Front Matter Page
IMF Country Report No. 17/122
LUXEMBOURG
FINANCIAL SYSTEM STABILITY ASSESSMENT
May 2017
This Financial System Stability Assessment on Luxembourg was prepared by a staff team of the International Monetary Fund. It is based on the information available at the time it was completed in April 2017.
Copies of this report are available to the public from
International Monetary Fund • Publication Services
PO Box 92780 • Washington, D.C. 20090
Telephone: (202) 623-7430 • Fax: (202) 623-7201
E-mail: publications@imf.org Web: http://www.imf.org/
Price: $18.00 per printed copy
International Monetary Fund
Washington, D.C.
© 2017 International Monetary Fund
Front Matter Page
LUXEMBOURG
FINANCIAL SYSTEM STABILITY ASSESSMENT
April 17, 2017
Approved By
James Morsink and Jörg Decressin
Prepared By
Monetary and Capital Markets Department
This report is based on the work of the Financial Sector Assessment Program (FSAP) mission that visited Luxembourg and Frankfurt during September 12–27 and November 29–December 14, 2016. The FSAP findings were discussed with the authorities during the Article IV consultation mission in March 2017.
The FSAP team was led by Peter Breuer and included Bradley Jones (deputy mission chief), Richard Berkhout, Antoine Bouveret, Jana Gieck Bricco, Giovanni Cucinotta, Ender Emre, Ziya Gorpe, Cyril Pouvelle, Nadine Schwarz, Thierry Tressel, and Froukelien Wendt (all IMF staff), as well as Michael Deasy, David Scott, Richard Stobo (external experts) with assistance from Christie Chea (IMF). The mission met with the Minister of Finance, the Governor of the Banque centrale du Luxembourg (BCL), the Directeur Général of the Commission de Surveillance du Secteur Financier (CSSF), the Directeur Général of the Commission aux Assurances (CAA) and their staffs, and representatives of the European Central Bank (ECB), the European Systemic Risk Board and the Single Resolution Board. The mission also met with representatives of banks, investment firms, insurance companies, other financial institutions, industry associations, as well as auditors, accountants, and lawyers.
FSAPs assess the stability of the financial system as a whole and not that of individual institutions. They are intended to help countries identify key sources of systemic risk in the financial sector and implement policies to enhance its resilience to shocks and contagion. Certain categories of risk affecting financial institutions, such as operational or legal risk, or risk related to fraud, are not covered in FSAPs.
Luxembourg is deemed by the Fund to have a systemically important financial sector and the stability assessment under this FSAP is part of bilateral surveillance under Article IV of the Fund’s Articles of Agreement
This report was prepared by Messrs. Peter Breuer and Bradley Jones, with inputs from the Luxembourg FSAP team members. The report draws on six Technical Notes and one Detailed Assessment Report.
Contents
Glossary
EXECUTIVE SUMMARY
KEY RECOMMENDATIONS
MACROFINANCIAL SETTING
A. Background
B. Luxembourg Financial System Structure and Trends
C. Vulnerabilities
RISKS, RESILIENCE AND SPILLOVERS
A. Stability Risks and Resilience
B. Spillover and Contagion Analysis
PRUDENTIAL OVERSIGHT
A. General and Cross Cutting Themes
B. Macroprudential Policy Framework
C. Banking Regulation and Supervision
D. Investment Fund Regulation and Supervision
E. Insurance Regulation and Supervision
F. Financial Markets Infrastructure—Clearstream Banking Luxembourg
G. Anti-Money Laundering and Combating Financing of Terrorism
CRISIS RESOLUTION AND SAFETY NETS
References
BOX
1. Is the Residential Real Estate Market in Line with Fundamentals?
FIGURES
1. Macroeconomic and Macrofinancial Context
2. Key Components of the Luxembourg Financial System
3. Bank Profit Sources
4. Investment Fund Assets Domiciled in Luxembourg
5. Investment Fund Exposures by Country
6. Insurance Industry: Premiums and Assets
7. Clearstream Luxembourg and the FMI Ecosystem
8. Bank Financial Soundness Indicators
9. Investment and Money Market Funds: Liquid Asset Holdings
10. The Insurance Industry: Capital and Profitability
12. Bank Intragroup Exposures
13. Bank Liabilities Accounted for by Investment and Money Market Funds
14. Residential Real Estate Market Affordability Measures
15. Summary of Luxembourg FSAP Stress Test Sectoral Coverage
16. Real GDP in the Adverse Scenario
17. FSAP Stress Test Macro Projections
18. Results of Top-Down Bank Solvency Stress Tests
19. Bank Liquidity Coverage
20. Insurance Capital and Eligible Own Funds in the Adverse Scenario
21. CNAV Money Market Fund Portfolios
22. Indices of Domestic Contagion and Vulnerability—Balance Sheet Analysis
23. Domestic Network Model—Market Data Analysis
24. Domestic vs. Cross-border Network of Financial Institutions
25. Network Analysis of Gross Intragroup and Cross-border Bank Exposures—Balance Sheet Analysis
26. Indices of Contagion and Vulnerability—Balance Sheet Analysis
27. Global Network Model—Market Data Analysis
28. Concentration Risk and Common Exposures in Luxembourg Bond Funds
29. Investment Fund Ownership Share of Sovereign Debt Markets
TABLES
1. FSAP Update 2017: Key Recommendations
