RUSSIAN BANKING SYSTEM AS COMPARED TO INTERNATIONAL TRENDS AND TRADITIONS

RECOMMENDATIONS OF THE 13TH INTERNATIONAL BANKING CONGRESS

ST. PETERSBURG, JUNE 2-4, 2004

 

The congress participants have pointed to largely encouraging trends and improved performance results in the Russian banking sector coupled with its expanding role in the country’s economy.

 

By and large, the development of the Russian banking system is consistent with international trends in banking. There has been a gradual progress towards compliance with international standards in the bank management system, as well as banking regulatory and supervisory environment, technologies and legislation.

 

And yet there is still a number of unsolved problems hampering a further growth of the Russian banking sector. Of paramount importance are high operational risks due to mismanagement and low corporate transparency in the greater part of Russia’s real sector, as well as deficiencies of the economy structure. An inflow of long-term investment is hindered by a continued shortage in medium- and long-term funding. Significantly increasing as it has been in the recent years, confidence in financial intermediaries, including banks, has still remained poor. Another critical problem has been inefficient legislation and law-enforcement practices, for instance, inadequate protection of secured creditors.

 

The congress participants have expressed a favourable opinion on the new version of Russian Banking Sector Development Program aimed at improving the overall economic performance of the banking sector and expected to render Russian credit institutions safer and more competitive, as well as preventing them from being involved in unfair and illegal business activities.

 

Discussions held at the congress have resulted in the following recommendations.

 

To legislative and executive bodies of the Russian Federation in co-operation with the Bank of Russia:

 

To strengthen creditors’ rights, primarily claims secured by pledges. To that end, to introduce amendments to the Civil Code of the Russian Federation and the Federal Laws ‘On Pledges’ and ‘On Insolvency (Bankruptcy) of Credit Institutions’, providing for the following:

-        in case of a debtor in bankruptcy, the possibility for secured creditors to get their claims paid without following the priority rule through selling pledged property; simplifying and unifying procedures for taking over pledged property and paying creditors’ claims secured by pledges;

-        establishing a system for recording pledged movable property and property rights (a registration bureau);

-        expanded usage of out-of-court procedures for taking over pledged immovable property.

In order to reduce the costs and increase the competitiveness of credit institutions, to introduce amendments to the applicable law aimed at:

-        cancelling the authority to exercise unusual functions delegated to banks, in particular, the function of control over customers’ cash discipline, reducing the tax agent function;

-        removing a ban on acquiring bank securities by Russian insurance companies, pension funds and other collective investors;

-        giving credit institutions the right to close dormant accounts without the consent of account holders;

-        cancelling the fee for opening branches of credit institutions;

-        removing restrictions for credit institutions to issue bonds;

-        establishing a simplified procedure for lending to SMEs;

-        streamlining the requirement set for credit institutions to use cash registers and POS equipment.

In order to create more favourable conditions for reducing and managing risks of credit institutions:

-        to provide legislatively for the functioning of a credit bureau on a commercial basis, with due observance of credit account holders’ rights (both legal entities and private individuals)

-        to review the provisions of Article 837 of the Civil Code of the Russian Federation and introduce amendments thereto giving credit institutions the right to provide in a bank deposit agreement a procedure for repayment of a deposit before maturity other than to pay funds on demand without notice of intended withdrawal;

-        to settle legislatively key issues relating to organisation of the market for derivative financial instruments (DFI), in particular, by introducing basic definitions of DFI to the Civil Code of the Russian Federation, and also by adopting a special law regulating the DFI market.

With regard to the intensifying processes of bank capital concentration, to study the possibility of introducing amendments to civil (primarily, the Civil Code of the Russian Federation) and banking legislation simplifying mergers and amalgamations of credit institutions; to introduce amendments to the Federal Law ‘On Banks and Banking’ ensuring that only creditors-private individuals shall be entitled to demand repayment of their cash claims before maturity, provided claims arose before the announcement of a merger/amalgamation by credit institutions.

To reinforce legal mechanisms for preventing dishonest people to establish control over credit institutions; to set legislative requirements for credit institutions to submit data about owners and top management of credit institutions, including data about the financial condition and business reputation of persons who may have a significant influence on decision-making by governing bodies of credit institutions (i.e. beneficial owners).

To take measures to improve legislation on combating money laundering and financing of terrorism in accordance with international standards, in particular:

To set a requirement to identify ultimate beneficiaries of bank transactions and beneficial owners of legal entities;

To expand the authority of supervisory bodies to set requirements relating to organisation of internal control aimed at combating money laundering and financing of terrorism;

To give credit institutions the right to terminate bank account (deposit) agreements in cases envisaged by law.

To improve legal mechanisms for liquidating credit institutions which have their banking licences revoked. To that end, to ensure:

Prompt adoption of amendments to the Federal Law ‘On Insolvency (Bankruptcy) of Credit Institutions’ providing for streamlining and accelerating bankruptcy procedures for credit institutions, enhancing the protection of creditors’ and depositors’ rights, and delegating the receiver function to the Deposit Insurance Agency;

Introduction of changes and additions to the applicable law limiting the possibility to suspend supervisory review measures in case of filing an appeal or in case of filing statements of claim against credit institutions.

In order to create the required legal conditions for sustainable development of the banking sector, promotion of competition and prevention of actions restricting the freedom of commercial activities in banking, to adopt the following amendments to the applicable law:

Providing for the introduction of a notification procedure for acquiring more than 1 per cent of shares (stocks) in the share (stock) capital of a credit institution by residents and non-residents and a licensing procedure for acquiring more than 10 per cent of shares (stocks) in the share (stock) capital of a credit institution by residents and non-residents;

Aimed at protecting the interests of customers during consolidations, mergers and transformations of credit institutions.

