2016年-世界发展银行全球_El_Salvador_Financial_Sector_Assessment_Program_Development_Module___Financial_Infrastructure_76页_1mb

Summary of Financial Sector Assessment Program - Development Module: El Salvador

Core Content

This document is a Financial Infrastructure Technical Note prepared by the World Bank as part of the Financial Sector Assessment Program (FSAP) mission in El Salvador in March 2016. It provides a detailed analysis of the country's payment and securities settlement systems, credit reporting systems, and secured transactions and collateral registry. The objective is to support the development of a more efficient, secure, and inclusive financial system.

Main Findings and Recommendations

Payment and Settlement Systems

• The National Payments System (NPS) has expanded and consolidated since the last FSAP.
• The Real-Time Gross Settlement (RTGS) system, operated by the Central Bank of El Salvador (BCR), is the backbone of the NPS and is widely used by both banks and non-bank financial institutions.
• In 2015, the RTGS system settled transactions equal to 1.8 times GDP, with 17% annual growth over the past three years.
• The Bolsa de Valores de El Salvador uses the RTGS system for securities settlement based on Model 2 Delivery versus Payment (DVP).
• The private ACH system was launched in 2011 but has low transaction volumes, and the SPM system is used for government payments, though it lacks Straight-Through-Processing (STP).

Legal and Regulatory Framework

• A payment system law is recommended to address legal gaps and risks, particularly around settlement finality and netting.
• The BCR is formally tasked with regulating and overseeing payment and securities systems under the Organic Law.
• There is no statutory recognition of electronic fund transfers as valid payments, and cheque images are not legally recognized for re-presentment.
• A functional and risk-based approach to regulation should be adopted to include non-banks in the regulatory perimeter.

Large-Value Payment Systems

• The BCR should evaluate whether the RTGS system meets international standards for systemically important payment systems.
• Large-value cheques should be discouraged in the short term and eliminated in the medium term due to inefficiencies and risks.
• Straight-through-processing (STP) should be implemented to promote RTGS usage.
• The BCR should stress test the RTGS system regularly and ensure business continuity plans with a secondary site ready within two hours of disruption.

Retail Payment Systems and Services

• Cash and cheques dominate the retail payment landscape, but the BCR should promote electronic payments.
• The ACH system needs to be expanded and improved in terms of governance and fees to encourage participation.
• Direct debit should be implemented in the ACH to reduce cash-based bill payments.
• The BCR should monitor interchange fees and their impact on POS penetration and merchant costs.
• A balanced approach to interoperability regulation is needed to avoid duplicative networks and discourage innovation.

Government Payments

• The Treasury Single Account (TSA) should be implemented to centralize government funds.
• The SPM system is inefficient due to lack of STP and should be leveraged using existing ACH infrastructure.
• G2P and G2B payments should be transitioned to electronic means to improve financial inclusion.
• Prepaid cards and e-money products should be considered for social transfers, taking into account acceptance infrastructure, payment functionality, and transaction costs.

Securities Settlement Systems

• The Cedeval (Central Securities Depository) is set to take over securities clearing and settlement, which would eliminate the time lag in settlement.
• Corporate governance and transparency of Cedeval should be aligned with international standards.
• Risk management should be independent and have board-level access.
• Interoperability with Euroclear, Clearstream, and other regional CSDs should be evaluated to mitigate cross-border risks.
• Cedeval should ensure final settlement by the end of value date and discontinue the deferral to next business day practice.
• Liquidity reserves should be maintained at least equal to six months of operational expenses to ensure continuity.

International Remittances

• Remittances to El Salvador reached USD 4,363 million in 2015, or 17% of GDP, with 90% from the US and 10% from Canada.
• The average remittance cost is 4.33%, below the global average of 7.53%.
• The BCR should consider allowing international remittances to be received into e-money accounts.
• A payment system law would provide a statutory framework for remittance service providers (RSPs) and remittances as payment instruments.

Payment System Oversight and Cooperation

• The BCR should define clear oversight objectives, standards, and tools.
• Oversight should be guided by the Principles for Financial Market Infrastructures (PFMIs).
• Formal cooperation with private sector stakeholders is recommended.
• The National Payments Council is suggested as a permanent body for cooperation and consultation.
• Clarification and coordination of responsibilities between the BCR and the SSF (Superintendencia del Sistema Financiero) is needed.

Credit Reporting Systems

• Credit reporting systems in El Salvador have existed since 1997, but are fragmented and unreliable.
• The National Credit Reporting System (NCRS) is not effective due to incomplete data and lack of sharing between sectors.
• Equifax has the largest database, while TransUnion has limited information from non-banking sectors.
• Data sharing is restricted due to bank secrecy laws, and positive credit information is not shared between sectors.
• Credit bureaus focus on specific niches, leading to incomplete credit profiles for individuals and companies.
• MSMEs have limited access to credit, with lending to this segment accounting for only 16.40% of total financial system lending in 2015.
• Consumer lending and housing credit account for 32% and 25%, respectively.
• Cross-border data flows and consumer consent are important considerations for improving data quality and consumer protection.

Key Information

• RTGS system: Backbone of NPS, used by BCR and non-bank institutions.
• ACH: Private-sector system with limited growth and volume.
• SPM: Government payment system with potential for future use in G2P.
• Cedeval: Central securities depository with potential to improve securities settlement.
• Remittances: Key to financial inclusion, with low cost and high volume.
• Legal framework: Needs strengthening, particularly around settlement finality and electronic payments.
• Credit reporting: Fragmented, with limited data sharing and coverage for MSMEs.
• Regulatory cooperation: BCR and SSF should work closely to enhance oversight and coordination.

Conclusion

The document highlights the evolution and challenges of El Salvador's financial infrastructure, emphasizing the need for legal reforms, regulatory improvements, and enhanced coordination. It provides technical insights and policy recommendations to modernize payment and credit reporting systems, improve securities settlement, and leverage remittances for financial inclusion. The BCR is identified as the key regulator and overseer in this context, with a focus on systemic risk management, operational efficiency, and public policy objectives.