2. Selected Economic Indicators, 2014–22
3. Structure of the Luxembourg Financial System
4. Composition of Luxembourg Bank Assets and Liabilities
5. Bank Financial Soundness Indicators (All Banks)
6. Investment Fund Exposures to Banks
7. Bank Liquidity Stress Test Results
8. Money Market and Investment Fund Liquidity Stress Tests
ANNEXES
I. Implementation Status of Key 2011 FSAP Recommendations
II. Risk Assessment Matrix (RAM)
III. Stress Testing Matrix (STeM)
IV. Report on the Observance of Standards and Codes (ROSC)—Summary Assessments of CPSS-IOSCO Principles for Financial Market Infrastructures: Clearstream Banking Luxembourg
Glossary
| AIFs |
Alternative Investment Fund |
| ACRC |
Audit, Compliance and Risk Management Committee |
| AGM |
Annual General Meeting |
| AIFMD |
Alternative Investment Fund Managers Directive |
| AIFMs |
Alternative Investment Fund Managers |
| AMA |
Advanced Measurement Approach |
| AML/CFT |
Anti-Money Laundering/Combating the Financing of Terrorism |
| ASL |
Automated Securities Lending Programme |
| ASL+ |
Automated Securities Lending Plus Programme |
| AuM |
Assets Under Management |
| Bafin |
Bundesanstalt für Finanzdienstleistungsaufsicht |
| BCL |
Banque centrale du Luxembourg |
| BCP |
Basel Core Principles |
| BRRD |
Banking Recovery and Resolution Directive |
| BU |
Bottom-Up |
| Buba |
Bundesbank |
| CAA |
Commissariat aux Assurances |
| CBL |
Clearstream Banking Luxembourg S.A. |
| CCB |
Countercyclical Buffer |
| CCPs |
Central Counterparties |
| CDPI |
Conseil de Protection des Déposants et des Investisseurs |
| CEMT |
Credit Exposure Management Tool |
| CEO |
Chief Executive Officer |
| CIU |
Collective Investment Undertaking |
| CoBM |
Commercial Bank Money |
| CPSS |
Committee on Payment and Settlement Systems |
| CNAV |
Constant Net Asset Value |
| CRD |
Capital Requirements Directive |
| CRCC |
Clearstream Risk and Compliance Committee |
| CRO |
Chief Risk Officer |
| CRR |
Capital Requirements Regulation |
| CRS |
Comité du Risque Systémique |
| CSDR |
Central Securities Depositories Regulation |
| CSDs |
Central Securities Depositories |
| CSSF |
Commission de Surveillance du Secteur Financier |
| DAR |
Detailed Assessment Report |
| DBAG |
Deutsche Börse AG |
| DGSD |
Deposit Guarantee Scheme Directive |
| DRP |
Disaster Recovery Plan |
| DVP |
Delivery versus Payment |
| EB |
Executive Board |
| EBA |
European Banking Authority |
| EBIT |
Earnings Before Interest and Tax |
| ECP |
Euro Commercial Paper |
| EIOPA |
European Insurance and Occupational Pensions Authority |
| ESMA |
European Securities and Market Authority |
| ELA |
Emergency Liquidity Assistance |
| EM |
Emerging Markets |
| EOF |
Eligible Own Funds |
| ESRB |
European Systemic Risk Board |
| EU |
European Union |
| FATF |
Financial Action Task Force |
| FGDL |
Fonds de Garantie des Dépôts Luxembourg |
| FMIs |
Financial Market Infrastructures |
| FMSA |
Federal Agency for Financial Market Stabilisation |
| FSAP |
Financial Sector Assessment Program |
| FSSA |
Financial Sector Stability Assessment |
| FX |
Foreign Exchange |
| GBP |
Great Britain Pound |
| GMF |
Global Macro-Financial Model |
| GTC |
CBL’s General Terms and Conditions |
| HQLA |
High Quality Liquid Assets |
| HY |
High Yield |
| IAIS |
International Association of the Insurance Supervisors |
| ICPs |
Insurance Core Principles |
| ICSD |
International Central Securities Depository |
| IOSCO |
International Organization of Securities Commissions |
| IRR |
Internal Rules and Regulations |
| ISIN |
International Securities Identification Number |
| IT |
Information Technology |
| iTOF |
Intraday Technical Overdraft Facility |
| KPI |
Key Performance Indicator |
| KRI |
Key Risk Indicator |
| KYC |
Know Your Customer |
| LCR |
Liquidity Coverage Ratio |
| LMTs |
Liquidity Management Tools |
| LTV |
Loan-To-Value |
| LSIs |
Less Significant Institutions |
| MMFs |
Money Market Funds |
| MOU |
Memorandum of Understanding |
| MREL |
Minimum Requirements for Own funds and Eligible Liabilities |
| NAV |
Net Asset Value |
| NCA |
National Competent Authority |
| NRA |
National Risk Assessment |
| NSFR |
Net Stable Funding Ratio |
| OFIs |
Other Financial Intermediaries |
| O-SIIs |
Other Systemically Important Institutions |
| OTC |
Over-the-Counter |
| PFMI |
Principles for Financial Market Infrastructures |
| PFS |
Professional of the Financial Sector |
| RAIFs |
Reserved alternative investment funds |
| RAM |
Risk Assessment Matrix |
| RTGS |
Real-Time Gross Settlement |
| RTO |
Recovery Time Objective |
| SAP |
Systemanalyse und Programmentwicklung system |
| SB |
Supervisory Board |
| SD |
Settlement Day |
| SI |
Significant Institution |
| SLA |
Service Level Agreement |
| SRB |
Single Resolution Board |
| SRF |
Single Resolution Fund |
| SRM |
Single Resolution Mechanism |
| SSM |
Single Supervisory Mechanism |
| SSS |
Securities Settlement Systems |
| STeM |
Stress Testing Matrix |
| STP |
Straight Through Processing |
| TNA |
Total Net Assets |
| TP |
Top-Down |
| UCITS |
Undertakings for Collective Investment in Transferable Securities |
| UCF |
Unconfirmed Funds Facility |
| VaR |
Value at Risk |