful of proportionality.
• Financial conglomerates pose unique challenges due to their interconnectedness and the need for supplementary supervision to address group-wide risks such as capital adequacy, liquidity, and contagion.

Key Areas of Focus

Banking Supervision

• Internal Models: The SSM has initiated a targeted review of internal models used for capital calculation. Continued improvement in model monitoring is essential to reduce variability in risk-weighted assets (RWAs). Bank boards should be more involved in the oversight of these models.
• Loan Classification and Provisioning: Accounting norms have traditionally driven loan classification in Belgium, but ECB guidelines now introduce prudential considerations. Supervisors should actively assess banks' treatment of assets to ensure sound provisioning.
• Related Party Transactions: There is no EU-wide regulation on related party transactions, and the legal definition in Belgium is too narrow. A broader definition and stronger policies are recommended.
• Off-Balance Sheet Activities: Special Purpose Entities (SPEs) should be included in supervision, with a process to determine whether they are fully or proportionally consolidated. Stress tests should consider all off-balance sheet activities.

Insurance Supervision

• Evolving Risk Profiles: Insurers have shifted from traditional products to asset management-type products, reducing interest rate risk but increasing liquidity risk. A robust regulatory framework for liquidity is needed.
• Capital Quality: Despite meeting Solvency II requirements, reliance on lower quality capital (e.g., subordinated loans from parent banks and unrecognized gains) is a concern. Proactive engagement with the industry is required to improve capital quality.
• Liquidity Risk: The Brexit has led to a reallocation of reinsurance business to Belgium, increasing the sector's complexity and risk. NBB should be prepared to deploy prudential measures to address liquidity risk.
• Data and Reporting: Detailed reporting requirements for insurers with large mortgage loan exposures should be considered. Retention of highly qualified staff is critical for the implementation of Solvency II.

Financial Conglomerate Supervision

• Governance and Risk Management: Supervisory expectations for governance and integrated risk management should be heightened. The SSM Supervisory Manual should be updated to include guidance on supplementary supervision.
• Intra-Group Transactions: Supervisory practices for data collection and analysis of intra-group transactions and concentration risk are limited and not harmonized. Guidance should be developed to assess the economic purpose of these transactions and identify sub-quality asset transfers.
• Regulatory Arbitrage: The mission recommends monitoring the risk of regulatory arbitrage between the insurance and banking sectors.

Recommendations

Key Information

• The Belgian banking sector is highly concentrated, with four banking groups holding over 80% of the consolidated system assets.
• Non-performing loans (NPLs) decreased to 3.5% of total loans in 2016: Q3, with a liquid assets to short-term liabilities ratio of 57.8.
• Composite insurers account for 92% of the insurance industry assets, with a high allocation to sovereign bonds, particularly Belgian government bonds.
• Solvency II has been implemented, but capital quality remains a concern, especially with subordinated loans and unrecognized gains.
• Financial conglomerates are interconnected and require supplementary supervision to address systemic risks.
• Brexit has increased the reinsurance business in Belgium, posing new challenges for supervisors.
• The FSAP team commends the authorities for their improvements and urges them to continue strengthening the policy framework for financial stability.

Conclusion

The Belgian financial sector has made significant progress in regulatory and supervisory frameworks, particularly in banking and insurance. However, challenges remain in capital quality, liquidity risk, and supervision of financial conglomerates. The IMF recommends continuous improvements in supervisory practices, enhanced data collection, and proactive engagement with the industry to ensure financial stability and effective regulation.