金融paper代寫范文參考：Evaluation of Macroprudential Regulation

本文是金融專業(yè)的paper范例，題目是“Evaluation of Macroprudential Regulation（宏觀審慎監(jiān)管評價）”，當今對宏觀審慎監(jiān)管的簡要描述將把它定義為一個厚厚的、復雜的規(guī)則網(wǎng)，用來(A)保持金融機構(gòu)的安全和持續(xù)經(jīng)營，如果做不到這一點，(b)幫助他們的解散和/或重組，(c)增強金融系統(tǒng)的抗沖擊能力，以抵御來自全系統(tǒng)事件和銀行倒閉的沖擊，并在可能的情況下防止全系統(tǒng)風險的發(fā)生這樣的描述并不令人驚訝，因為金融市場、銀行體系和監(jiān)管領域?qū)嶋H上是一張由眾多組成部分組成的復雜的網(wǎng)絡。本文將討論宏觀審慎政策的動機。特別是金融機構(gòu)和金融體系在現(xiàn)有宏觀審慎政策范圍內(nèi)發(fā)揮作用的義務;當前和未來的法律框架與市場紀律之間的挑戰(zhàn);利益相關者和受益人的義務被賦予決策的權力，以確定法定監(jiān)管的目標;是否有支持和有效的控制手段來成功地挑戰(zhàn)現(xiàn)狀。

A succinct present day description of macroprudential regulation would define it as a thick and complex web of rules employed to (a) keep financial institutions safe and a going concern, and failing that, (b) to assist their resolution and/or restructuring, and (c) to augment the resilience of financial systems to withstand shocks emanating from system-wide events as well as from bank failures and, where possible, prevent the occurrence of system-wide risks.[1] Such a description is not surprising as the financial markets, the banking system, and the regulatory landscape are indeed a thick and complex web of constituents. This paper will discuss the motivations for macroprudential policy. In particular, the obligations on financial institutions and the financial system to function within existing macroprudential policies; the challenges of the presence of current and future statutory framework versus market discipline; the obligations of stakeholder and beneficiaries enshrined with the powers to make decisions to determine objectives of statutory regulation; and whether there are controls available to successfully challenge the status quo that are supportive, and effective.

The mechanisms of macroprudential regulation are complemented by initiatives to increase the resilience of the financial system and thus impose obligations on financial institutions and the financial system. Some of these initiatives[2] include the fundamental reform of OTC derivatives trading, clearing and reporting[3], requiring a risk-based approach for remuneration in financial institutions, and regulation of credit ratings and Credit Rating Agencies. [4]

As at end-2008, OTC derivatives had reached USD 598 trillion (GBP 460 trillion) measured by notional value and USD 35 trillion (GBP 27 trillion) by gross market.[5] Owing to the scale of OTC derivatives and their impact on destabilising the financial system, reforms on OTC derivatives markets imposed obligations on financial participants and the financial system to improve their transparency, prevent market abuse and reduce systemic risks. The implementation of the EU Market Abuse Regulation (“MAR”) in 2016 was one reform which caused a further expansion in the scope of insider trading and market manipulation prohibitions in order to respond to the changing nature and structure of financial markets. An example of a key driver towards the implementation of MAR was an increase in the focus on fixed income and commodity markets and related benchmarks in the wake of the financial crisis and a success of scandals in markets previously untouched by insider dealing, and arguably, market manipulation laws (FX, LIBOR etc.).

截至2008年底，場外衍生品名義價值達到598萬億美元(460萬億英鎊)，總市場達到35萬億美元(27萬億英鎊)由于場外衍生品的規(guī)模及其對金融體系穩(wěn)定性的影響，場外衍生品市場的改革迫使金融參與者和金融體系承擔責任，以提高其透明度，防止市場濫用和減少系統(tǒng)風險。2016年實施的歐盟市場濫用法規(guī)(“MAR”)是一項改革，該改革導致內(nèi)幕交易和市場操縱禁令的范圍進一步擴大，以應對金融市場不斷變化的性質(zhì)和結(jié)構(gòu)。一個關鍵驅(qū)動因素對3月的實現(xiàn)是一個專注于增加固定收益和大宗商品市場和相關基準后,金融危機和丑聞的成功市場以前沒有被內(nèi)幕交易,可以說,市場操縱的法律(外匯、利率等)。

