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Countermeasures to improve macro-prudential supervision and suggestions to China's financial supervision system
With the release of Basel III at the end of 20 10, CBRC actively promoted the implementation of Basel III in China, and is studying four new regulatory tools, namely dynamic capital, dynamic provision, leverage ratio and liquidity, to build a new regulatory framework for the banking industry in China. As can be seen from the main contents of Basel III listed above, the New Basel Accord emphasizes the importance of "countercyclical supervision" (cross-time dimension supervision), trying to smooth out the economic fluctuations brought about by the internal procyclicality of the financial system through hard quantitative supervision indicators, while ignoring the cross-institutional dimension supervision. The author thinks that the financial supervision system of China in the future should not be limited to meeting the requirements of the new agreement in terms of quantitative indicators, but should be based on the development status of China's banking industry and design a supervision system conducive to its own development and financial stability. 1. Tax on systemically important financial institutions. With the bankruptcy of Bear Stearns, Lehman Brothers and other large investment banks, the US government immediately launched a $700 billion financial aid program to save these "too big to fail" financial institutions. The negative externalities of the financial system have caused huge losses of public wealth and social welfare, and at the same time, negative externalities have damaged the efficiency of resource allocation, making it difficult to reach the Pareto optimal state. When solving the problem of negative externalities, the means based on motivation is better than direct command or control, and Pigou tax is a typical method based on motivation. Pigou believes that the tax levied on activities that produce externalities is equal to marginal social losses, which can promote the competitive equilibrium of the economy to reach the Pareto efficiency boundary again. The author believes that the regulatory authorities can follow the example of the Federal Deposit Insurance Corporation (FDIC) and levy a "financial stability contribution tax" (FSC) on domestic systemically important institutions, and accumulate the tax into a "rescue fund", which will be mainly used to pay the rescue costs of banks and financial institutions in the future.

Judging from the development of China's banking industry, taxing domestic systemically important banks will only reduce the current profits of banks and will not fundamentally weaken their competitiveness. China's systemically important financial institutions (industry, agriculture, China, construction and communications) have all received capital injection from the state finance, which means that taxpayers bear all the costs in the process of bank share reform. Managers operate well, and the value-added income of state-owned financial capital belongs to the state; Managers are not well managed, and the loss of state-owned financial capital is also borne by the state. In order to avoid taxpayers' additional risk losses to systemically important banks during the crisis, it is particularly necessary to levy financial stability tax on domestic systemically important banks.

2. Strengthening the supervision of financial innovation Considering the development status of China's banking industry, it is not advisable to limit the scale of bank assets and reduce the substitutability in order to control the risks of systemically important financial institutions. The most effective way is to reduce the risk correlation of systemically important financial institutions. The financial crisis shows that the innovation of financial products can only transfer and disperse risks, but not reduce them. With more and more innovations in financial derivatives, their risk accumulation will be higher and higher. Therefore, the focus of strengthening financial innovation supervision is to strengthen consolidated supervision and supervision of wealth management products, requiring all systemically important banks to effectively implement consolidated system and wealth management products, so as to achieve "controllable cost, controllable risk and true disclosure of information". The regulatory authorities should base financial innovation on the effective demand of the real economy, bring financial product innovation activities into a clear legal and institutional framework, effectively regulate financial product innovation, and minimize the negative impact caused by the leverage amplification effect of financial innovation. In 2007, McCully, executive director of Pacific Investment Management Company, first proposed the concept of shadow banking. 20 10 September, Federal Reserve Chairman Ben Bernanke defined shadow banking as "a financial institution that acts as an intermediary to transfer savings to investment in addition to regulated deposit institutions", which generally includes mortgage companies, hedge funds, private equity funds and structured investment vehicles (SIV). Due to the complicated product structure design and insufficient information disclosure of shadow banking, it is difficult for regulators and financial market participants to identify a series of risks, including product risks and counterparty risks. In addition, because shadow banking has no rigid constraint on capital adequacy ratio, although its own funds are few, its business scale is very large, and the potential credit expansion multiple may reach dozens of times.

Since 20 10, with the implementation of China's prudent monetary policy, domestic banks are facing the contradiction between strong credit impulse and credit line. In order to avoid the limitation of loan scale, commercial banks have launched "shadow banking" businesses such as bank-credit cooperation and credit asset transfer, which leads to huge potential risks in the financial system. Therefore, the regulatory authorities should pay special attention to the influence of "shadow banking" on the stability of the financial system. First of all, according to the business scale and characteristics of shadow banking, the regulatory authorities should clarify the capital and liquidity requirements, establish a strict inspection system combining off-site supervision and on-site supervision, and control the leverage ratio of financial products. Secondly, the regulatory authorities should require shadow banks to disclose information including product design, product sales and transaction methods to them regularly or in time, so as to improve the transparency of financial products and financial markets. Finally, it is necessary to strengthen international cooperation between regulatory authorities. The subprime mortgage crisis in the United States quickly spread to the global financial system and the real economy, which is inseparable from the international development of shadow banking. Therefore, domestic regulatory authorities should actively participate in the construction of global financial regulatory system, strengthen cooperation with international organizations such as IMF and G20 in the fields of information sharing, accounting standards and legal system coordination, and establish a joint emergency mechanism to deal with the financial crisis. 20 10 Zhou Xiaochuan, Governor of the People's Bank of China, summed up the systemic risks faced by China's financial system at the "Macro-prudential Policy: Advanced Seminar from an Asian Perspective": "The momentum of continuous expansion of domestic credit is still strong, and cross-border capital flows contain potential risks. Macro risks such as excess liquidity, inflation, asset price bubbles, and cyclical non-performing loans have increased significantly, and the asset quality and risk resistance of the financial industry are facing severe tests. " Since 2008, under the loose monetary policy, China's economy is facing the dual pressures of increasing internal inflation pressure and external exchange rate war. The emergence of excess liquidity and financial products that evade policy restrictions also makes financial regulatory authorities face unprecedented challenges.

Under the condition that the current monetary policy does not change the basis of total adjustment, monetary policy and macro-prudential supervision have different policy objectives and tools, which are difficult to replace each other. Therefore, it is necessary to strengthen the coordination between monetary policy and macro-prudential supervision. In fact, a core issue facing the central bank is not the trade-off between price stability and financial stability, but how to make a decision between current economic stability and future economic stability, that is, the implementation of policies must comprehensively evaluate the economic situation from the dual perspectives of price stability and financial imbalance. When signs of overheating appear, if monetary policy remains loose, any subsequent macro-prudential tools will be difficult to work. In other words, the structural adjustment advantage of macro-prudential supervision must be based on appropriate monetary aggregate adjustment.

Therefore, in order to maintain the stability of the financial environment, in terms of system design, monetary authorities and regulatory authorities should establish a joint meeting system of monetary policy and financial supervision as soon as possible, hold regular consultations on major issues in financial operation, and inform each other of the implementation and orientation of monetary policy and financial supervision policies in a timely manner; It is necessary to strengthen the information sharing between the two, establish a unified and efficient financial information center as soon as possible, and prevent financial institutions from arbitrarily transferring financial assets and conducting illegal operations from the perspective of evading financial supervision; It is necessary to announce the operation of monetary policy and financial supervision on a regular basis by means of improving transparency and guiding public expectations, so as to show the public the attitudes and views of monetary authorities and financial supervision authorities on the current financial operation, adjust financial intermediaries through market means, prevent or slow down the impact of financial markets on financial policy expectations, and maintain the stable operation of financial markets.