金融paper代写范文参考：Evaluation of Macroprudential Regulation

本文是金融专业的paper范例，题目是“Evaluation of Macroprudential Regulation（宏观审慎监管评价）”，当今对宏观审慎监管的简要描述将把它定义为一个厚厚的、复杂的规则网，用来(A)保持金融机构的安全和持续经营，如果做不到这一点，(b)帮助他们的解散和/或重组，(c)增强金融系统的抗冲击能力，以抵御来自全系统事件和银行倒闭的冲击，并在可能的情况下防止全系统风险的发生这样的描述并不令人惊讶，因为金融市场、银行体系和监管领域实际上是一张由众多组成部分组成的复杂的网络。本文将讨论宏观审慎政策的动机。特别是金融机构和金融体系在现有宏观审慎政策范围内发挥作用的义务;当前和未来的法律框架与市场纪律之间的挑战;利益相关者和受益人的义务被赋予决策的权力，以确定法定监管的目标;是否有支持和有效的控制手段来成功地挑战现状。

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，场外衍生品名义价值达到598万亿美元(460万亿英镑)，总市场达到35万亿美元(27万亿英镑)由于场外衍生品的规模及其对金融体系稳定性的影响，场外衍生品市场的改革迫使金融参与者和金融体系承担责任，以提高其透明度，防止市场滥用和减少系统风险。2016年实施的欧盟市场滥用法规(“MAR”)是一项改革，该改革导致内幕交易和市场操纵禁令的范围进一步扩大，以应对金融市场不断变化的性质和结构。一个关键驱动因素对3月的实现是一个专注于增加固定收益和大宗商品市场和相关基准后,金融危机和丑闻的成功市场以前没有被内幕交易,可以说,市场操纵的法律(外汇、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.

有一个强有力的初步证据表明，不适当的激励结构在鼓励行为方面发挥了作用，这种行为导致了金融危机。然而，要精确地衡量这一贡献的重要性是非常困难的。随着金融危机的发展，银行的高额薪酬，特别是向高管和参与交易活动的交易员支付的高额奖金，这些交易活动后来造成了巨额损失，一直是公众高度关注的话题。

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.

信用评级和信用评级机构的影响和影响被认为是加剧金融批评。随着欧洲主权债务危机在爱尔兰、葡萄牙、西班牙和希腊蔓延，欧盟政府和欧洲央行的政策制定者指责三大[9]发布了过度负面的评估。它在金融体系内创造了顺周期性，因为一个被降级的国家将面临更高的利率，因此其偿还债务的能力将自动受到影响。此类机构对该行业的垄断，创造了一个缺乏竞争的环境，让投资者几乎没有其他选择。尽管三大银行现在面临监管(在美国，多德•弗兰克法案赋予证交会额外的监管权力，以及欧盟的监管机制——欧洲市场监管机构)，但它们的市场主导地位和基本的“发行方付费”业务模式都没有受到政府或政策制定者的挑战这种监督监督应该延伸到要求评级机构只在有合理理由(基于历史记录和足够的透明度)相信可以产生一致评级的情况下才接受评级任务这是很重要的，而且在宏观审慎政策的范围内，因为信用评级在资本市场中一直扮演着重要的角色，它为投资者提供了对证券违约相对可能性的独立评估。然而，有人担心，评级机构的治理是否有效地解决了与利益冲突和分析独立性有关的问题。对创新性新安排进行评级的业务进行竞争的评级机构可能无法确保商业目标不会影响对金融工具是否能够进行有效评级的判断。因此，可以采取一些措施来减轻对信用评级的依赖，并减少不适当使用评级的情况。

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.

即使违约推定或系统范围的方法是，公共救助在未来变得不那么频繁，考虑到实施严格的新银行处置机制，以促进有序破产，最大限度地减少道德风险，其他强有力的理由仍然存在，以证明事前监管是合理的。由于金融体系的复杂性，要对所推行政策的后果进行合理的事先评估几乎是不可能的。宏观审慎决策的影响在短期内并不明显。因此，宏观审慎监管机构的作用是困难的，特别是考虑到任务的目标和影响经济结果的机制的概念，以及确保宏观审慎政策下的金融稳定与微观审慎政策下单个银行的稳健之间的概念互动，以实现单一监管机制。宏观审慎监管机构需要在经济和金融市场状况良好、没有明显短期利益的时候，在合适的时间限制金融活动，以校准监管和监管安排。否则，这种重心的转移可能会导致宏观审慎监管机构/政策制定者之间的利益冲突，因为这将给他们施加政治压力，迫使他们淡化或推迟以促进经济增长为重点的政策决定。银行业的游说团体更有可能反对提高资本要求(如巴塞尔协议III所规定的)或对交易对手的贷款条件进行更严格的限制，他们可能会试图以信贷成本增加为理由来说服公众同意他们的观点。当经济转向时，担心保护纳税人和存款保险基金的公共部门将不愿接受任何监管和监督安排的放松。

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]

对于应该成为宏观审慎工具包一部分的宏观审慎工具的类型缺乏共识的出现，反映出需要更好地了解宏观审慎工具的设计或应该如何设计和校准。这些挑战，全球金融稳定和问责制，将会得到更好的保证，如果更多的辖区，包括全球(包括美国)，采用更积极的工具，如巴塞尔III的反周期资本缓冲(CCyB)。例如，关于宏观审慎工具包的一些困惑可能在于，对于哪些工具可以被视为宏观审慎，哪些工具不能被视为宏观审慎，缺乏清晰的认识。宏观审慎工具被定义为两类[16]，时间维度[17]和跨部门维度[18]举例来说，《巴塞尔协议III》(Basel III)的资本充足率规则(如果适用于所有金融机构，并在系统性事件发生前启动)将是微观审慎的;如果它只适用于具有系统重要性的金融机构，那就是宏观审慎;如果在响应系统事件时触发，将是灾难恢复管理工具。然而,同时全球不一致的实现宏观审慎工具似乎有问题,这并不奇怪的考虑,可能会影响全球政策工具的选择和组合包含例如由于国家具体情况的诚实程度等关系资本的理由,金融体系的广度和深度，意味着不存在放之四海而皆准的解决方案

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.

可以说，市场纪律可以在激励银行约束资本和流动性风险方面发挥关键作用。《巴塞尔协议II》资本充足率框架采用的理论是，在“第三支柱”下改善披露将在监管和问责发展方面发挥重要作用，从而激励适当的行为。但我们可以有力地证明，过去5年发生的事件表明了市场纪律的不足和问责制的缺乏。

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.

过度冒险(至少在最高管理层)，可能更多地受到广泛的行为和文化因素的驱动，而不是理性地考虑薪酬合同中固有的精确激励:占主导地位的高管人物有强烈的倾向，相信自己的战略。而过度风险的现实往往只能在系统性层面被发现。

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]

话虽如此，银行监管不能(也不应该寻求)创造一种零失败的环境，而是创造一种可以管理机构失败的环境，使其不会危及金融体系的稳定和造成市场混乱宏观审慎监管机构和其他当局在应对金融不稳定方面仍面临重大挑战。决策者所采取的工具、任务和措施的演变的基本教训对监管框架的发展至关重要。毕竟，锚并不比它们所在的土壤更好。在最坏的情况下，如果风险观察不足，资产价值被高估，这片土地可能变成流沙

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