Another fundamental reform of OTC derivatives trading, clearing and reporting which was motivated by macroprudential policy objectives was to ensure that central counterparties (“CCPs”) do not expose shocks to the financial markets when under stress. CCPs by their very objective, are heavily exposed to the counterparty credit risk of their members. However, CCPs needs strong internal systems and controls to ensure that over time, commercial pressures and competition from other CCPs do not lead to inadequate margining.[6] CCPs hold collateral from their members and are able to call for further resources from their members under their recovery plans if these funds are exhausted, however this could impact a counterparty’s credit and liquidity profile if they are unable to meet the demands to fulfil their notional obligations as well as initial margin required by CCPs. This, in turn, could impact the CCPs counterparty credit risk and liquidity risk and could risk the credit markets grinding to a halt, leading to moral hazard as counterparties have limited scope to monitor each other’s credit quality and act properly because a third party (the CCP) is bearing all the responsibilities. Therefore, it would be prudent to consider the development of further arrangements for the recovery and resolution of CCPs.

There is a strong prima facie case that inappropriate incentive structures played a role in encouraging behaviour which contributed to the financial crisis. It is very difficult, however, to gauge precisely how important that contribution was. High levels of remuneration in banks, and in particular high bonuses paid both to top executives and to traders involved in trading activities which subsequently generated large losses, have been the subject of intense public focus as the financial crisis has developed.

有一個強有力的初步證據(jù)表明，不適當?shù)募罱Y(jié)構(gòu)在鼓勵行為方面發(fā)揮了作用，這種行為導致了金融危機。然而，要精確地衡量這一貢獻的重要性是非常困難的。隨著金融危機的發(fā)展，銀行的高額薪酬，特別是向高管和參與交易活動的交易員支付的高額獎金，這些交易活動后來造成了巨額損失，一直是公眾高度關注的話題。

There are two distinct issues. The first and short-term issue concerns the total level of remuneration paid to executives in banks which have received taxpayer support. This is a legitimate issue of public concern, and one where governments as significant shareholders have crucial roles to play. But it is not an issue for the long-term nor for bank regulators. The second being that the long-term issue concerns the way in which the structure of remuneration can create incentives for inappropriate risk taking. It is on this issue that the FSA and financial regulators across the world are now focused. Regulators should therefore include a strong focus on the risk consequences of remuneration policies within their overall risk assessment of firms, and should enforce a set of principles which will better align remuneration policies with appropriate risk management and accountability, as can be seen with the implementation of the Senior Managers Regime[7] which is part of the UK governments drive to improve culture, governance and accountability within financial services firms.[8] It fundamentally aims to encourage individuals to take personal responsibility for their accounts; improve conduct at all levels; and make sure firms and individuals clearly understand and can demonstrate who does what. However, the success such a regime will be in in regulators ability to ensure it takes action within its regulatory remit and to ensure that the regulator does not adjudicate on behaviour beyond its scope. It would al achieving international acceptance to implement similar regimes is important part of and retaining and attracting the right talent for the roles.

The impact and influence of credit ratings and Credit Rating Agencies be argued to exacerbate financial criticises. EU government and ECB policy makers accused the big three[9] of publishing unduly negative evaluations as the European sovereign debt crisis spread through Ireland, Portugal, Spain, and Greece. It created procyclicality within the system as a country subject to a downgrade was subjected to higher interests rates and therefore would automatically suffer in its ability to pay its debts. The monopolisation of the sector by such agencies has created an uncompetitive environment that leaves investors with few alternatives. While the big three now face oversight (in the US the US Dodd Frank legislation vested the SEC with additional oversight authority, and ESMA - the EU’s oversight mechanism) neither their market domination nor their fundamental "issuer pays" business model has been challenged by the government or policy makers.[10] This supervisory oversight should extend to requiring that rating agencies only accept rating assignments where there is a reasonable case (based on historical record and adequate transparency) for believing that a consistent rating could be produced.[11] This is important and within scope of macroprudential policy because credit ratings have played a long established role in capital markets, providing investors with an independent assessment of the comparative likelihood of default of securities. However, there are concerns about whether the governance of rating agencies has effectively addressed issues relating to conflict of interest and analytical independence. Rating agencies competing for the business of rating innovative new arrangements may not have ensured that commercial objectives did not influence judgements on whether financial instruments were capable of being rated effectively. Therefore, some measures could be taken to ease the dependency on credit ratings and to reduce the inappropriate use of ratings.

