金融部门评估规划（Financial Sector Assessment）手册：Chapter 10 Assessing Information and Governance Infrastructure

Chapter 10 Assessing Information and Governance Infrastructure 10 sion.It refers(a)to the legal and institutional arrangements and structures that affect the quality,availability,and transparency of information on monetary and financial condi- tions and policies at various levels and (b)to the incentives and organizational structures to set and implement policies by regulators,the regulated institutions,and their coun- erparties.The info ormation inf cure includes (a)the framework for monetar nd financial policy transparency (discuss in section 10.1)(b)the ac contingandaud framework that helps to define and validate the information that is disclosed to the public and the regulatory authorities (discussed in section 10.2);and (c)the arrangements to compile,process,and share information on financial conditions and credit exposures of borrowers and other issuers of financial claims(credit-reporting and financial information services,discussed in section 10.3). The ents for financial and non-financial firms that are publicly listed and traded are of particular interest because they directly affect the functioningof the financial markets where their securities are traded.The corporate governance arrange- ments and the Organisation for Economic Co-operation and Development(OECD)prin- ciples of corporate governance are discussed in section 10.4.The governance of financial firms and of financial sector regulators is covered in different degrees of detail in the standards for financial sector supervision.Selected aspects of financial sector governance are also highlighted in that section. A key aspect of financial institutions'govemnance is the institution's disclosure prac- tices,which are determined in part by the supervisory framework,including the listing requirements by securities regulators,and by the company laws.The appropriate scope of

241 1 I H G F E D C B A 12 11 10 9 8 7 6 5 4 3 2 Information and governance infrastructure for finance provides the foundation for finan￾cial development and effective market discipline, and it helps to reinforce official supervi￾sion. It refers (a) to the legal and institutional arrangements and structures that affect the quality, availability, and transparency of information on monetary and financial condi￾tions and policies at various levels and (b) to the incentives and organizational structures to set and implement policies by regulators, the regulated institutions, and their coun￾terparties. The information infrastructure includes (a) the framework for monetary and financial policy transparency (discussed in section 10.1); (b) the accounting and auditing framework that helps to define and validate the information that is disclosed to the public and the regulatory authorities (discussed in section 10.2); and (c) the arrangements to compile, process, and share information on financial conditions and credit exposures of borrowers and other issuers of financial claims (credit-reporting and financial information services, discussed in section 10.3). The governance arrangements for financial and non-financial firms that are publicly listed and traded are of particular interest because they directly affect the functioning of the financial markets where their securities are traded. The corporate governance arrange￾ments and the Organisation for Economic Co-operation and Development (OECD) prin￾ciples of corporate governance are discussed in section 10.4. The governance of financial firms and of financial sector regulators is covered in different degrees of detail in the standards for financial sector supervision. Selected aspects of financial sector governance are also highlighted in that section. A key aspect of financial institutions’ governance is the institution’s disclosure prac￾tices, which are determined in part by the supervisory framework, including the listing requirements by securities regulators, and by the company laws. The appropriate scope of Chapter 10 Assessing Information and Governance Infrastructure

Financial Sector Assessment a Handbook financial institutions'disclosure,including the disclosure standards under the New Basel Capital Ac cord,isdi cussed in section 10.5. he disclosure and govemance arrangeme context,there are significant linkages among the governance arrangements for the regula- tory agencies (including the central bank),the regulated entities,and the non-financial sector.This governance nexus should be taken into account in assessing the overall infor- mation and governance infrastructure.I 10.1 Monetary and Financial Policy Transparency Good transpar ractices for central banks and financial agencies in their conduct of policies can contribute policy effectivene policy consistency and good governance.The scope of good transparency practices and the issues in assessing their adequacy and effectiveness are discussed in this section. 10.1.1 Code of Good Practices The concept of transparency of monetary and financial policies refers to an environ- 10 ment in which the objectives of the policy;the policy's legal,institutional,and economic framework;the policy decisions and their rationale;the data and information related to monetary and financial policies;and the terms of agencies'accountability are provided to the public on an understandable,accessible,and timely basis.The Code of Good Practice parency practices for centra and financial agenci es in th of monetary and financial policies.The MFP Code was developed by the IMF in 1999.This document is a distillation of concepts and practices that are already in use and for which there is a record of experience.Together with the Supporting Document to the Code of Good Practices on Transparency in Monetary and Financial Policies(Supporting Document;IMF 2000b) the various guidance notes,and the specific templates,the MFP Code serves as the refer- ence material for assessing transpare practices in monetary and financial policies. spare y of m nd f inancial policies con s to policy effective fciareehebe e swarene ment to meeting the goals,can contribute to good policy making and can improve the effective ness of policies.Transparency in the mandate,as well as the rules and procedures in the operations of monetary and financial agencies,helps to ensure consistency in cases where conflicts might arise between or within government units.Good governance calls for central banks and financial agencies to be accountable,particularly where the monetary and financial authorities are granted a high degree of auto omy.In the case of moneta ansparency eved by the secto with a clea scription of the consid tio that guide monetary polic ensure that market expectations can be formed more efficiently and,thereby,make the monetary policy transmission mechanism generally more effective.Through good 242

