Appendix Structural Policy and Operational Objectives of the National Bank of Poland
- Piero Ugolini
- Published Date:
- November 1996
The new approach focused on delivering a comprehensive technical assistance program in all interrelated operational areas of the central bank, while introducing regulation and procedures to improve the existing structures. The comprehensiveness of the technical assistance delivered was dictated by the close links between operational areas in a market-oriented central bank and the need for making progress simultaneously in all areas in order to avoid undue delays (for example, payments system, monetary operations and foreign exchange, monetary statistics and bank supervision, accounting and monetary statistics, and balance of payment statistics).
The new type of technical assistance from the Monetary and Exchange Affairs Department was initiated with cooperation from six central banks to help the National Bank, each in a specific area.28 The cooperating central banks agreed to make expert staff available for short-term visits to Poland as Monetary and Exchange Affairs Department consultants. In addition, they provided managerial and technical support to their experts and allowed them time off from their normal duties to prepare for and to follow up on their visits to Poland. Many experts also arranged training opportunities abroad for National Bank staff at their own institutions and elsewhere.
In addition, the above innovations have also had the effect of changing somewhat the extent and the content of the Monetary and Exchange Affairs Department technical assistance in two respects. First, by emphasizing the comprehensive and dynamic approach, its technical assistance has widened to the point of embracing simultaneously all functional operations of the central banks. Under the traditional approach, the Monetary and Exchange Affairs Department/Central Banking Department used to focus or provide training on one or two subjects. Second, by preparing an action plan with the authorities during the diagnostic mission, its technical assistance is now a component of a major and broader restructuring plan of the country’s economy.29
Initial Action Plan to Modernize the National Bank of Poland, 1991–92
Form a senior-level Payments System Policy Committee, chaired by the First Vice-President, with representation from the accounting, legal, bank supervision, foreign monetary and credit policy, information technology, and economic research departments, plus the new interbank settlements department.
Form a new Interbank Settlements Department to manage daily interbank clearing and settlement services, coordinate contacts with the Payments Association and any other groups formed to address payment issues, support the Payments System Policy Commiuee, and manage the National Bank-wire system.
Stimulate the formation of the Polish Payments Association to coordinate the National Bank actions and take unilateral action if bankers cannot reach agreement. Monthly meetings with bankers on clearinghouse, development of standards for payment instruments, and so forth.
Centralize commercial bank branch accounts into one account per bank at the National Bank head office. Preparatory work to begin immediately.
Implement the remaining near-term improvements.
Send advices of interbank debits and credits directly to the National Bank branch on the same day they are sent to the bank branch.
Require banks to organize efficient local and other physical exchanges of paper checks and payment orders.
Eliminate the procedure that grants credits before debits can be charged to the paying banks.
Establish a working group on monetary programming.
Eliminate interest on excess reserves.
Establish framework for monetary programming and reserve forecasting.
Introduce longer maturity National Bank bills (91 days, 182 days), and post bill rediscount rate differentiated by maturity.
Introduce refinance auctions and related adjustments to other monetary policy instruments,30 and greater flexibility in interest rates.
Review secondary market developments and prepare plans for new institutional arrangements for the secondary markets; and discuss plans with the commercial banks.
Analyze the various surveys, especially foreign exchange exposures; prepare consolidated returns for banks having branches and affiliates abroad; and discuss legal matters.
Analyze the first reports designed with the new accounting plan; follow up on the survey; organize off-site monitoring; prepare “notes for National Bank management”; and prepare annual statements for banks.
Organize on-site missions; prepare preliminary proposals for prudential regulations; begin diagnostic studies of individual banks using the new account system; and conclude discussions of legal matters.
Follow up on on-site missions; continue diagnosis of individual banks; finalize prudential regulations; and study interest rate risk.
Balance of Payments
Create Foreign Department’s own PC software for the pilot balance of payment statistics project, and start estimating cross-trade.
Analyze results of pilot direct investment survey, send out survey forms for 1990, and start balance of payment statistics monitoring.
Introduce new monthly reports on foreign accounts.
Introduce (preliminary) analytical balance of payment statistics model and review direct investment survey.
Implement the new classification of services and capital accounts in the context of the new balance of payment statistics mainframe system.
