通过国际货币基金组织/世界银行fsap视角对全球银行业现场监管趋势的比较回顾

A comparative review of worldwideon-site banking supervision trendsthrough the lens of IMF/World BankFSAP Alessandro Santoni, Valentina Rapalino,Roberta Nesti Disclaimer:This publication should not be reported as representing the views of the European Central Bank (ECB).The views expressed are those of the authors and do not necessarily reflect those of the ECB. Contents 1Executive summary and introduction3 1.1FSAP61.2Overview of Basel Core Principles (BCPs) and on-sitesupervision principles71.3Sample9 2General overview of on-site inspection structures within severalsupervisory authorities11 3Major areas of improvement in relation to on-site examinationshighlighted by FSAP analysis25 3.1Balance between off-site and on-site supervision253.2Communication of supervisory findings to board of banks273.3Scope of on-site examinations293.4Staffing of off-site and on-site functions303.5Use of externals to conduct supervisory activities323.6Sanctions and enforcement measures343.7Cross-border on-site examinations and home-host relationship373.8On-site examinations on AML topics43 4Conclusion 47 5Annexes 5.1Annex 1: Sampled countries used for this assessment49 5.2Annex 2: Overview of different versions of Basel Core Principles(BCPs) for effective bank supervision50 Abstract The IMF working paper, “Good Supervision: lessons from the field,” examines theeffectiveness of On-site Inspections (OSIs) as a supervisory tool in advancedeconomies (AEs), drawing insights from 60 Basel Core Principles (BCPs)assessments conducted between 2012 and June 2023. Despite their critical role inensuring financial stability, OSIs are identified as the second-largest weaknessamong supervisory techniques in AEs. The study highlights challenges such aslimited supervisory resources, infrequent inspections of smaller banks, and an over-reliance on off-site monitoring, which cannot fully substitute the insights gained fromin-person supervision. Key deficiencies include gaps in OSI scope, frequency,staffing, and enforcement mechanisms, as well as communication and structuralissues. The paper underscores the need for supervisory authorities to balance on-site and off-site methods, enhance staffing and inspection practices, and strengthenenforcement capabilities. These improvements are deemed essential to alignsupervisory practices with BCP standards and foster a more resilient financialsystem. Keywords: On-site Inspections (OSIs), Basel Core Principle (BCP), InternationalMonetary Fund (IMF), supervisory techniques JEL codes: G2, E58 Executive summary and introduction The IMF Working Paper “Good Supervision: Lessons from the Field” (2023) foundthat on-site inspections (OSIs) rank asthe second-largest weakness among thesupervisory techniques used in advanced economies (AEs) (see Figure 1). Theauthors reviewed 60 Basel Core Principles (BCPs) assessments completed between2012 and June 2023, broadly concluding that effective and proactive supervision iscrucial for maintaining stable and sound financial systems. They recommend thatsupervisory authorities closely evaluate their supervisory processes and techniquesagainst best practices in relation to the BCPs. Authorities should focus on ensuringindependence and accountability, clearly defining their mandate, and providingadequate staffing in terms of both resources and skills, as well as legal protection fortheir staff. Among other vulnerabilities, the authors cite the risk of supervisors devoting toomuch attention on large and complex banks due to their systemic importance whilepotentially neglecting smaller banks and the risks they may pose. The authors arguethat this is also connected to the fact that “limited supervisory resources often lead toless frequent and less comprehensive inspections of small banks”. As a result, off-site monitoring becomes the primary supervision method, with more data-driven andstandardised processes employed. The authors also find that external independentparties are sometimes engaged in reviewing risk management systems and controlsbut that, in any case, it is crucial for supervisors to conduct targeted or limited-scopeinspections of small banks. The authors, in their review of FSAP findings spanning a decade (2012-2023),identified that supervisors face resource constraints, thus limiting the time, expertise,and number of resources that can be devoted to supervisory tasks. The authors alsonote that “despite investments in areas such as Suptech and supervisory monitoring,an adequate balance of offsite and onsite supervision remains necessary”, arguingthat regular bank visits cannot be fully replaced by technology or off-site monitoring,as supervision requires verification, and that direct contact is still essential to confirmthe accuracy and reliability of policies, procedures and commitments made tosupervisors. Indeed, as mentioned in the BCBC Working paper: “Lessons on supervisoryeffectiveness: literature review”1(2025) and based on the study carrie