242 Financial Sector Assessment: A Handbook 1 I H G F E D C B A 12 11 10 9 8 7 6 5 4 3 2 financial institutions’ disclosure, including the disclosure standards under the New Basel Capital Accord, is discussed in section 10.5. The disclosure and governance arrangements for financial and non-financial sectors should be seen in the broader context of public sector governance. Within this broader context, there are significant linkages among the governance arrangements for the regula￾tory agencies (including the central bank), the regulated entities, and the non-financial sector. This governance nexus should be taken into account in assessing the overall infor￾mation and governance infrastructure.1 10.1 Monetary and Financial Policy Transparency Good transparency practices for central banks and financial agencies in their conduct of monetary and financial policies can contribute policy effectiveness, policy consistency and good governance. The scope of good transparency practices and the issues in assessing their adequacy and effectiveness are discussed in this section. 10.1.1 Code of Good Practices The concept of transparency of monetary and financial policies refers to an environ￾ment in which the objectives of the policy; the policy’s legal, institutional, and economic framework; the policy decisions and their rationale; the data and information related to monetary and financial policies; and the terms of agencies’ accountability are provided to the public on an understandable, accessible, and timely basis. The Code of Good Practices on Transparency in Monetary and Financial Policies (MFP Code) identifies desirable trans￾parency practices for central banks and financial agencies in their conduct of monetary and financial policies. The MFP Code was developed by the IMF in 1999.2 This document is a distillation of concepts and practices that are already in use and for which there is a record of experience. Together with the Supporting Document to the Code of Good Practices on Transparency in Monetary and Financial Policies (Supporting Document; IMF 2000b), the various guidance notes, and the specific templates, the MFP Code serves as the refer￾ence material for assessing transparency practices in monetary and financial policies. The transparency of monetary and financial policies contributes to policy effective￾ness, facilitates policy consistency, and strengthens governance. The public’s awareness of the goals and instruments of policy, as well as the authorities’ credible commitment to meeting the goals, can contribute to good policy making and can improve the effective￾ness of policies. Transparency in the mandate, as well as the rules and procedures in the operations of monetary and financial agencies, helps to ensure consistency in cases where conflicts might arise between or within government units. Good governance calls for central banks and financial agencies to be accountable, particularly where the monetary and financial authorities are granted a high degree of autonomy. In the case of monetary policy, transparency about policy process—achieved by providing the private sector with a clear description of the considerations that guide monetary policy decisions—helps ensure that market expectations can be formed more efficiently and, thereby, makes the monetary policy transmission mechanism generally more effective. Through good

Chapter 10:Assessing Information and Govemance transparency practices,the central bank can establish a mechanism for strengthening its credibility by matching its actions to its public statements.Similarly,transparency of a regulatory agency's mandate,operations,and regulatory processes is essential in establish. ing the credibility and effectiveness of financial sector oversight.Although credibility is achieved by meeting the stated objectives and responsibilities,transparency may also limit self-interest on the part of the regulators and may foster increased commitment of regulated firms to regulatory compliance,prudent behavior,proper risk management,and The MFP Code lists 17 good practices on transparency of monetary policies by the central bank and 20 good practices on transparency of financial practices.The four groups of transparency practices and a summary description of each practice are presented in Annex 10.A.The four groups are(1)clarity of roles,responsi. bilities,and objectives of central banks and financial agencies;(2)the processes for the formulating and reporting of monetary policy decisions by the central bank and of finan. cial policies by fin ial policie and (4) and financial I agencies 10.1.2 Assessment Methodology and Assessment Experience 10 The objectives of MFP transparency assessments are to review the effectiveness of current practices and to recommend desirable transparency practices.I he assessments,therefore, are designed to Allow the authorities to evaluate the transparency of their monetary policy and their financial supervisory and regulatory frameworks. .Identify and,where appropriate,recommend desirable transparency practices for central banks and financial agencies. .Provide input into the overall asse ssment of the vulnerabilities of a country's mon ntify the evelopmental needs c a country pert ining spe cifically to trans parency issues and to assist in making informed policy decisions about the reforms needed .Provide input on the extent to which transparency practices contribute to policy effectiveness and to monetary and financial stability. The mep code is broad and takes into account the varied institutional and legal frameworks that are found in many countries across various stages of financial develop ment Conse of hich ently,the w of ti re as well as is apb oplied and achieved-in ming andn differ. ing different institutional arrangements and legal litions. ssessments should not be conducted ina mechanistic way because practical policy considerations may require that some disclosures not be made in certain contexts. In particular,benefits of transparency practices have to be weighed against the poten- tial costs,and it may be appropriate to limit the extent of transparency.For example 243