Central Bank Accounting
Stop immediatly the opening of new foreign exchange and zloty accounts for nonbanks.
Ensure adequate telecommunication lines between the National Bank head office and branches.
Prepare organizational procedures for the consolidation of accounts and the implementation of the new plan of accounts by the Bank.
Follow up on the preparation of the consolidation project.
Consolidate (daily) accounts in a main book at the National Bank headquarters (Central Accounting Department); a precondition is the centralization of the banks’ branch accounts (first stage).
Begin preparation of organizational procedures and related accounting regulations for the main book to interface with the National Bank-wire (second stage), and for the future centralization in the general ledger (third stage).
Publish the ten-day returns (summary balances) derived from the main book.
Address staffing problems.
Use the training opportunities offered by cooperating central banks.
Foreign Exchange Operations
Modify Foreign Exchange Law and National Bank regulations to encourage the development of an interbank market in foreign exchange.31
Integrate Kantor (bureaux de change) and bank markets for foreign exchange.
Finalize computerized position, keeping system, and benchmark portfolios.
Replace position limits on nostro accounts by exposure limits based on prudential considerations.
Finalize written guidelines on operating procedures for dealing and investment, and follow up on the implementation of the interbank market.
Publish rules governing interbank net settlements.
Approve National Bank participation in National Clearinghouse Association.
Publish procedures for operation of consolidated current accounts.
Form National Bank working group on payment system for the development of coordinated long-range tactical plan, taking into account linkages that exist between the safety and soundness of the banking industry, the execution of monetary policy, treasury debt management, payment and accounting aspects of foreign operations, foreign exchange clearings, and interbank settlement.
Align settlement procedures for check payment instruments to eliminate remaining debit float.
Develop position paper on the National Bank’s objectives for and role in the modernization of the Polish payments system, and draft tactical plans. This tactical plan should address:
Any remaining float-related matters.
Operating procedures for current accounts.
Strategy for improving real time interbank settlement, including an approach to a National Bank-wire implementation.
Strategy for clearing and settlement of securities’ transactions.
Implement consolidated current accounts and begin operation of clearinghouses for paper payment instruments.
Align settlement procedures for transfer payment instruments to reduce or eliminate credit float.
Publish position paper and draft tactical plans for public comment.
Publish final policy position paper, and finalize technical plans coordinated with other National Bank departments for the implementation of the direction adopted.
Follow up on the implementation of the Now Accounting Plan.
Organize meetings to clarify accounting issues with commercial banks in the following areas: foreign exchange operations, loan classification.
Organize similar meetings on leasing, interbank market operations, and loan syndication.
Expand the Accounting Pian to include other operations in the areas of foreign exchange, leasing, interbank market operations, and loan syndication.
Create working groups to resolve specific accounting issues and to study implementation of proposals: internal groups within the National Bank (Banking Supervision Department and Economics, Projections, Analysis and Research Department): National Bank and commercial banks: Ministry of Finance, National Bank and commercial banks.
• Finalize and enforce the solvency ratio.
Introduce liquidity ratio guidelines.
Introduce large-risk exposure rules or guidelines.
Issue loan classification and provisioning rules.
Analyze structural and dealing positions of commercial banks in foreign exchange, from risk-management point of view.
Study interest rate risk.
Study sovereign risk.
Study credit risk by sectors of activities.
Study credit risk by regions—July/December.
Organization and Management of the Banking Supervision Department
Assess the procedures used to grant licenses to commercial banks.
Assess the process of off-site analysis and appraisal of financial position of banks based on monthly reports received by the Banking Supervision Department; formulate new recommendations for this exercise.
Assess existing procedures for on-site inspections and make recommendations to improve them.
Select a core of agents for on-site inspection and begin in-house training courses for them.
Establish a methodology for on-site inspections.
Assess basic training to be given to the Banking Supervision Department staff by external consultants.
Create a “document file” for collection and preparation of translations of material related to banking supervision from foreign languages into Polish.
Visit the regional banking supervision units to assess the quality of their activities.
Analyze the conditions under which the National Bank can request investigations to be conducted by external auditors.
Formulate a strategy to be implemented for the banks experiencing serious difficulties.
