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CARIBBEAN FINANCIAL STABILITY-
NEXT STEPS
Presented by Cleviston Haynes
FIRST JOINT CARIFORUM-EU COFERENCE ON FINANCIAL SERVICES
9 July, 2010
OVERVIEW
1. Lessons from Global Financial Crisis.
2. Caribbean Financial Systems.
3. Proposal for Promoting Regional
Financial Stability.
2
GLOBAL FINANCIAL CRISIS
Break-down in risk management at financial
institutions.
Gaps in supervision and regulation that
adversely impacted regulators ability to
monitor or address these risks.
Regulatory arbitrage.
Fragmented supervision.
Risks were easily transferred across
institutions.
No one protected overall system.
3
CARIBBEAN
FINANCIAL SYSTEMS
Banking sector is the dominant financial sector activity within the
region.
Banking sector complemented by insurance, securities, credit
union and mutual fund activities which individually and
collectively are small in comparison.
The banking sector is mainly foreign owned and highly
concentrated.
Notable consolidation of activity in recent years through mergers
and acquisitions.
Significant financial entities domiciled in region but operating
cross-border.
Some firms are operating across financial sectors.
4
CARIBBEAN
FINANCIAL SYSTEMS
With the high degree of concentration,
institutions that may not be considered
systemically important in their home country,
may be systemically important in a small
country because of its share of the market
and the lack of alternatives to provide similar
services.
Dependence on foreign institutions make
Caribbean economies vulnerable to shocks
occurring elsewhere.
5
FINANCIAL SECTOR SUPERVISION
Mixed models of supervision with the dominant mode being
central banks with responsibility for banking while insurance
companies and credit unions are handled under government
ministries.
Jamaica has established a financial services commission to
regulate securities and insurance companies while Barbados is
on the verge of integrating all non-bank regulation under a
single regulator to be established.
Trinidad and Tobago has responsibility for banking and
insurance.
Jamaica has also established a financial regulatory council.
These trends reflect concerns about regulatory framework and
supervision, particularly in the non-bank sector.
6
RISKS TO FINANCIAL STABILITY
Financial stability extends beyond banks.
Insurance companies could have significant
exposures in a bank that goes bad. If the
insurance entity is significant this could shake
confidence in both types of institutions.
Financial stability could be threatened by
Inadequate information sharing among domestic
and regional regulators.
Lack of consolidated view of financial institutions
and the risks posed by intra-group transactions.
Inadequate assessment of cross-border
contagion risk. 7
CONSOLIDATED
SUPERVISION
Financial institutions are operating cross-border and
sometimes cross sector
Entities need to be examined as a whole and not solely on the
basis of the local operation
Primary responsibility falls to the regulator where the parent is
domiciled
Important to have common standards across jurisdictions
Effective information sharing among regulators needed
Contagion risk is high even for sound subsidiaries when one
significant affiliate falters.
Efforts at consolidated supervision relatively recent and need to
be enhanced.
8
REGIONAL SUPERVISORY
APPROACHES
Role of Regional Supervisory groupings.
Sector specific supervisory standards
Harmonisation of legislative framework
Training
Memorandum of Understanding.
Colleges of Supervisors.
9
FINANCIAL STABILITY ANALYSIS
It involves both the economic and the prudential,
capturing the impact that domestic and external
economic effects may have on financial risk
Applying traditional prudential standards.
It is regional in scope, to take account of cross
border exposures, contagion, and the effects of the
operations of regional financial conglomerates.
It is an ongoing exercise, with monthly data
collection, analysis and reporting.
10
ELEMENTS OF THE REGIONAL FRAMEWORK
Collection and publication of regional FSIs, monthly.
Monthly financial stability assessment memorandum to
highlight new sources of risk, vulnerabilities, and to track
remedial actions.
Monthly meeting of central bank governors to review the
memorandum, to take action to strengthen regional
financial system resilience and to monitor implementation
(video conference).
Publication of regional FSR, annually.
Trigger mechanism for response to impending financial
failure built-in.
11
CURRENT MONTHLY DATA
Real sector and monetary data.
Commercial bank balance sheet and income
data.
Regional financial soundness indicators
(Jamaica, Trinidad-Tobago, …)
12
DATA WE NEED MONTHLY
Insurance and credit union balance sheet and income
data.
Balance Sheet and Income data for other non bank
financial institutions e.g. – mutual funds, mortgage
companies, other deposit taking institutions and
financial conglomerates.
FSIs for nonbanks.
Intra-regional transactions balances.