243 Chapter 10: Assessing Information and Governance Infrastructure 1 I H G F E D C B A 12 11 10 9 8 7 6 5 4 3 2 transparency practices, the central bank can establish a mechanism for strengthening its credibility by matching its actions to its public statements. Similarly, transparency of a regulatory agency’s mandate, operations, and regulatory processes is essential in establish￾ing the credibility and effectiveness of financial sector oversight. Although credibility is achieved by meeting the stated objectives and responsibilities, transparency may also limit self-interest on the part of the regulators and may foster increased commitment of regulated firms to regulatory compliance, prudent behavior, proper risk management, and internal control. The MFP Code lists 17 good practices on transparency of monetary policies by the central bank and 20 good practices on transparency of financial policies, all grouped into four categories. Many of the good practices are further divided into more detailed practices. The four groups of transparency practices and a summary description of each practice are presented in Annex 10.A. The four groups are (1) clarity of roles, responsi￾bilities, and objectives of central banks and financial agencies; (2) the processes for the formulating and reporting of monetary policy decisions by the central bank and of finan￾cial policies by financial agencies; (3) public availability of information on monetary and financial policies; and (4) accountability and assurances of integrity by the central bank and financial agencies. 10.1.2 Assessment Methodology and Assessment Experience The objectives of MFP transparency assessments are to review the effectiveness of current practices and to recommend desirable transparency practices. The assessments, therefore, are designed to • Allow the authorities to evaluate the transparency of their monetary policy and their financial supervisory and regulatory frameworks. • Identify and, where appropriate, recommend desirable transparency practices for central banks and financial agencies. • Provide input into the overall assessment of the vulnerabilities of a country’s mon￾etary and financial system. • Help identify the developmental needs of a country pertaining specifically to trans￾parency issues and to assist in making informed policy decisions about the reforms needed. • Provide input on the extent to which transparency practices contribute to policy effectiveness and to monetary and financial stability. The MFP Code is broad and takes into account the varied institutional and legal frameworks that are found in many countries across various stages of financial develop￾ment. Consequently, the ways in which transparency is applied and achieved—in terms of timing and manner of disclosure as well as the content of reports—may differ, reflect￾ing different institutional arrangements and legal traditions. Assessments should not be conducted in a mechanistic way because practical policy considerations may require that some disclosures not be made in certain contexts. In particular, benefits of transparency practices have to be weighed against the poten￾tial costs, and it may be appropriate to limit the extent of transparency. For example

