Mandatory Financial Stability Assessments Under The Financial Sector Assessment Program Update

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

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.

This background paper reviews the development of the scope of financial stability assessments under the FSAP since the 2014 FSAP Review. The paper summarizes past experiences of such adaptation and observed trends with respect to the coverage of specific topics and then discusses possible directions to adjust the scope of future FSAPs over the next five years given the likely changes in the financial stability landscape. The paper also discusses collaboration with the World Bank as it pertains to the scope of financial stability assessments. It does not examine issues such as analytical approaches, participation, and resources, which are covered elsewhere in the FSAP Review.

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.

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.

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 past five years have seen an expansion of the scope of FSAPs to assess countries' macroprudential policy (MaPP) frameworks. This note documents this increase and offers some suggestions on how the treatment of MaPP issues in FSAPs can be further strengthened and better integrated into the overall financial stability assessment.

A key criterion for judging the success of the Financial Sector Assessment Program (FSAP) is the extent to which the program has enhanced the IMF’s engagement with policymakers and influenced country policies. This reflects the fact that achieving one of the program’s key objectives—reducing the frequency and severity of financial crises—rests on its ability to encourage policy action by country authorities, either directly or through other bilateral and multilateral activities. The “traction” of FSAPs thus reflects the degree to which the program is seen as useful by the authorities and the effect it has in shaping the domestic policy agenda. And the impact that the FSAP may have on wider domestic and international audiences.