By the end of 1997, 78 bilateral MoUs had been signed between the EEA banking supervisory authorities. The key aims of MoUs are to establish a regular exchange of information between national supervisory authorities.
While the "gateways" for the exchange of information have been laid down in
Community legislation, MoUs provide a practical framework for communication to be carried out between supervisors. Moreover, MoUs define procedures and reciprocal commitments between pairs of EU supervisors related to the various parts of the supervisory process, such as establishment procedures and on-site examinations.

Finally, the multilateral mode is the one in which a group of supervisors works collectively as, say, a single consolidated supervisor.
Such a mode is required when the problems involved are area-wide. They may be area-wide for a number of reasons with regard to the institutions, or groups, involved: their dimension; their linkages with a number of different markets in various countries; the role they play in the payment system or in other "systemic" components of the market, etc. Multilateral co-operation can also enhance the quality of supervision by examining common macroeconomic influences on the banking system and common trends in the financial system that may not be revealed from the national perspective only.

Today, the Banking Supervision Committee is the key forum for multilateral co-operation. It is composed of representatives of the banking supervisory authorities of the EU countries, either forming part of the respective NCB or separate bodies. The Banking Supervision Committee's main functions are the promotion of a smooth exchange of information between the
Eurosystem and national supervisory authorities and co-operation among EU supervisory authorities. Another forum for dealing with the requirements of the multilateral mode is the Groupe de Contact, a group of EU banking supervisory authorities which, for many years, has discussed individual banking cases in a multilateral way, but at a lower organisational level than the high-level Banking Supervision Committee.

19. So far, the need to develop the multilateral mode has been relatively limited, as the emergence of a single banking market in the
European Union has been slow and the euro was not yet in place. Thus, the fact that the multilateral mode has not gone, for the moment, beyond periodic discussions among supervisors and occasional industry-wide analyses should not be a cause for concern.

I am convinced, however, that in the future the needs will change and the multilateral mode will have to deepen substantially. Over time such a mode will have to be structured to the point of providing the banking industry with a true and effective collective euro area supervisor. It will have to be enhanced to the full extent required for banking supervision in the euro area to be as prompt and effective as it is within a single nation.

There are no legal impediments to that. The existing legislation, whether Community or national, permits all the necessary steps to be made.
Information can be pooled; reporting requirements and examination practices can be developed and standardised; common databases can be created; joint teams can be formed; and analyses of developments across the whole banking system can be conducted. The Community legislation providing for the unconstrained exchange of confidential information between supervisors does not distinguish between bilateral and multilateral co-operation, but the common interpretation is that it covers both modes. It will be the task of the Banking Supervision Committee, for its part, to develop the multilateral mode among EU banking supervisors.

20. If the above concerns primarily the euro area supervisor, what about the euro area central banker, i.e. the Eurosystem? The euro area central banker has neither direct responsibility for supervising banks nor for bank stability. It is, however, no stranger in this land. It has a vital interest in a stable and efficient banking industry; it is, therefore, keen to see its action complemented with an effective conduct of the supervisory functions by the competent authorities; it needs a clear and precise knowledge of the state of the euro area's banking industry as a whole and of its major individual players; and it may have a role to play, as we shall see, in the management of crises.

For the Eurosystem, natural reference models are provided by the central banks of countries that apply the separation approach, for example:
Germany before the euro; the United Kingdom after the creation of the
Financial Services Authority; or Japan. In all these cases the central bank has a well-developed expertise in the micro and macro-prudential field; each distinctively plays a role in the macro-prudential field by addressing threats to the stability of the banking system and analysing the soundness of the structural features of the system. For their own purposes, these central banks also have precise and comprehensive information about the banks in their respective country. This is obtained either from performing practical supervisory duties, as in the case of the Bank of Japan or the
Bundesbank; or from the national supervisory authority; or through direct contacts with the banking industry, as in the case of the Bank of England.