Regional interbank market transactions; interbank
loans and deposits.
13
OTHER INFORMATION/DATA REQUIRED
Ownership structure of regional financial
conglomerates.
Foreign asset/exchange exposure of large
financial institutions.
Market information – equity prices, housing
prices, commodity prices, financing
arrangements for major investment projects.
Capital flows – regional and extra regional
flows (higher frequency).
14
MONTHLY FINANCIAL SYSTEM ASSESSMENT IS
ESSENTIAL
Someone needs to be maintaining vigilance
over the regional financial sector at all
times.
Since regional central banks have financial
stability responsibility in their countries, a
regional conference of central bank
governors and heads of monetary
authorities is the obvious choice.
May be via teleconferencing
15
QUARTERLY CONFIDENTIAL FSR MEMO
The quarterly meeting would need to
be informed by a memo, indicating
the strengths and vulnerabilities
revealed by an analysis of the
monthly FSIs.
This memo would be short, focusing
on crucial issues, and supported by
appropriate tables and charts.
16
MEASUREMENT AND MODELING
The analysis which informs the report would use the
following techniques as appropriate:
Analysis of prudential indicators and ratios;
Financial Soundness Indicators;
Early Warning Systems (EWS), signaling and
discrete dependent variable approaches;
Vector Auto regression (VAR) frameworks;
Stress testing frameworks;
Judgemental analysis
17
INSTITUTIONAL ARRANGEMENTS
The CCMF is currently implementing a project on Financial
Risk Assessment in the Caribbean which is funded by the IDB.
The project is a collaboration with CARICOM central banks.
The project is designed to produce financial soundness
indicators for the region and develop appropriate
methodologies for monitoring financial stability.
This project will provide the CCMF with the capability to
prepare confidential brief, focused FSR memos, in addition to
the annual published FSR envisaged in the IDB project.
18
INSTITUTIONAL ARRANGEMENTS
The CCMF is in discussion with the CDB on
the need for financing for a second project, to
build the financial statistical data base needed,
in collaboration with regional central banks;
In order to implement both projects, CCMF will
need additional staff and funding.
19
QUARTERLY REGIONAL
CENTRAL BANK MEETING …
Would review main sources of vulnerability in the
regional financial system;
Would identify measures to strengthen the
resilience of the financial sector, and the lead
central bank to undertake remedial action. The
convening of colleges of regulators could be a
vehicle for such remedial action;
Would monitor progress;
Would serve to reduce the risk of systemic financial
failure.
20
CRISIS MANAGEMENT
In the event a crisis did emerge, an emergency meeting of
the governors would be triggered, to discuss the
appropriate response;
The governors meeting would initiate crisis response
irrespective of the source of the crisis, because of their
global responsibility for financial stability;
CCMF would provide this emergency meeting with the
most recent information relating to the affected institutions
and sub-sectors of the financial system;
The crisis meeting would designate the lead actor, and the
countries and regulators to be involved, depending on the
nature of the crisis. 21
RECOMMENDATIONS
Regional central banks and monetary authorities set up a
schedule of quarterly meetings on financial stability issues,
beginning when CCMF acquires the ability to prepare the
envisaged FSR memo;
The quarterly financial stability meeting would determine
actions to increase regional financial resilience, and would
monitor implementation;
All colleges of regulators, for all financial institutions, would
report to the monthly meeting;
The central bank group would also act as regional financial
crisis manager.
22
THE RECOMMENDED FRAMEWORK
Monthly meeting of Governors and
Heads of MA’s
Reports of Reports of
Monthly FS
colleges of CGBS, CAIR,
memo
regulators CGSR, CAPS
Info from National regulatory
central banks bodies for insurance,
and MA’s collective investment, etc
23
IS THERE ANY PRACTICAL ALTERNATIVE?
Extending the existing colleges of regulators does not address the
need for preventative measures, and it does not address the
deficiencies of data and analysis.
We do not want to wait until the next crisis erupts to have to take
remedial action in a data vacuum, as was the case with CL
Financial.
The recommended action helps to avert crises, by policy action to
increase resilience.
In the event of a crisis, central banks and monetary authorities will
have up to date data and analysis to inform their response, and to
reassure the public that they have the measure of the crisis and its
implications.
24
CRISIS MANAGEMENT
In the event that an entity faces
catastrophe, regulators need to be able to
respond.
Situation heightened if entity operates
cross-border.
Emphasises need for communication
channels to identify potential risks and
responses.
25
THANK YOU!
26
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