Chapter 12 Sequencing Financial Sector Reforms The development of a financial sector necessarily involves a wide range of policy actions and structural and institutional reforms.Those actions and reforms the design of of institutions;and the development of the associated legal,information,and liquidity 12 infrastructure.Given the multitude of policy actions and operational reforms to be imple- mented,the following question naturally arises:What principles and criteria should be considered in setting policy priorities among various policy and institutional reforms?All financial sector a hort term and then listing medium-and long-term structura Sequencing is the setting of priorities among financial sector measures,and the appro- priate sequencing and coordination of reforms is important for the following reasons: Inappropriate sequencing of reforms could cause excessive risk taking and financial instability .Limited institutional capacity necessarily requires some prioritization of reformele ments. Given the numerous policy and operational reforms in each area of financial policy setting priorities could facilitate and encourage the adoption of reforms;hence,this aspect of financial sector assessments is important. The sequencing of financial sector policies assum great im ortance when issues of ount op experience with financial crisis arly suggests t the mistaken sequencing of capita account liberalization contributed to the speed and severity of crisis in many countries
317 1 I H G F E D C B A 12 11 10 9 8 7 6 5 4 3 2 The development of a financial sector necessarily involves a wide range of policy actions, and structural and institutional reforms. Those actions and reforms cover the design of instruments and operational arrangements for markets; the licensing and restructuring of institutions; and the development of the associated legal, information, and liquidity infrastructure. Given the multitude of policy actions and operational reforms to be implemented, the following question naturally arises: What principles and criteria should be considered in setting policy priorities among various policy and institutional reforms? All financial sector assessments present the findings in priority, showing high-priority actions of some urgency for the short term and then listing medium- and long-term structural measures. How should such priorities be set? Sequencing is the setting of priorities among financial sector measures, and the appropriate sequencing and coordination of reforms is important for the following reasons: • Inappropriate sequencing of reforms could cause excessive risk taking and financial instability.1 • Limited institutional capacity necessarily requires some prioritization of reform elements. • Given the numerous policy and operational reforms in each area of financial policy, setting priorities could facilitate and encourage the adoption of reforms; hence, this aspect of financial sector assessments is important. The sequencing of financial sector policies assumes great importance when issues of capital account liberalization (capital account opening) are under consideration. Recent experience with financial crisis clearly suggests that the mistaken sequencing of capital account liberalization contributed to the speed and severity of crisis in many countries Chapter 12 Sequencing Financial Sector Reforms
Financial Sector Assessment:A Handbook (World Bank 2001).While there is no consensus on the net effect of capital accoun liberalization on growth,poverty,and volatility,there is consensus that (a)the effect of financial liberalization(financial opening)on growth depends on institutional quality: (b)the growth effects of financial liberalization could be large and statistically significant for a wide range of countries(in the middle range of incomes and institutional quality): and (c)the development of adequate institutional capacity appears to be an important and necessary precondition for coping with volatility and reaping net gains from liberal. ization (Obstfeld and Taylor 200).However,building institutic raise tional de sign and of the of reform strategies sand sequ cing-that to be understood (IMF 2003a).Thus,sequenci reforms is among the core elements of reaping the benefits of capital account opening.Key considerations in such sequencing are discussed in this chapter. 12.1 Development with Stability:The Role of Sequencing? Long-term economic growth hinges on sound financial institutions and deep financial markets to mobilize savings and allocate resources.The liberalization of financial insti- tutions,markets,and cross-border capital flows that are aimed at deepening financial intermediation and capital markets,however,increases risks that often result in financial distr .As ne ew institutions,instruments,and markets emerge,risks evolve in agn. The goal of the orderly sequencing of financial sector reform is to safeguard monetary and financial stability during financial liberalization and financial sector development 12 Strategies to develop local financial markets and intuitions must revolve around mitigat ing risks injected in the financial system as markets develop and become more sophisti- cated.Risks consist both of financial risks faced by financial intermediaries and market participants,and of macroeconomic risks that may be triggered by financial liberalization e.loss of monetary control or excessive interest rate volatility following liberalization ures).Thu developme measures would need to be bol. meast I and Financial sequenced to allow adequate b ment capacity and its associated infrastructure. oeldupofnkmanaege The different markets (e.g.,money,exchange,bond,equity,and derivatives)and various financial products and services (e.g.,credit to target groups and financial services to the poor)that need to be developed may be hierarchically ordered according to the types and complexity of risks to be managed when particular markets or products develop and expand,and on the scope of institutional preparations needed for good govemance set broad priorities am various fina ancial sector segments that need furthe develd key preparatory step in top row of figure 12. ent,and lustrates this key step b .The y pres ngvanios8oals6fg eve opment of market and financial services in a hierarchical order (see section 12.4 for a further discussion).This hierarchy primarily reflects the complexity of risks that need to be addressed and other short-and medium-term priorities that are country specific.In particular,building and strengthening short-term money markets and risk management 318