The Banking Supervision Committee is in a good position to co-operate with the Eurosystem in the collection of information. Indeed, the so-called
BCCI Directive has removed the legal obstacles to the transmission of confidential information from competent supervisory authorities to "central banks and other bodies with a similar function in their capacity as monetary authorities". This includes national central banks and the ECB. Of course, the provision of supervisory information is voluntary and its development will have to be based on an agreed view of the central banking requirements the Eurosystem will have in this field.

V. CRISIS MANAGEMENT

21. In normal circumstances central banking and prudential supervision have an arm's length distance between them. In crisis situations, however, they need to act closely together, often in co- operation with other authorities as well. Charles Goodhart and Dirk
Schoenmaker have made here at the London School of Economics a valuable contribution to analysing the handling of major banking problems in the history of industrial countries. One of their conclusions is that, in most instances, central banks have indeed been involved. Banking problems are so close to monetary stability, payment system integrity and liquidity management that this finding hardly comes as a surprise. The advent of the euro will not, by itself, change this state of affairs.

22. When discussing crisis management, it should not be forgotten that, while central banks have a direct and unique role to play when the creation of central bank money is involved, this represents just one category of emergency action. Another category refers to the injection - by politically liable Finance Ministries - of taxpayers' money into ailing or insolvent credit institutions. There is also a third, market-based, category, consisting of the injection of private money by banks or other market participants. These three typologies of emergency action all require the involvement of policy-makers, but they must not be mixed up when evaluating the existing arrangements. Therefore, before discussing the much debated question of the lender-of-last-resort, let me briefly comment on the two, probably less controversial cases where central bankers are not the providers of extra funds.

23. First, the "private money solution". This market-based approach is clearly the preferable option, not just to save public funds and avoid imbalances in public finances, but also to reduce the moral hazard problem generated by public assistance to ailing institutions. Indeed, policy- makers are increasingly aware that the expectations of a helping hand can increase financial institutions' risk appetite in the first place. However, even when a market-based solution is possible, on the grounds of private interest, private parties may not be able to reach a solution for lack of information or co-ordination. Public authorities have therefore an active role to play for the market solution to materialise. The recent rescue package co-ordinated by the Federal Reserve Bank of New York to prevent the
LTCM hedge fund from collapsing is a good example of public intervention being used to achieve a private solution.

Acting as a "midwife" in brokering a private sector deal is not the only example of managing crises without injecting public funds. Banking supervisors have at their disposal a number of tools to intervene at the national level to limit losses and prevent insolvency when a bank faces difficulties. These tools include special audits, business restrictions and various reorganisation measures.

In the euro area, national supervisors and central banks will continue to be the key actors in the pursuit of market-based solutions to crises. The Eurosystem, or the Banking Supervision Committee, would become naturally involved whenever the relevance of the crisis required it.

24. Second, the "taxpayers' money solution". Taxpayers have been forced to shoulder banks' losses in the past, when public authorities felt that otherwise the failure of a large portion of a country's banking system or of a single significant institution would have disrupted financial stability and caused negative macroeconomic consequences. In such instances banks have been taken over by the state, or their bad assets have been transferred to a separate public entity to attract new private investment in the sound part of the otherwise failed banks. The US savings & loans crisis of the 1980s, the banking crises in Scandinavia in the early 1990s and the current banking crises in Japan and some East-Asian countries are examples of system-wide insolvency problems that have triggered taxpayers' support. Crйdit Lyonnais and Banco di Napoli are recent examples of public support to individual insolvency problems.

The introduction of the euro leaves crisis management actions involving taxpayers' money practically unaffected. The option of injecting equity or other funds remains available for the Member States, since these operations are not forbidden by the Treaty. Nevertheless, the European
Commission will be directly involved in scrutinising and authorising such actions, since any state aid must be compatible with the Community's competition legislation. This happened, for example, in the cases of Banco di Napoli and ‚[pic]Crйdit Lyonnais.

