Integrating Stability Assessments Under The Financial Sector Assessment Program Into Article Iv Surveillance

Integration of financial sector issues into bilateral surveillance has been a long-standing challenge. Financial stability is a key component of the domestic and external stability of members and is important for the promotion of the “stable system of exchange rates” envisaged under Article IV. But although financial sector issues and policies are at the core of the Fund’s surveillance mandate, their effective integration has been a challenge. To address this challenge, it is proposed to adopt a more risk-based approach to financial sector surveillance by making FSAP stability assessments part of Article IV surveillance for members with systemically important financial sectors.

Recognizing the important impact that a member’s domestic economic and financial policies can have on systemic stability, Article IV of the IMF’s Articles of Agreement establishes obligations for members respecting the conduct of these policies, including their financial sector policies. An examination of members’ financial sector policies is important in all cases of bilateral surveillance, and three quarters of the Fund’s membership has already undergone a financial stability assessment. With this Decision, the Fund decides that, taking into account the framework described above and the overall purpose of surveillance, heightened scrutiny should be given in bilateral surveillance to the financial sector policies of those members whose financial sectors are systemically important, given the risk that domestic and external instability in such countries will lead to particularly disruptive exchange rate movements and undermine systemic financial and economic stability. The mandatory financial stability assessments undertaken under this Decision will consist of the following elements: a) an evaluation of the source, probability, and potential impact of the main risks to macro-financial stability in the near-term for the relevant financial sector; b) an assessment of the authorities’ financial stability policy framework; and c) an assessment of the authorities’ capacity to manage and resolve a financial crisis should the risks materialize.

This paper presents the staff analysis underpinning two central elements of the proposal to make financial stability assessments under the FSAP mandatory for members with systemically important financial sectors: the definition of systemic importance used in the paper and the methodology for identifying members with systemically important financial sectors (Section II); and the review of the literature and industry practices that form the basis for the staff proposal to conduct these mandatory financial stability assessments at a frequency of about three years (Section III).

In September 2010, the Executive Board made financial stability assessments under the Financial Sector Assessment program (FSAP) a regular and mandatory part of bilateral surveillance under Article IV for jurisdictions with systemically important financial sectors. This decision recognized that although financial sector issues were at the core of the Fund’s surveillance mandate, the FSAP as designed in the late 1990s had severe limitations as a tool. Voluntary participation, the low frequency of assessments, and their very broad coverage (particularly in emerging market and developing countries, where assessments are typically conducted jointly with the World Bank) limited the usefulness of the FSAP for surveillance. Building on the revamp of the FSAP during the 2009 program review that delineated the institutional responsibilities of the Fund and the World Bank and defined the content of the stability assessment under the FSAP, the Executive Board took the next step in 2010 to make these stability assessments mandatory every five years for members with systemically important financial sectors

Improving the quality of the Fund’s financial sector analysis and integrating it with surveillance is a major undertaking that involves action on several fronts. The 2007 Financial Sector Taskforce Report (“Taskforce Report”) provided a comprehensive assessment of the status of financial sector analysis in the Fund and established a broad organizing framework on how to integrate better finance into Article IV surveillance. The 2008 Triennial Surveillance Review (TSR) and supplements developed this theme further, and the Board’s ensuing Statement on Surveillance Priorities made the integration of macroeconomic and financial sector surveillance one of the four overarching operational priorities for Fund surveillance.

The Financial Sector Assessment Program (FSAP), established in 1999, is an in-depth assessment of a country’s financial sector. It is an important element of the Fund’s surveillance and provides input to the Article IV consultations. In developing and emerging market countries, FSAP assessments are usually conducted jointly with the World Bank and include two components: a financial stability assessment (the main responsibility of the Fund) and a financial development assessment (the main responsibility of the World Bank). Each FSAP concludes with the preparation of a Financial System Stability Assessment (FSSA), which focuses on issues of relevance to IMF surveillance and is discussed by the IMF Executive Board normally together with the country’s Article IV staff report. Since the program’s inception, 144 member countries have requested and undergone FSAPs, most of them more than once. In recent years, the Fund has been conducting 14–16 FSAPs per year at an annual cost of US$13–15 million. The last review of the FSAP in 2009, in the aftermath of the global financial crisis, introduced a number of far-reaching reforms that have clarified the responsibilities of the Fund and the Bank in developing and emerging market countries, where assessments usually take place jointly, established institutional accountability, strengthened the analytical focus and coverage of FSAPs, and introduced the option of modular assessments that has afforded the Fund and national authorities greater flexibility on the scope and timing of assessments. In 2010, the financial stability assessment under the FSAP in 25 jurisdictions with financial sectors deemed by the Fund to be systemically important became a mandatory part of Article IV surveillance, expected to take place every five years. The list was expanded to 29 jurisdictions in 2013. For all other jurisdictions, FSAP participation continues to be voluntary.In 2010, the financial stability assessment under the FSAP in 25 jurisdictions with financial sectors deemed by the Fund to be systemically important became a mandatory part of Article IV surveillance, expected to take place every five years. The list was expanded to 29 jurisdictions in 2013. For all other jurisdictions, FSAP participation continues to be voluntary.

The IEO report provides a welcome opportunity to reflect on the IMF’s initiatives to expand and deepen its financial surveillance work in response to the Global Financial Crisis. In order to improve the relevance and traction of bilateral financial surveillance, the IMF needs to deepen financial and macrofinancial analysis, particularly in Article IV consultations, including by taking practical steps to better integrate Financial Sector Assessment Program analysis in Article IV consultations and by increasing financial skills and expertise among staff. The IMF should continue to work to enhance the impact of IMF multilateral surveillance by increasing rigor and transparency, and by deepening collaboration with international partners. On scaling-up the IMF’s work with the international regulatory agencies to assess the impact of reforms, the IMF has undertaken several assessments of different aspects of the reforms following the 2012 Financial Surveillance Strategy. Some of these have been conducted jointly with the Standard Setting Bodies.

The Financial Sector Assessment Program (FSAP) Provides In-Depth Assessments Of Financial Sectors. FSAPs Are Usually Conducted Jointly With The World Bank In Emerging Market And Developing Economies And By The Fund Alone In Advanced Economies. Fsaps Provide Valuable Analysis And Policy Recommendations For Surveillance And Capacity Development. Since The Program’s Inception, 157 Fund Members Have Undergone Individual Or Regional Fsaps. In Recent Years, The Fund Has Been Conducting 12–14 Fsaps Per Year At A Cost Of About 3 Percent Of The Fund’s Direct Spending.