318 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 (World Bank 2001). While there is no consensus on the net effect of capital account liberalization on growth, poverty, and volatility, there is consensus that (a) the effect of financial liberalization (financial opening) on growth depends on institutional quality; (b) the growth effects of financial liberalization could be large and statistically significant for a wide range of countries (in the middle range of incomes and institutional quality); and (c) the development of adequate institutional capacity appears to be an important and necessary precondition for coping with volatility and reaping net gains from liberalization (Obstfeld and Taylor 2004). However, building institutions raises issues of institutional design and of the scope of reform strategies—priorities and sequencing—that need to be understood (IMF 2003a). Thus, sequencing of financial sector reforms is among the core elements of reaping the benefits of capital account opening. Key considerations in such sequencing are discussed in this chapter. 12.1 Development with Stability: The Role of Sequencing2 Long-term economic growth hinges on sound financial institutions and deep financial markets to mobilize savings and allocate resources. The liberalization of financial institutions, markets, and cross-border capital flows that are aimed at deepening financial intermediation and capital markets, however, increases risks that often result in financial distress and crisis. As new institutions, instruments, and markets emerge, risks evolve in complexity and magnitude. The goal of the orderly sequencing of financial sector reform is to safeguard monetary and financial stability during financial liberalization and financial sector development. Strategies to develop local financial markets and intuitions must revolve around mitigating risks injected in the financial system as markets develop and become more sophisticated. Risks consist both of financial risks faced by financial intermediaries and market participants, and of macroeconomic risks that may be triggered by financial liberalization (e.g., loss of monetary control or excessive interest rate volatility following liberalization measures). Thus, market development and liberalization measures would need to be bolstered by parallel measures to mitigate both financial and macroeconomic risks. Financial development policies should also be sequenced to allow adequate buildup of risk management capacity and its associated infrastructure. The different markets (e.g., money, exchange, bond, equity, and derivatives) and various financial products and services (e.g., credit to target groups and financial services to the poor) that need to be developed may be hierarchically ordered according to the types and complexity of risks to be managed when particular markets or products develop and expand, and on the scope of institutional preparations needed for good governance. This ordering helps set broad priorities among various financial sector segments that need further development, and it constitutes a key preparatory step in sequencing. The top row of figure 12.1 illustrates this key step by presenting various goals for the development of market and financial services in a hierarchical order (see section 12.4 for a further discussion). This hierarchy primarily reflects the complexity of risks that need to be addressed and other short- and medium-term priorities that are country specific. In particular, building and strengthening short-term money markets and risk management
Chapter 12:Sequencing Financial Sector Reforms Figure 12.1.Financial Development:Stylized Sequencing of Reforms evelopment go oney and Types of measures t5nmneouetaeg9n Risk mitigation 3 s macro isks Financial system infrastructure 6.Acm and 12 ndgeeeneareno 9.9 ectors Note:Arrows represent the listing measures under each theme Source:Karacadag,Sundararajan,and Elliott (2003). in such markets can nd can facilitate the development and ene -both fin d m of lon ger-term and mor sur naly cotesd suc er to provide marke ty of activ money markets that are based on treasury bills or other instruments.The development of government bond markets and of a structure of risk-free yields provides the benchmark 319
319 Chapter 12: Sequencing Financial Sector Reforms 1 I H G F E D C B A 12 11 10 9 8 7 6 5 4 3 2 in such markets can set the stage and can facilitate the development and effective risk management—both financial and macroeconomic—of longer-term and more-risky securities. Measures to develop government bond markets, such as promoting primary dealers to provide market-making services, are generally facilitated by the availability of active money markets that are based on treasury bills or other instruments. The development of government bond markets and of a structure of risk-free yields provides the benchmark Figure 12.1. Financial Development: Stylized Sequencing of Reforms Themes: Hierarchy of market and product development goals Types of measures Money and exchange market and related central bank reforms Government bond market and public debt management Banking and financial services to target groups Corporate debt and equity markets Derivatives and asset-backed securities Market and product development 1. Entry, instrument design, primary issuance, and access policies 2. Trading and settlement infrastructure Risk mitigation 3. Prudential supervision and market conduct oversight 4. Risk controls in the payment system 5. Macroprudential surveillance and macropolicies to manage volatility and systemic risks Financial system infrastructure 6. Accounting and disclosure standards 7. Insolvency regime and property rights 8. Internal information systems, transparency, and governance Capital account liberalization Note: Arrows represent the listing measures under each theme. Source: Karacadag, Sundararajan, and Elliott (2003). 9. Capital inflows and instruments and sectors 10. Capital outflows by instruments and sectors Financial institutions restructuring and recapitalization Figure 12.1. Financial Development: Stylized Sequencing of Reforms