The handling of solvency crises is not within the competence of the national central banks nor that of the ECB, although national central banks are likely to be consulted, as they have been in the past.

25. Third, the "central bank money solution". This is the lender-of- last-resort issue that has brought the Eurosystem under vigorous criticism by distinguished academics and the IMF's Capital Markets Division of the
Research Department. The criticism has been that the alleged absence of a clear and transparent mechanism to act in an emergency raises doubts in the markets about the ability of the Eurosystem to handle crisis situations. It is said that the uncertainty generated by the present arrangements would entail new risks, including the possibility of investors requiring an additional risk premium at times of financial market volatility and, ultimately, of the credibility of EMU being damaged. Two examples of these concerns deserve an explicit mention. The IMF "Report on Capital Markets",
September 1998, stated that "it is unclear how a bank crisis would be handled under the current institutional framework …which is not likely to be sustainable". Similarly, the first report of the CEPR (Centre for
Economic Policy Research) on monitoring the ECB entitled "The ECB: Safe at
Any Speed?" expressly suggested that the Eurosystem lacks crisis management capacity and is too rigid to pass the A-Class test to keep the vehicle on the road at the first steep turn in financial market conditions in Europe.

26. My response to this criticism is threefold. To my mind, the criticism reflects a notion of lender-of-last-resort operations that is largely outdated; it underestimates the Eurosystem's capacity to act; and, finally, it represents too mechanistic a view of how a crisis is, and should be, managed in practice.

27. The notion of a central bank's lender-of-last-resort function dates back more than 120 years, to the time of Bagehot. This notion refers to emergency lending to institutions that, although solvent, suffer a rapid liquidity outflow due to a sudden collapse in depositors' confidence, i.e. a classic bank run. A bank could be exposed to depositors' panic even if solvent because of the limited amount of bank liquidity and an information asymmetry between the depositors and the bank concerning the quality of bank's assets that do not have a secondary market value.

Nowadays and in our industrial economies, runs may occur mainly in textbooks. They have little relevance in reality because, since Bagehot, many antidotes have been adopted: deposit insurance, the regulation of capital adequacy and large exposures, improved licensing and supervisory standards all contribute to the preservation of depositors' confidence and minimise the threat of a contagion from insolvent to solvent institutions.

A less unlikely case is a rapid outflow of uninsured interbank liabilities. However, since interbank counterparties are much better informed than depositors, this event would typically require the market to have a strong suspicion that the bank is actually insolvent. If such a suspicion were to be unfounded and not generalised, the width and depth of today's interbank market is such that other institutions would probably replace (possibly with the encouragement of the public authorities as described above) those which withdraw their funds. It should be noted, in this respect, that the emergence of the single euro money market lowers banks' liquidity risk, because the number of possible sources of funds is now considerably larger than in the past.

Given all of these contingencies, the probability that a modern bank is solvent, but illiquid, and at the same time lacks sufficient collateral to obtain regular central bank funding, is, in my view, quite small. The textbook case for emergency liquidity assistance to individual solvent institutions has, as a matter of fact, been a most rare event in industrial countries over the past decades.

28. What if this rare event were nevertheless to occur and cause a systemic threat? The clear answer is that the euro area authorities would have the necessary capacity to act. This is not only my judgement, but also that of the Eurosystem, whose decision-making bodies have, as you can imagine, carefully discussed the matter. I am not saying that we are, or shall be, infallible; no one can claim such a divine quality. I am saying that there are neither legal-cum-institutional, nor organisational, nor intellectual impediments to acting when needed. In stating this, I am aware that central banks may be the only source of immediate and adequate funds when a crisis requires swift action, while solvency remains an issue and failure to act could threaten the stability of the financial system.

In these circumstances the various national arrangements would continue to apply, including those concerning the access of central banks to supervisors' confidential information. As is well known, such arrangements differ somewhat from country to country.

Страницы: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21