Financial Sector Assessment a Handbook extensive disclosure mentsabou intemal and exchange market operations might disrupt markets,constrain the free flow of discussion by policy makers,or prevent the adoption of contingency plans.Thus,there are circumstances in which it would not be appropriate for central banks to disclose their near-term monetary and exchange rate policy implementation tactics or to provide detailed information on foreign exchange operations.Similarly,there may be good reasons for the central bank (and financiala es)not to nake public speci emergency lending.Ho wever,th broa principles and procedures gov sions on emergency lending could be established and made transparent while maintaining "constructive ambiguity"about their applicability in specific situations (see chapter 5. section 5.2.1).However,limiting transparency in selected areas needs to be seen in the offer judgment on the e appropriatenes desirability of specific monetary and financial policies or frameworks that countries should adopt. The assessment of observance of the MFP Code should draw on a wide range of infor mation and should focus on the degree and means of disclosure to the public,as well as on the effect of disclosure practices on a policy's effectiveness.The sources of information needed for the as typically include relevant laws regulations,and instruction well as other documentation (reports,studies,public statements, unpublis 10 guidelines,directives,and assessments);counterparty agencies and officials with whom assessment-related discussions are held:meetings with other domestic authorities:any relevant government or industry associations(such as bankers'associations,auditors,and accountants):and key market participants and analysts who draw on the information disclosed.The r the me nt con of exami for each practice in the MFP co e,the various content of disclosure,and modes of disclosure.In addition,a fifth dimension-clarity and comprehensibility of transparency-is also examined.The content,clarity,and accessi. bility of the information that is disclosed are what transforms"disclosure"into"transpar. cy."An assessment of those five dim ensions is based on a broad qualitative judgm drawing on counry practices and is no tbased on any specified list essment cr Illustrative country practices are summarized in the Supporting Document,which also provides two-or three-part explanations of each transparency practice: ."Explanation and rationale"elaborates on what is meant and why it is desirable. ."Application"indicates where and how the practices are implemented,with some ntifcationandwhereaplicablewihe ation con derations"deals with practical cons and costs,intended audience,domestic versus international dimensions-where relevant.The supporting document also provides a list of references- -academic studies as well as official documents-on transparency and accountability issues. The qualitative judgment of various dimensions of transparency can be informed by the supporting document,and this judgmer classify the de ervance of each practice into five categories:observed,broadly observed,partly observed,non-observed,and not applicable.Detailed guidance on the procedures 244

244 Financial Sector Assessment: A Handbook 1 I H G F E D C B A 12 11 10 9 8 7 6 5 4 3 2 extensive disclosure requirements about internal policy discussion on money and exchange market operations might disrupt markets, constrain the free flow of discussion by policy makers, or prevent the adoption of contingency plans. Thus, there are circumstances in which it would not be appropriate for central banks to disclose their near-term monetary and exchange rate policy implementation tactics or to provide detailed information on foreign exchange operations. Similarly, there may be good reasons for the central bank (and financial agencies) not to make public specific contingency plans, including possible emergency lending. However, the broad principles and procedures governing the deci￾sions on emergency lending could be established and made transparent while maintaining “constructive ambiguity” about their applicability in specific situations (see chapter 5, section 5.2.1). However, limiting transparency in selected areas needs to be seen in the context of a generally transparent environment. Also, the MFP Code is not designed to offer judgment on the appropriateness or desirability of specific monetary and financial policies or frameworks that countries should adopt. The assessment of observance of the MFP Code should draw on a wide range of infor￾mation and should focus on the degree and means of disclosure to the public, as well as on the effect of disclosure practices on a policy’s effectiveness. The sources of information needed for the assessment typically include relevant laws, regulations, and instructions, as well as other documentation (reports, studies, public statements, Web sites, unpublished guidelines, directives, and assessments); counterparty agencies and officials with whom assessment-related discussions are held; meetings with other domestic authorities; any relevant government or industry associations (such as bankers’ associations, auditors, and accountants); and key market participants and analysts who draw on the information disclosed. The methodology for the assessment consists of examining, for each practice in the MFP code, the various forms of disclosure used, frequency of disclosures, quality or content of disclosure, and modes of disclosure. In addition, a fifth dimension—clarity and comprehensibility of transparency—is also examined. The content, clarity, and accessi￾bility of the information that is disclosed are what transforms “disclosure” into “transpar￾ency.” An assessment of those five dimensions is based on a broad qualitative judgment drawing on country practices and is not based on any specified list of assessment criteria. Illustrative country practices are summarized in the Supporting Document,3 which also provides two- or three-part explanations of each transparency practice: • “Explanation and rationale” elaborates on what is meant and why it is desirable. • “Application” indicates where and how the practices are implemented, with some quantification and, where applicable, with some country examples. • “Implementation considerations” deals with practical considerations—benefits and costs, intended audience, domestic versus international dimensions—where relevant. The supporting document also provides a list of references—academic studies as well as official documents—on transparency and accountability issues. The qualitative judgment of various dimensions of transparency can be informed by the supporting document, and this judgment is used to classify the degree of observance of each practice into five categories: observed, broadly observed, partly observed, non-observed, and not applicable. Detailed guidance on the procedures