Financial Sector Assessment:A Handbook for ther more-rkye and facilitating risk management.Measures to strengthen the access of target groups such as rural areas and small firms to financial services are medium-term goals that follow a strengthening of the basic banking,money,and government securities markets that help manage macroeconomic risks. domestic and external financial reforms thus need to be pursued in a manner that builds the capacity of regulators and financial institutions to monitor and manage the risks as iated with a wide ge of financial markets. P missible financial transactions investable instruments,and loanable funds,particularly the following cial stability hinges on establishing the Macroeconomic risk management requires effective instruments and institutions for monetary and exchange policy implementation,including well-functioning money,exchange,and government debt markets (Ishii and Habermeier,2002). Financial risk management depends on high standards in corporate governance, accounting,and disclosure,and in prudential regulation and supervision.Those utional reform re ritical to fos ering men nwhich capital mar et n grow witho mining financial stal ity De eloping ncial institutions is a critic omponent of buildi capita markets and financial risk-management capacity.Both bank and non-bank finan cial institutions are the key counterparties in financial markets.They often create and transmit risks.As such,establishing good governance structures-including effective internal controls and risk-management systems-in financial institutions 12 is among the most critical of market reforms. Reforms in financial system infrastructure-including the insolve cy regime rrights, and ace e and disclosure rudential regula and ionshouldstartg mlment the rfo d their r theum arly th e pr of ma et de elopm institution restructuring and good corporate governance. .Capital account liberalization and domestic financial reforms should be approached in an integrated manner (Johnston and Sundararajan 1999).Capital account liberalization by instruments and sectors should be sequenced in a manner that reinforces domestic financial liberalization and allows for institutional capacity building to manage the additional risks,as further explained in the next section. 12.2 Strengthening Access to Foreign Capital Effective strategie foreign capital can n,but the b ts of such a L law,shareholder protection,adequate prudential regulation and supervision,and finan- cial transparency are significant determinants of whether capital account openness-to enhance access to foreign capital-is beneficial or harmful. 320
320 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 for pricing corporate bonds and other more-risky securities and derivative products, thus facilitating risk management. Measures to strengthen the access of target groups such as rural areas and small firms to financial services are medium-term goals that follow a strengthening of the basic banking, money, and government securities markets that help manage macroeconomic risks. Domestic and external financial reforms thus need to be pursued in a manner that builds the capacity of regulators and financial institutions to monitor and manage the risks associated with a wide range of financial markets, permissible financial transactions, investable instruments, and loanable funds, particularly the following: • Capital market development-cum-financial stability hinges on establishing the institutional infrastructure for controlling both macroeconomic and financial risks. Macroeconomic risk management requires effective instruments and institutions for monetary and exchange policy implementation, including well-functioning money, exchange, and government debt markets (Ishii and Habermeier, 2002). Financial risk management depends on high standards in corporate governance, accounting, and disclosure, and in prudential regulation and supervision. Those institutional reforms are critical to fostering an environment in which capital markets can grow without undermining financial stability. • Developing sound financial institutions is a critical component of building capital markets and financial risk-management capacity. Both bank and non-bank financial institutions are the key counterparties in financial markets. They often create and transmit risks. As such, establishing good governance structures—including effective internal controls and risk-management systems—in financial institutions is among the most critical of market reforms. • Reforms in financial system infrastructure—including the insolvency regime, creditor rights, and accounting and disclosure—and prudential regulation and supervision should start early in the process of market development, given the time needed to implement the reforms and their importance to financial institution restructuring and good corporate governance. • Capital account liberalization and domestic financial reforms should be approached in an integrated manner (Johnston and Sundararajan 1999). Capital account liberalization by instruments and sectors should be sequenced in a manner that reinforces domestic financial liberalization and allows for institutional capacity building to manage the additional risks, as further explained in the next section. 12.2 Strengthening Access to Foreign Capital Effective strategies to enhance access to private foreign capital can provide a significant boost to economic growth and poverty reduction, but the benefits of such access can be realized only in proportion to a country’s level of institutional development.3 The rule of law, shareholder protection, adequate prudential regulation and supervision, and financial transparency are significant determinants of whether capital account openness—to enhance access to foreign capital—is beneficial or harmful
