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Burcu Hacibedel
and
Mariusz Jarmuzek
Denmark’s nonbank financial institutions (NBFI) sector has substantially increased in size since the Global Financial Crisis (GFC), becoming an important part of the financial system. Systemic risk associated with NBFIs have been contained but warrants close monitoring, especially regarding leverage, liquidity buffers, and interconnectedness. There are important mitigating factors that reduce systemic risk stemming from NBFIs in Denmark. Strengthening of systemic risk assessment and policy framework for NBFIs is warranted and could include developing a systemic risk assessment framework covering both banks and NBFIs and an ensuing system-wide stress testing framework.
International Monetary Fund. Monetary and Capital Markets Department
While domestic money laundering (ML) threats are well understood by the authorities, Ireland faces significant and increasing threats from foreign criminal proceeds. As a growing international financial center,1 Ireland is exposed to inherent transnational money laundering and terrorist financing (ML/TF) related risks. The ML risks facing Ireland include illicit proceeds from foreign crimes (e.g., corruption, tax crimes). Retail and international banks, trust and company service providers (TCSPs),2 lawyers, and accountants are medium to high-risk for ML, while virtual asset service providers (VASPs) pose emerging risks. Brexit, the recent move of international banks to Dublin, and the COVID-19 pandemic increased the money laundering risks faced by Ireland. The Central Bank of Ireland (Central Bank) nevertheless has demonstrated a deep and robust experience in assessing and understanding their domestic ML/TF risks; however, an increased focus on risks related to transnational illicit financial flows is required. A thematic risk assessment undertaken by the Anti-Money Laundering Steering Committee (AMLSC) of international ML/TF risks would enhance the authorities’ risk understanding and is key to effective response to the rapid financial sector growth. Introducing data analytics tools, including machine learning to leverage potentially available big data on cross-border payments, would allow for efficient detection of emerging risks. The results of this assessment should be published to improve the understanding of transnational ML/TF risks and feed into the anti-money laundering and combating the financing of terrorism (AML/CFT) policy priorities going forward.
International Monetary Fund. Monetary and Capital Markets Department
This considers the regulation and supervision of the market-based finance (MBF) sector in Ireland. Ireland has made good progress in implementing MBF-relevant recommendations from the 2014 and 2016 Financial Sector Assessment Programs, but some gaps remain. As the integrated regulator for the financial services sector, the Central Bank would benefit from greater formal legal independence, stronger enforcement powers and more flexibility on individual compensation to attract and retain scarce talent. There is scope for the Central Bank to leverage its expertise and experience to promote further EU convergence on MBF oversight. Closing data gaps would further enhance the Central Bank’s robust regulation and supervision of the MBF sector. The Central Bank should intensify its work to assess and mitigate financial stability risks of MBF. Finalization of work already under way on investment fund pricing errors should be prioritized, while oversight of SPEs deserves regulatory and supervisory attention. The introduction of a comprehensive framework for pricing errors will lay the foundations for greater investor protection and more consistent industry practices. Oversight of special purpose entities has improved from the perspective of statistical analysis, but more efforts are needed to strengthen governance practices.
International Monetary Fund. Monetary and Capital Markets Department
This paper discusses Ireland’s technical note on financial safety nets and crisis management. This note assesses the bank recovery, resolution, and crisis preparedness regime in Ireland. It analyzes laws, policies, procedures, institutional capacity and coordination arrangements for bank failure resolution and for managing financial distress and crises. The assessment is focused on banks under the direct remit of the Central Bank of Ireland and does not evaluate the role played by the European Central Bank and the Single Resolution Board for Ireland’s largest banks. The note also assesses steps toward adopting a recovery and resolution regime for insurers. Substantive efforts have been made to propose a resolution regime for insurers and to identify scope for improving the existing insolvency framework as it applies to insurers. This note recommends that the Department of Finance should explore providing statutory protections to persons selected by the Central Bank albeit appointed by the Court for resolution purposes. It also recommends that the Central Bank and Department of Finance should seek the views of the competition authority on the extent to which resolution regime legislation overrides national competition rules.
International Monetary Fund. Monetary and Capital Markets Department
This Technical Note on Oversight of Fintech explains that Ireland’s fintech sector is growing in importance through the entry of innovative new players and digital transformation of incumbents’ business models and products. This note seeks to identify risks arising from fintech as well as policy responses by authorities. The Irish Government has adopted a Strategy implemented by annual action plans for the development of Ireland’s international financial services sector that includes several initiatives of relevance to fintech. The Central Bank has an Innovation Hub that provides a single point of contact for stakeholders on fintech-related issues. Under the EU’s passporting framework host regulators receive limited information on the activities that passporting entities carry out in their jurisdiction. Incumbent retail banks in Ireland are dedicating significant resources to digital transformation, while fintechs are enlarging consumer choice through innovative new services. The Central Bank should further intensify its efforts to monitor developments on crypto-assets through systematic data collection within the scope of its powers and, where unacceptable risks remain, issue carefully targeted warnings and investor communications.