Domestic Public Debt Management
Distribute medium-term securities to households and other nonbank investors. Implement a new strategy by selling medium-term government securities “on tap” through “issuing agents” (to be established) according to the rules (to be established) and under the supervision of the National Bank. Also, the Bank’s branches could sell securities directly to the household sector.
Implement technical improvements in auction procedures: introduce minimum or exclusive price, speed up process of entering data in the computer, change method of calculation of yield, and ensure coincidence of redemption dates and the settlement dates for new issues.
Extend treasury bill maturity and begin technical preparation for the auctions of medium-term government securities.
Introduce a receipt in substitution for the physical issuance of treasury bills.
Initiate a secondary market. Issue regulations for (a) the establishment of appropriate primary and secondary dealers, (b) trading in the wholesale market, and (c) supervision of the market.
Develop a book-entry system.
Negotiate with the Ministry of Finance the conversion of part of outstanding National Bank credit to Government into marketable securities to be used in monetary operations.
Introduce reverse repo auctions.
Tighten access to current account credit and require government securities as collateral for such credit (charge a higher rate for unsecured credit).
Initiate more active use of repo/Yeverse repo auctions, taking into account the results of treasury debt sales, in order to achieve short-term operating targets for the bank’s current account balances (set on a rough basis initially).
Formulate and analyze plans to promote market makers in government securities, and consider the associated technical and regulatory arrangements, including National Bank dealer financing facilities.
Review operational procedures and methodology for short-term reserve money programming, in coordination with monetary analysis and programming work of the economics, projections, analysis, and research department, for longer time horizon.
Authorize primary dealers in government securities with clearly stated privileges and obligations.
Install LAN for the Foreign Department’s personal computers, acquire back-up hardware.
Implement reverse repurchase agreements.
Implement treasury bill lending.
Decide on supporting software by National Bank management.
Start purchase of U.S. treasury notes.
Prepare for investment in German capital market—the Deutsche Bundesbank is ready to organize a one-week training program for three Foreign Department members.
Foreign Exchange Market
Issue decree allowing use of buy/sell rates by the National Bank and commercial banks, and begin quoting buy/sell rates.
Request reinterpretation by the Ministry of Finance of Article 7 of Foreign Exchange Law to permit interbank dealing between commercial banks.
Abolish regulatory distinction between private and commercial foreign exchange funds.
Place prudential limits on banks:
Overall currency exposure.
Exposure against zloty.
Require daily reporting on major banks’ best available information on previous day’s closing positions.
(6) Change procedures for exchange rate quotation so as to use same day’s international cross rates and develop procedures for the daily announcement of foreign exchange rates.
(7) Promote establishment of market makers in domestic interbank foreign exchange market; adopt appropriate codes of conduct.
(8) Organize seminar for senior management on reserve management objectives and constraints.
Monetary Research and Balance of Payments
Monetary and Financial Analysis
Consolidate balance sheet of the banking system, including:
Setting up a system of verification of the new reporting forms.
Improving the organization of processing the forms.
Assisting with upcoming statistical problems in this area.
Set up a framework for monetary programming.
Expand the accelerated information system and ensure consistency with the new monthly reporting system of banks.
Improve economic analysis performed by the Economics, Projections. Analysis, and Research Department staff.
Define further information needs for economic analysis, including setting up new tables for the Polish money market, capital market, government finance, prices, wages, production, etc.
Review and finalize the remaining outstanding issues.
Expand the set of internal tables on the basis of the new reporting forms.
Analyze monetary and financial developments to improve internal briefings and external reporting.
Study seasonal effects on monetary flows.
Monetary Programming and Policy Research
Set up an interdepartmental working group between the Monetary and Credit Policy Department, the Foreign Department, and the Economics, Projections. Analysis, and Research Department.
Improve forecast methods and begin estimations of equations.
Analyze the differences between forecasts and actual results.
Implement the monetary programming framework.
Set up an interdepartmental working group between the Banking Supervision Department and the Economics, Projections, Analysis, and Research Department for the coordination of the interpretation of the plan of accounts and future amendments of the plan.
Set up an interdepartmental working group on statistics of common interest.
Continue to improve the accuracy of the reporting forms received from banks.
Improve and expand the statistical database with monthly information on the budget flows (expenditure, revenue, etc.).