信用評級和信用評級機構(gòu)的影響和影響被認為是加劇金融批評。隨著歐洲主權債務危機在愛爾蘭、葡萄牙、西班牙和希臘蔓延，歐盟政府和歐洲央行的政策制定者指責三大[9]發(fā)布了過度負面的評估。它在金融體系內(nèi)創(chuàng)造了順周期性，因為一個被降級的國家將面臨更高的利率，因此其償還債務的能力將自動受到影響。此類機構(gòu)對該行業(yè)的壟斷，創(chuàng)造了一個缺乏競爭的環(huán)境，讓投資者幾乎沒有其他選擇。盡管三大銀行現(xiàn)在面臨監(jiān)管(在美國，多德?弗蘭克法案賦予證交會額外的監(jiān)管權力，以及歐盟的監(jiān)管機制——歐洲市場監(jiān)管機構(gòu))，但它們的市場主導地位和基本的“發(fā)行方付費”業(yè)務模式都沒有受到政府或政策制定者的挑戰(zhàn)這種監(jiān)督監(jiān)督應該延伸到要求評級機構(gòu)只在有合理理由(基于歷史記錄和足夠的透明度)相信可以產(chǎn)生一致評級的情況下才接受評級任務這是很重要的，而且在宏觀審慎政策的范圍內(nèi)，因為信用評級在資本市場中一直扮演著重要的角色，它為投資者提供了對證券違約相對可能性的獨立評估。然而，有人擔心，評級機構(gòu)的治理是否有效地解決了與利益沖突和分析獨立性有關的問題。對創(chuàng)新性新安排進行評級的業(yè)務進行競爭的評級機構(gòu)可能無法確保商業(yè)目標不會影響對金融工具是否能夠進行有效評級的判斷。因此，可以采取一些措施來減輕對信用評級的依賴，并減少不適當使用評級的情況。

External regulation and supervision is detrimental to addressing interconnectedness of individual financial institutions and markets. The presences of statutory frameworks augment the resilience of financial systems to withstand shocks emanating from system-wide events as well as from bank failures and, where possible, prevent the occurrence of system-wide[12], macroprudential policy. Reliance on internal governance controls and market discipline is not adequate to confine bank risk-seeking and shareholder pursuit of every higher risks for higher benefits in order to achieve higher returns. Private sector goals and incentives[13] contrast vastly with public sector interests and concerns[14], for example when the public sector reacts to losses from financial institutions which spill over into areas of the economy, which results in moral hazard and therefore requires banks to use high levels of leverage which further poses risks for the solvency of the individual institutions and the stability of the financial system, banks are reliant on the provision of (frequently state-backed) deposit guarantee schemes and a central bank operated lender of last resort facility to prevent depositors runs turning into a solvency event for a bank with the possibility of ensuring contagion and system-wide panic.

Even if the default presumption or system-wide approach is that public bailouts become less frequent in the future, in view of implementation of rigour new bank resolution regimes to facilitate orderly failure which minimizes moral hazard, other strong reasons still exist to justify ex ante regulation. It is almost impossible to make a sound prior assessment of the consequences of the policies pursued, due to the complexities of the financial system. The impact of the macroprudential decisions are not visible in the short term. As a result, the role of macroprudential supervisors is difficult, especially given the objective of the tasks and of the conception of the mechanism influencing economic outcomes, and the conceptual interactions between ensuring financial stability under macroprudential policy and the soundness of individual banks under microprudential policy to effect a single supervisory mechanism.  Macroprudential supervisors need to restrain activity at the right time when the economy and financial markets are sound without visible short-term benefits to calibrate regulatory and supervisory arrangements. Otherwise, the shift in focus could lead to a conflict of interest among macroprudential supervisors/policy makers by subjecting them to political pressures to water down or postpone their policy decisions to prioritise enhancing economic growth. Banking lobbies are more likely to be opposed to increases in capital requirements (as stipulated under Basel III) or greater restrictions on loan terms with counterparties, and they could try to rally the public to their perspective by citing increased costs of credit. A public sector concerned about protecting taxpayers and deposit insurance funds will be hesitant to buy into any relaxation of regulatory and supervisory arrangements when the economy turns.