To draft changes and additions to the Federal Laws ‘On Banks and Banking’ and ‘On the Central Bank of the Russian Federation (the Bank of Russia)’ aimed at defining more precisely, based on the recommendations of the Basel Committee on Banking Supervision and the best international practice, consolidated supervision provisions, including fixing legislatively the authority of the Bank of Russia to supervise the activities of bank holdings; to bring legal norms regulating the activities of bank groups and bank holdings, as well as disclosure of information about their activities to the interested users, into compliance with the internationally accepted accounting standards.

To determine as the first priority task legislative acceptance of IAS in the Russian Federation and, correspondingly, introduce relevant amendments in the legal base, in particular, the Federal Law ‘On Accounting’.

To accelerate the adoption of the Federal Law ‘On Consolidated Financial Statements’.

 

To the Government of the Russian Federation and the Bank of Russia:

 

To ensure the drafting of legal acts listed in the previous section and the provision of assistance when passing them through legislative bodies.

To take comprehensive measures to organise the functioning of a retail deposit insurance system.

To promptly implement a host of measures based on the requirements of the Federal Law ‘On Currency Regulation and Currency Control’.

To contribute to the growth of demand for bank loans on the part of the real sector of the economy by means of the monetary policy through implementing measures aimed at reducing inflation and interest rates in the financial market and ensuring the predictability of macro-economic indicators and smooth fluctuations in the Rouble exchange rate.

To draft legal acts on co-ordination of burglar-alarm systems used at banking premises setting clear uniform requirements and determining sets of documents to be submitted by credit institutions when getting their branches or other sub-divisions registered.

To provide assistance to regional authorities in implementing regional programs of lending to SMEs.

Based on the improvement of and amendments (additions) to IAS, to continue drafting new and adjusting the applicable legal and normative acts on preparation of financial statements and accounting.

To continuously conduct training and re-training of personnel in charge of preparing financial statements to IAS.

To organise basic professional training for lecturers and students of higher educational establishments, as well as re-training for specialists dealing with accounting and financial statements to IAS.

To start developing uniform educational standards in the area of accounting and financial statements to IAS.

To develop and approve auditing standards regulating the application of international accounting standards (IAS).

To organise the process of teaching IAS to Russian auditors and develop mandatory qualification requirements for auditors certifying the fair presentation of IAS financial statements.

 

To the Bank of Russia:

 

To develop risk-orientated approaches, including the implementation of a rapid response system providing for express evaluation of activities conducted by credit institutions and taking timely and effective supervisory review measures based on, primarily, the nature and real value of banking risks with regard to their potential influence upon the soundness of credit institutions.

In accordance with the applicable law, to realise a host of measures aimed at minimising the risks of the emerging deposit insurance system, primarily through preventing participation in this system of unsound banks.

To continue forming an institute of credit institution overseers.

To amend legal and normative acts so as to provide for a simplified procedure for opening and registration of credit institutions’ branches.

To reduce the number of reporting forms and simplify the reporting procedure for credit institutions.

To issue normative acts regulating the procedure for establishing movable cash offices by banks.

To develop a system of bank refinancing through granting loans secured by government bonds, bonds issued by Russian regions having an acceptable rating, and bonds issued by the Bank of Russia.

To exercise more stringent control over the results of application by credit institutions of internal control rules and procedures aimed at combating money laundering and financing of terrorism, in particular, through implementing, in addition to inspections, a system of remote control over compliance with the relevant law by credit institutions.

To continue publishing macro-prudential indicators characterising key parameters of the banking sector of the Russian Federation, including indicators by region, as well as a list of banks disclosing information on the web-site of the Bank of Russia.

To continue improving the existing payment system of Russia, including measures aimed at enhancing funds transfers, implementing modern data transfer technologies and methods, and providing effective and uninterrupted service to participants of the settlement system.

In co-operation with representatives of the banking community, to develop, based on the experience of the developed countries, a normative document contributing to forming adequate approaches to the activities, and control over the activities, of bank holdings.

Based on the analysis of IAS financial statements of credit institutions as at 31 December 2004, to determine a further procedure for their submission to the Bank of Russia and other parties.

To organise permanent consultations on IAS application, in particular, through placing answers to questions arising at credit institutions on the official site of the Bank of Russia.

 

To credit institutions and their associations:

 

In order to raise the quality of bank service, to develop management systems, including risk management, and internal control; to widely use the best international practice reflected inter alia in the recommendations of the Basel Committee on Banking Supervision.

To strengthen activities aimed at raising asset quality.

To avoid ‘fraud’ capitalisation and other forms of ‘window-dressing’.

In order to prevent the penetration of criminal capital into the Russian banking sector, to ensure compliance with the requirements of the Federal Law ‘On Combating Money Laundering and Financing of Terrorism’, being guided by the best international practice.

To ensure the transparency of credit institutions’ ownership structure.

To enhance the transparency of credit institutions’ activities based on the international banking practice; to ensure unconditional reliability of disclosures; to undertake measures ensuring an effective access of interested users of all categories (shareholders, members, customers and counterparties) to the information about the activities of credit institutions disclosed in accordance with the applicable law. For the purposes of timely and reliable disclosure of information about own activities, to use Internet resources more widely, primarily through creating and maintaining own Internet sites.

In order to effectively solve the task of combating money laundering, to ensure compliance with the principle ‘Know Your Customer’, continuously take efforts aimed at raising the professional level and banking culture of bank employees guided by the internationally accepted business ethics, including the Code of Banking Ethics approved by the banking community in April 2002.

To develop and adopt corporate governance standards within the framework of bank associations.

To pay special attention to training credit institutions’ specialists in the area of IAS application.