Create tables with consistent time series (building blocks) based on the new reporting forms for banks.
Install new automation facilities with technical coordination from the Banking Computer Center.
Balance of Payments
Review progress of implementing new balance of payment statistics formal.
Central Bank Accounting
Divest the National Bank of Poland from commercial activities. Transfer all existing private accounts to commercial banks.
Implement the new plan of accounts of the National Bank following the divestiture of commercial activities.
Consolidate all central bank transactions at National Bank headquarters every ten days.
Create a separate unit reporting directly to the President; streamline and facilitate the operational tasks of the new separate unit.
Complete the Telbank Business Plan.
Form an Automation Steering Committee.
Complete a general work plan.
Develop detailed work plans for:
Installation of hardware and environmental software for the ES9000.
Connection to the Telbank.
Overall plans for phasing out processing for non-National Bank initiatives.
Overall plans for phasing out old National Bank head office equipment being replaced by the ES9000.
Complete project plans for initial application development. This will proceed in stages with plans for Accounting, Foreign Operations, General Ledger, National Bank-wire, and Book-Entry Systems.
Begin the Economics, Projections, Analysis, and Research Department/Money and Credit Policy Department—LAN project.
BaliñoJ.T. Tomás and others (1994) “The Payments System Reforms and Monetary Policy in Emerging Market Economies in Central and Eastern Europe,” IMF Working Paper 94/13 (Washington: International Monetary Fund).
BaliñoJ.T. Tomás and CarloCottarellieds. (1994) “Frameworks for Monetary Stability, Policy Issues, and Country Experiences,” papers presented at the Sixth Seminar on Central BankingWashington, D.C.March1–101994.
DownesPatrick and RezaVaez-Zadeheds. (1990) “The Evolving Role of Central Banks,” papers presented at the Fifth Seminar on Central BankingWashington, D.C.November5–151990.
EbrillP. Liam and others (1994) Poland: the Path to a Market Economy IMF Occasional Paper 113 (Washington: International Monetary Fund).
KawalecStefan and others (1994) “Dealing with Bad Debts: The Case of Poland,” in Building Sound Finance in Emerging Market Economiesed. byGerardCaprio and others (Washington: International Monetary Fund and World Bank).
SundurarajanV. (1992) “Financial Sector Reforms and their Appropriate Sequencing,” The 19th SEANZA Central Banking Course (Tokyo: Bank of Japan).
The law was approved on January 31, 1989, and became officially operational on February 1, 1989.
This plan was strongly supported by the IMF, as well as other multilateral institutions, the European Union (EU), most European countries, and the United States. As part of the stabilization and modernization package, the National Bank of Poland adopted a series of far-reaching reforms in virtually all operational activities. The ultimate objective of the Bank was the creation of a market-based system where the central bank could implement indirect instruments of monetary policy to manage interest rate determination. The former Central Bank Department of the IMF, now called Monetary and Exchange Affairs Department, supported the initial modernization efforts of the Bank with the help of six cooperating central banks: the Austrian National Bank, the Bank of England, the Bank of France, the Bundesbank, The Netherlands Bank, and the U.S. Federal Reserve. The format of technical assistance adopted in the case of Poland was unique also for the IMF, insofar as comprehensive technical assistance was provided simultaneously in all functional areas of the National Bank of Poland for the first time.
By 1987, the National Bank of Poland operated 732 bank branches out of 808 existing banks, excluding 1,660 cooperative banks.
Bank Gospodarki Zywnościonej.
Article 6.1 of the National Bank of Poland Act of January 31, 1989.
Article 6.2 of the National Bank of Poland Act of January 31, 1989.
Monetary management and money market development, the Bank of England; monetary and balance of payments research and analysis, the Netherlands Bank; banking supervision, the Bank of France; central bank accounting and internal auditing, the Austrian National Bank; foreign exchange operations, the Bundesbank; and the payments system, the U.S. Federal Reserve. In the area of public debt management, the Banca d’Italia provided one expert for one visit.
More details on the technical assistance program are provided in an MF Survey article of August 13, 1990, “IMF Central Banking Department Organizes Aid to National Bank of Poland.”
Indeed, it took the National Bank of Poland until mid-1994 to produce a daily consolidated sheet.