即使違約推定或系統(tǒng)范圍的方法是，公共救助在未來變得不那么頻繁，考慮到實施嚴格的新銀行處置機制，以促進有序破產(chǎn)，最大限度地減少道德風險，其他強有力的理由仍然存在，以證明事前監(jiān)管是合理的。由于金融體系的復雜性，要對所推行政策的后果進行合理的事先評估幾乎是不可能的。宏觀審慎決策的影響在短期內(nèi)并不明顯。因此，宏觀審慎監(jiān)管機構(gòu)的作用是困難的，特別是考慮到任務的目標和影響經(jīng)濟結(jié)果的機制的概念，以及確保宏觀審慎政策下的金融穩(wěn)定與微觀審慎政策下單個銀行的穩(wěn)健之間的概念互動，以實現(xiàn)單一監(jiān)管機制。宏觀審慎監(jiān)管機構(gòu)需要在經(jīng)濟和金融市場狀況良好、沒有明顯短期利益的時候，在合適的時間限制金融活動，以校準監(jiān)管和監(jiān)管安排。否則，這種重心的轉(zhuǎn)移可能會導致宏觀審慎監(jiān)管機構(gòu)/政策制定者之間的利益沖突，因為這將給他們施加政治壓力，迫使他們淡化或推遲以促進經(jīng)濟增長為重點的政策決定。銀行業(yè)的游說團體更有可能反對提高資本要求(如巴塞爾協(xié)議III所規(guī)定的)或?qū)灰讓κ值馁J款條件進行更嚴格的限制，他們可能會試圖以信貸成本增加為理由來說服公眾同意他們的觀點。當經(jīng)濟轉(zhuǎn)向時，擔心保護納稅人和存款保險基金的公共部門將不愿接受任何監(jiān)管和監(jiān)督安排的放松。

Macroprudential policy is a promising addition to the regulator tool-kit that should help to mitigate the risk of a global liquidity meltdown, thus enabling the financial system to retain the benefits of monetary policy focused on sustaining price and economic stability. However, regulatory tool-kits do have their challenge in identifying and dealing with financial vulnerabilities outside of the banking system where they could be lodged in lightly regulated entities and avoiding regulatory arbitrage[15] across geographical jurisdictions that simply pushes the boundaries, and risk, around globally integrated financial markets. In addition, as previously discussed on the issue of public sector concerns versus the incentives of policy makers, a critical element to the toolkit for the implementation of macroprudential policy is public understanding and support in order to sustain effective policy.

The emergence of lack of consensus as to the type of macroprudential tools that should form part of a macroprudential toolkit reflects the need to better under how macroprudential tools are designed or should be designed and calibrated. These challenges, global financial stability and accountability, would be better assured if more jurisdictions, globally (such as including the United States), adopted more active use of tools such as the countercyclical capital buffer (CCyB) of Basel III.  For example, some of the confusion with regard to a macroprudential toolkit could lie in the lack of clarity as to which tools can be considered macroprudential, and which tools cannot. Macroprudential tools are defined to fall into two categories[16], time dimensions[17] and cross-sectorial dimensions.[18] To illustrate, the Basel III capital adequacy rules, which if applied to all financial institutions and initiated before a systemic event would be microprudential; if it were to only apply to systemically important financial institutions would be macroprudential; and if triggered in response to a systemic event would be a disaster recovery management tool. However, whilst global inconsistency in the implementation of macroprudential tools seems problematic, this is not surprising given the considerations that could affect the choice and combination of policy tools incorporated globally due for example to country specific circumstances such as the degree of honesty relating to capital justification, and the breath and depth of the financial system, signifying that there is a no one-size-fits-all solution.[19]