Chapter 10:Assessing Information and Govemance tions in conducting the assesments are available in the .A supplementary document providing case studies for 15 countries is under prepa- ration. So far,the IMF Executive Board has conducted two reviews of experiences with assess ments of the MFP Code,drawing on MFP Code assessments for 57 countries.In general the two reviews indicated a high level of observance of transparency practices among the countries reviewed.Observance was strongest with respect to the public availability of information on monetary and financial policies.Many central banks and financial ncies are making of va ous channels of the public's acce In bar nking su rvision ar d pa yment syste in practices relating to clarity of the roles,responsibilities,an ransparency practic es with respect to the accountability an assurance of integrity of the central banks and financial agencies continue to be a challenge for many of the countries (see boxes 10.1 and 10.2).This finding also has been borne out in other Fund initiatives such as the Safeguards Assessments (IMF 2002)and in the assessments of Special Data Dissemination Standards(SDDS)(IMF 2003).Among all financial sectors banking supervisory agencies had the most-developed transparency practices whereas insurance regulatory ag gencies had the least-developed transparency practices. Standard-setting bodies have increasingly includedt y-related criteria in 10 their individual st ndards and codes.The lAIS standards emphasize the need for trans supr AIS C The Cr of the MFP Payment Systems (see Chapter 11 for ref ces and discussion) or en cave oversigh of such payment systems by the central bank and,consistent with the MFP code,calls for the central bank to define clearly its payment system objectives and to disclose publicly its role and major policies with respect to systemically important payment systems.The cov erage of transparency issues in regulatory standards is,however,rather uneven,and there have been recent efforts to specify transparency practices of regulatory agencies in greater detail as a component of good regulatory governance of those agencies(components of good regulatory governance consist of independence,accountability,transparency,and integrity). 10.2 Accounting and Auditing Assessments of accounting and auditing standards isa key t of the evaluation of ntry's fi market infr cture(th pillar of the Fin cia vernance core component of go corporate governance is an accurate disclosure that is based on high-quality acc ounting an auditing standards.A comprehensive assessment of those standards presents the strengths and weaknesses of accounting and auditing frameworks.The assessment also analyzes the framework's quality and enforcement,as well as its potential success in changing the effectiveness of supervision and the soundness of the financial system.A sound account- 245

245 Chapter 10: Assessing Information and Governance Infrastructure 1 I H G F E D C B A 12 11 10 9 8 7 6 5 4 3 2 and practical considerations in conducting the assessments are available in the guidance note (IMF 2000) for assessing the code. • A supplementary document providing case studies for 15 countries is under prepa￾ration. So far, the IMF Executive Board has conducted two reviews of experiences with assess￾ments of the MFP Code, drawing on MFP Code assessments for 57 countries.4 In general, the two reviews indicated a high level of observance of transparency practices among the countries reviewed. Observance was strongest with respect to the public availability of information on monetary and financial policies. Many central banks and financial agencies are making more effective use of various channels of communication to increase the public’s access to information. In banking supervision and payment system oversight, transparency was weak in practices relating to clarity of the roles, responsibilities, and objectives of the institutions. Transparency practices with respect to the accountability and assurance of integrity of the central banks and financial agencies continue to be a challenge for many of the countries (see boxes 10.1 and 10.2). This finding also has been borne out in other Fund initiatives such as the Safeguards Assessments (IMF 2002) and in the assessments of Special Data Dissemination Standards (SDDS) (IMF 2003). Among all financial sectors, banking supervisory agencies had the most-developed transparency practices whereas insurance regulatory agencies had the least-developed transparency practices. Standard-setting bodies have increasingly included transparency-related criteria in their individual standards and codes. The IAIS standards emphasize the need for trans￾parency by the supervisory agency, and various transparency practices of the MFP Code are embedded in the IAIS Core Principles. The Core Principles for Systemically Important Payment Systems (see Chapter 11 for references and discussion) calls for effective oversight of such payment systems by the central bank and, consistent with the MFP code, calls for the central bank to define clearly its payment system objectives and to disclose publicly its role and major policies with respect to systemically important payment systems. The cov￾erage of transparency issues in regulatory standards is, however, rather uneven, and there have been recent efforts to specify transparency practices of regulatory agencies in greater detail as a component of good regulatory governance of those agencies (components of good regulatory governance consist of independence, accountability, transparency, and integrity). 10.2 Accounting and Auditing Assessments An assessment of accounting and auditing standards is a key part of the evaluation of robustness of a country’s financial market infrastructure (the third pillar of the Financial Sector Assessment) and includes financial sector governance. A core component of good corporate governance is an accurate disclosure that is based on high-quality accounting and auditing standards. A comprehensive assessment of those standards presents the strengths and weaknesses of accounting and auditing frameworks. The assessment also analyzes the framework’s quality and enforcement, as well as its potential success in changing the effectiveness of supervision and the soundness of the financial system. A sound account-