International Monetary Fund. Monetary and Capital Markets Department
This Technical Note discusses Ireland’s report on Banking Supervision. Supervision of less significant institutions is largely effective in Ireland. The Central Bank’s supervisory approach to LSIs is intrusive and well-developed supervisory tools are appropriately applied. The prudential regulation of banks has improved greatly since the 2016 Financial System Assessment Program. The EU framework has largely managed to embrace international regulatory reforms, following up on the causes of the Global Financial Crisis. The banking supervision has been tested by severe headwinds, with the final outcomes still in play. Supervision went through a period of major challenges for the economy and the financial system, namely from Brexit and the pandemic. The continued effectiveness of banking supervision in Ireland will depend on its success in solving several complicated problems. This note provides the main recommendations to enhance the supervision of the banking activities conducted in Ireland with a direct bearing on its financial stability.
International Monetary Fund. Monetary and Capital Markets Department
This Technical Note highlights Ireland’s Insurance Regulation and Supervision. Ireland’s insurance sector is characterized by high penetration and density in both the life and the non-life sector, which, however, stems largely from outward cross-border business. Irish insurers have proved to be resilient during the coronavirus disease 2019 pandemic, although the full effects have yet to be seen. Primary drivers of solvency ratios have been financial market and interest rate movements affecting insurers’ investment portfolios and liability valuations. The Central Bank has been expanding its analysis of climate risks and corresponding risk management practices in the financial sector. There is scope for the Central Bank to leverage its expertise and experience to promote further EU convergence on insurance oversight. The Central Bank has been very active in policy discussions at the European Insurance and Occupational Pensions Authority and is well placed to take a leading role in the efforts to achieve consistent application of EU legislation, and generally supervisory convergence, on the supervision of cross-border business; the supervision of intra-group transactions and group concentrations; and the supervision of captives.
International Monetary Fund. Monetary and Capital Markets Department
This Financial System Stability Assessment paper highlights that the Irish financial system has grown rapidly and in complexity, especially after Brexit, and Ireland has become a European base for large financial groups. Risks to financial stability emanate from a much larger and more complex financial system, persistent legacy issues, as well as emergent ones from non-bank lending, Fintech, and climate change. Stress tests confirmed banks’ resilience to severe macrofinancial shocks, with some caveats. While broadly adequate, supervisory resources and capacity need to keep pace with a growing and more complex sector with significant cross-border linkages. Efforts are needed to further strengthen supervision of banks’ credit risk and develop capacity and skills on new areas such as climate, non-bank lending, and Fintech. Insurance oversight should prioritize intra-group complexities. Resolution and crisis management can be enhanced through greater planning and collaboration between the Central Bank and the Department of Finance to bolster the ability to deal effectively with institution failures and systemic crises.
Mr. Fabio Comelli
and
Ms. Sumiko Ogawa
This paper reviews the approaches to systemic risk analysis in 32 central bank financial stability reports (FSRs). We compare and contrast the systemic risk analysis in FSRs with the IMF Article IV staff reports, noting that Article IV staff reports and FSRs frequently pick up analytical content from each other. All reviewed FSRs include a systemic risk assessment, which has not always been the case in Article IV staff reports. Also, compared to Article IV staff reports, on average, FSRs tend to cover a wider range of financial risks and vulnerabilities and tend to have more extensive discussions of the policy mix to mitigate systemic risk. In these assessments, FSRs utilize sophisticated analytical tools, such as stress tests and growth-at-risk, more frequently than Article IV staff reports. We emphasize that a central bank FSR typically presents a rich resource that IMF country teams can leverage, as already done by some, in forming their independent view about systemic risk.
Silvia Iorgova
Outside of financial crises, investors have little incentive to produce private information on banks’ short-term liabilities held as information-insensitive safe assets. The same does not hold true during crises. We measure daily information production using data from credit default swap spreads during the global financial crisis and the subsequent European debt crisis. We study abnormal information production around major events and interventions during these crises and find that, on average, capital injections reduced abnormal information production while early European stress tests increased it. We also link information production to outcomes: high levels of information production predict bank balance sheet contraction and higher government expenditures to support financial institutions. In an addendum, we show information production on nonfinancials dramatically increased relative to financials at the height of the COVID-19 crisis, reflecting the nonfinancial nature of the initial shock.