Chapter 12:Sequencing Financial Sector Reforms Enhanced access can be achieved by a combination of two approaches lendersoa domestic market by promoing for ig direct investment,foreign portfolio investment,bank fi ancing from abroad,and infrastructure financing through public-private partnerships .Facilitating access to international capital markets by domestic entities,a move that requires certain preconditions of policy environment and institutional pre paredness,including credit rating and investor relations. In addition to sectoral reforms,implementation of those approaches will require finan- cial sector policies that strengthen access to financial services domestically by developing rkerinsions,dince thar mpnvestment climte,ino nd nance;and that well de capital ount liberaliz Foreig can play an important role in developing local financial markets.Th timing and use of foreign capital,however,should be selected in a manner that supports its contribution to domestic market development and that limits the cost of additiona risk.Accordingly,foreign capital is often best used first to facilitate real sector and institu tional reforms.including banking and corporate sector restructuring through privatization (Johnston and Sundararajan 1999).Capital account liberalization should start with the liberalization of foreign direct investment,which helps import the superior technology and manag ment expertise needed to implement operational reforms in financial institu and c orations.For technology a nd o als o prom ote competition export growth salso can serve as an important source of der nd for local iberain portfolio investment in equity securities widens and diversifies the investor 12 base for local markets,and it enhances market discipline on issuers in particular and on macroeconomic management more generally (Sundararajan,Ariyoshi,and Otker-Robe 2002).Opening up to portfolio inflows,however,may increase volatility in market prices, at least for emerging-market economies in the short run(Kaminsky and Schmukler 2003) If one is to limit rollover risk,it is often better to liberalize market for longer-term debts before shorter-t n maturities How capital account liberalizat market development strategy or example,al instruments and sectors-with adequate prudenti can support money and exchange market development.Similarly,the well-planned opening of inflows of foreign portfolio investment can add to the liquidity of domestic equity markets Well-developed risk-management capacities of local investors and financial institu tions can help domestic financial markets benefit from foreign capital without subiecting markets to excessive stress.Cross-border capital flows,in essence,amplify the wide array of risks already prevailing in liberalized domestic financial marke including credit isks.Thus,the risk man agemer cities of fir nd do nestic inv .L e to be strong a enough toassess and manage higher degrees of ris in all ror ex cial institutions and corporations in South Korea and I ha nd (apl the Asia crisis)did not adequately assess and manage the risks associated with foreign bor
321 Chapter 12: Sequencing Financial Sector Reforms 1 I H G F E D C B A 12 11 10 9 8 7 6 5 4 3 2 Enhanced access can be achieved by a combination of two approaches: • Attracting foreign investors and lenders to a domestic market by promoting foreign direct investment, foreign portfolio investment, bank financing from abroad, and infrastructure financing through public–private partnerships. • Facilitating access to international capital markets by domestic entities, a move that requires certain preconditions of policy environment and institutional preparedness, including credit rating and investor relations. In addition to sectoral reforms, implementation of those approaches will require financial sector policies that strengthen access to financial services domestically by developing markets, institutions, and infrastructure; that improve investment climate, information provision, and governance; and that are well designed and properly sequenced for capital account liberalization. Foreign capital can play an important role in developing local financial markets. The timing and use of foreign capital, however, should be selected in a manner that supports its contribution to domestic market development and that limits the cost of additional risk. Accordingly, foreign capital is often best used first to facilitate real sector and institutional reforms, including banking and corporate sector restructuring through privatization (Johnston and Sundararajan 1999). Capital account liberalization should start with the liberalization of foreign direct investment, which helps import the superior technology and management expertise needed to implement operational reforms in financial institutions and corporations. Foreign technology and ownership also promote competition and export growth. Foreign investors also can serve as an important source of demand for local securities. Liberalizing portfolio investment in equity securities widens and diversifies the investor base for local markets, and it enhances market discipline on issuers in particular and on macroeconomic management more generally (Sundararajan, Ariyoshi, and Ötker-Robe 2002). Opening up to portfolio inflows, however, may increase volatility in market prices, at least for emerging-market economies in the short run (Kaminsky and Schmukler 2003). If one is to limit rollover risk, it is often better to liberalize market for longer-term debts before shorter-term maturities. However, capital account liberalization should closely complement the domestic market development strategy. For example, allowing short-term capital flows for certain instruments and sectors—with adequate prudential safeguards—can support money and exchange market development. Similarly, the well-planned opening of inflows of foreign portfolio investment can add to the liquidity of domestic equity markets. Well-developed risk-management capacities of local investors and financial institutions can help domestic financial markets benefit from foreign capital without subjecting markets to excessive stress. Cross-border capital flows, in essence, amplify the wide array of risks already prevailing in liberalized domestic financial markets, including credit, liquidity, market, interest rate, exchange rate, and operational risks. Thus, the risk management capacities of financial institutions and domestic investors have to be strong and sophisticated enough to assess and manage higher degrees of risk in all areas. For example, in hindsight, financial institutions and corporations in South Korea and Thailand (before the Asia crisis) did not adequately assess and manage the risks associated with foreign bor-