對于應該成為宏觀審慎工具包一部分的宏觀審慎工具的類型缺乏共識的出現(xiàn)，反映出需要更好地了解宏觀審慎工具的設計或應該如何設計和校準。這些挑戰(zhàn)，全球金融穩(wěn)定和問責制，將會得到更好的保證，如果更多的轄區(qū)，包括全球(包括美國)，采用更積極的工具，如巴塞爾III的反周期資本緩沖(CCyB)。例如，關于宏觀審慎工具包的一些困惑可能在于，對于哪些工具可以被視為宏觀審慎，哪些工具不能被視為宏觀審慎，缺乏清晰的認識。宏觀審慎工具被定義為兩類[16]，時間維度[17]和跨部門維度[18]舉例來說，《巴塞爾協(xié)議III》(Basel III)的資本充足率規(guī)則(如果適用于所有金融機構(gòu)，并在系統(tǒng)性事件發(fā)生前啟動)將是微觀審慎的;如果它只適用于具有系統(tǒng)重要性的金融機構(gòu)，那就是宏觀審慎;如果在響應系統(tǒng)事件時觸發(fā)，將是災難恢復管理工具。然而,同時全球不一致的實現(xiàn)宏觀審慎工具似乎有問題,這并不奇怪的考慮,可能會影響全球政策工具的選擇和組合包含例如由于國家具體情況的誠實程度等關系資本的理由,金融體系的廣度和深度，意味著不存在放之四海而皆準的解決方案

Macroprudential analysis should cover all sectors: problems in the banking industry and trends in specific markets, for example, bond prices can, for instance, have significant implications for insurance companies. And any separation of prudential regulation and supervision creates the risks of inadequate accountability, coverage and regulatory arbitrage, clearly illustrated by the case of AIG.[20]

It can be argued that market discipline can play a key role in incentivising banks to constrain capital and liquidity risks. The Basel II capital adequacy framework adopts the theory that improved disclosure under ‘Pillar 3’ will play a vital role alongside regulation and accountability development, in incentivising appropriate behaviour. But a strong case can be made that the events of the last five years have illustrated the inadequacy of market discipline and lack of accountability.

可以說，市場紀律可以在激勵銀行約束資本和流動性風險方面發(fā)揮關鍵作用。《巴塞爾協(xié)議II》資本充足率框架采用的理論是，在“第三支柱”下改善披露將在監(jiān)管和問責發(fā)展方面發(fā)揮重要作用，從而激勵適當?shù)男袨椤５覀兛梢杂辛Φ刈C明，過去5年發(fā)生的事件表明了市場紀律的不足和問責制的缺乏。

In conclusion, macroprudential policy is an accompaniment to microprudential policy and it interacts with other types of public policy that have an effect on financial stability such as monetary or fiscal policy, but it is no substitute for them. The central role of capital-based tools, have distinct property, and tend to complement each other in addressing the same externality, as such a combination of instruments may seem, instead, more appropriate to correct the same externality.

Excessive risk taking, at least at the top management level, may be driven more by broad behavioural and cultural factors than by a rational consideration of the precise incentives inherent within remuneration contracts: dominant executive personalities have a strong tendency to believe in their own strategies. And the reality of excessive risk can often only be spotted at a systemic level.

過度冒險(至少在最高管理層)，可能更多地受到廣泛的行為和文化因素的驅(qū)動，而不是理性地考慮薪酬合同中固有的精確激勵:占主導地位的高管人物有強烈的傾向，相信自己的戰(zhàn)略。而過度風險的現(xiàn)實往往只能在系統(tǒng)性層面被發(fā)現(xiàn)。

That being said, bank regulation cannot (and should not seek) create a zero failure environment but an environment where institutional failure can be managed so that it does not endanger the stability of the financial system and create market dislocation.[21] Macroprudential supervisors and other authorities are still facing major challenges in coming to grips with financial instability. The basic lessons of the evolution of the tools, tasks and measures taken by policy makers is crucial to the development of the regulatory framework. After all, anchors are no better than the soil in which they are planted. And that soil could, at worst, turn out to be quick sand, if it comprises of insufficient risk observations and overstated asset values.[22]

話雖如此，銀行監(jiān)管不能(也不應該尋求)創(chuàng)造一種零失敗的環(huán)境，而是創(chuàng)造一種可以管理機構(gòu)失敗的環(huán)境，使其不會危及金融體系的穩(wěn)定和造成市場混亂宏觀審慎監(jiān)管機構(gòu)和其他當局在應對金融不穩(wěn)定方面仍面臨重大挑戰(zhàn)。決策者所采取的工具、任務和措施的演變的基本教訓對監(jiān)管框架的發(fā)展至關重要。畢竟，錨并不比它們所在的土壤更好。在最壞的情況下，如果風險觀察不足，資產(chǎn)價值被高估，這片土地可能變成流沙

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