New interest rates were applied to the old credits—requiring a change in the laws on credit relationships so as to modify the fixed-rate contracts on the old credits to preferential sectors—but only a part of the interest payments was serviced by the end users of credit. The remainder was partly met by budgetary subsidies to end users, and partly by mandated capitalization of interest. This approach served to freeze the sectoral distribution of bank credit, particularly when nominal interest rates were high.
Sundararajan (1992), p.259.
All interest payments on central investment refinance were automatically rolled over into additional refinance, while banks were free to repay and borrow under this facility within agreed overall limits. Thus, it was difficult to forecast the outstanding usage of such refinance as this in effect served as a large and growing line of credit to be used at the initiative of banks.
Government securities and foreign exchange transactions were settling at t + 2 days.
For example, the capability of the National Bank to make outright transactions in treasury bills was obstructed by the requirement that (until July 1, 1995) treasury securities sold to the Bank had to be issued in physical form.
Article 57.2 of the January 31, 1989, National Bank of Poland Act.
The ratio could not be lower than 8 percent for any bank in Poland. However, a bank starting its operation was obliged to maintain the ratio at a level not lower than 15 percent during the first year of its operation, and not lower than 12 percent during the second year. This regulation is still in effect.
Poland rejoined the International Monetary Fund in 1986.
In the check-kiting operation, a certified check drawn on an account in Bank A could be deposited in an account in Bank B, immediately credited to that account, and, while the check was in the process of being presented to Bank A, the National Bank of Poland would extend float credit to Bank B, which could be outstanding for several days. Art-B’s particular twist on this scam was to get its bank (Bank Handlowy Kredytowy of Katowice) to certify checks written on an account in which there was no money. Thus, Art-B was able to receive a large amount of credit from the banking system, funded ultimately by the National Bank. Art-B’s owners absconded with some $400 million and the Bank was forced to close Bank Handlowy Kredytowy of Katowice; all depositors were paid in full.
At that time, the computer centers performed the intrabranch accounting functions, which resulted in the preparation of four advices—credits received, debits sent, debits received, and credits sent. These advices were given to the bank branch on the morning following the processing. The bank branch then sent the advices to the National Bank branch on the next day (or subsequent days) for posting to the branch’s account at the Bank.
The World Bank and IMF Conference Building Sound Finance in Emerging Market Economies, presented by Mr. Stefan Kavalec, Under Secretary at the Ministry of Finance in Poland (unpublished paper).
Success has to be seen in the context of the considerable progress made by the country as a whole in a few years. As a resull of this progress, Poland has received high ratings from three major rating agencies, which has allowed the country to issue Eurobonds in mid-1996.
National Bank of Poland President decree on the establishment of the Open Market Operations Coordination Committee (January 1, 1993, amended in March 1993).
SORB is the system that maintains the reserve and clearing accounts of all banks on the books of the National Bank.
Article 3a, Chapter 1 of the Act of December 14, 1994 (Bank Guarantee Fund).
Privatized during 1996.
The open position limits are 15 percent for each currency, and 30 percent and 40 percent of the Bank’s eligible capital for global net position and total exposure, respectively.
The 1990 National Bank of Poland Act, albeit comprising important and crucial articles to establish the National Bank’s independence, had some weaknesses and has required continuous amendments.
Monetary management and money market development, the Bank of England; monetary and balance of payments research and analysis, The Netherlands Bank; banking supervision, the Bank of France; central bank accounting and internal auditing, the Austrian National Bank; foreign exchange operations, the Deutsche Bundesbank; and the payments system, the U.S. Federal Reserve. In the area of public debt management, the Banca d’Italia provided one expert for one visit.
As a result of the Polish experience, the Monetary and Exchange Affairs Department technical assistance has also become more policy oriented and an integral component of a larger restructuring plan for the entire economy, which is often supported by the use of Fund resources under structural adjustment programs.
The related adjustments include raising of interest rates on current account credit, establishing strict limits (e.g., proportional to capital) on access to bill rediscount facilities, raising interest on payment credit to at least 200 percent of the rate on current account credit, and introducing weekly adjustments in bill rediscount rates.
Specifically, Articles 7 and 13 of the Foreign Exchange Law or its interpretation may need to be changed.
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