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1
Transitional Issues in Emerging Market
Economies El Salvador Presentation for the
World Bank Ana Margoth Arévalo, Superintendence
of the Financial System El Salvador Washington,
Dec. 5th., 2003
2
  • Outline
  • Background
  • Timeframe
  • Rationale for the separation.
  • About the agencies
  • Mechanisms of coordination
  • The Central Banks Role
  • An evaluation of the Process
  • Final Remarks

3
  • Background
  • Nationalization of banks and savings and loan
    associations
  • The SSF, the Central Bank, and the Monetary
    Board

4
  • Timeframe
  • Two stages
  • The separation of banking supervision (The SSF)
    from the Central Bank (1990)
  • The creation, almost simultaneously, of two new
    supervisory agencies the Superintendence of
    Securities (1996) and the Superintendence of
    Pensions (1996), but with different processes

5
  • Rationale for the separation
  • The separation of the Superintendence from the
    Central Bank responded to a comprehensive reform
    program that sought to redefine the role of the
    Central Bank regarding monetary, credit and
    exchange policy and to modernize the financial
    system.
  • The creation of the two new agencies were
    decisions responding to specific needs. One
    related to the development of the securities
    market, the other derived from the establishment
    of a new system of pension funds.

6
  • From the Central Bank to an independent agency
  •  
  • The 1990s reforms gave the Central Bank more
    autonomy, a new mandate, promoting financial
    stability and developing an efficient and
    competitive financial system. It could no longer
    fix interest or exchange rates nor finance,
    directly or indirectly, the government
  • Financial sector reforms included reforming
    legal and institutional frameworks, restructuring
    and privatizing banks and savings and loan
    institutions, and strengthening financial
    supervision. Its new organic law gave (1990) the
    Superintendence autonomy, although it is still
    an integrated institution to the Central Bank.

7
STRUCTURE OF FINANCIAL SUPERVISION
8
  • About the Agencies
  •  
  • All three are headed by a Superintendent
    appointed by the President. Two of them have a
    Board of Directors whose members are independent.
  • Funding sources differ between the agencies. All
    receive funds from fees paid by supervised
    entities. However, whereas the SSF receives
    funds from the Central Bank, the rest depend on
    the general government budget .
  • Regulatory schemes differ. Whereas regulation
    for banks is approved by the SSFs Board of
    Directors, that for the security market and
    pension funds must be issued by the President,
    from proposals made by the superintendencies.

9
  • Mechanisms of coordination
  • Established by Law
  • The Superintendent Committee, formed by all
    superintendents. It must consider matters such
    as adoption of supervisory criteria and
    policies, review of laws and regulations,
    coordination of financial groups supervision.
  • A mandate to keep adequate mechanisms of
    communication and information sharing.

10
  • Mechanisms of coordination
  • The possibility of establishing common
    administrative units and of outsourcing services.
  • The Risk Committee, formed by the Superintendent
    Committee and the President of the Central Bank.
    Its objective is to determine investment limits
    per type of instrument, terms, and rating
    requirements for the investment of pension funds.
    It must meet at least once a year.

11
  • The Central Banks Role
  •   Regulates the payment system, provides
    clearing and settlement services for payment
    transactions, and does a general monitoring of
    the financial system and liquidity.
  •  With the implementation of the Monetary
    Integration Law in January 2001, it lost its
    role as lender-of-last-resort.
  •  It does not supervise institutions. However,
    its favorable opinion is needed for, among
    others, revoking temporarily or permanently a
    bank license, updating minimum capital
    requirements or imposing additional ones.

12
  • The Central Banks Role
  • In case of systemic risk, the decision to
    allow the Deposit Guarantee Institute to support
    restructuring a bank must have a favorable
    opinion from the Committee whose members are the
    President of the Central Bank, the head of the
    SSF, and the Finance Minister.

13
  • An Evaluation of the Process
  • There is consensus that the agencies are now
    technically stronger, and have more supervisory
    and regulatory power. However, there were
    deficiencies in the process that led to a crisis
    which prompted a deep review of the
    Superintendences technical capacity and the
    need to assess the accuracy of the regulated
    institutions accounting records.
  • The crisis made evident the need to implement
    consolidated supervision and to
    strengthen enforcement capacity of the
    superintendencies.

14
  • An Evaluation
  • Administrative cost of supervision is higher as
    is the transaction cost for the regulated
    institutions. 
  •  
  • There are also issues regarding regulatory
    arbitrage
  • More important is the need to increase protection
    for supervisors so that they effectively carry
    out their responsibilities
  •  

15
  • Final Remarks
  •  
  • Regulators and supervisors in El Salvador are
    very aware of the importance of realizing a
    comprehensive consolidated supervision of
    financial conglomerates, and of the need of
    cooperating and sharing information effectively
    and efficiently among them.
  • Presently, a program is being develop to
    strengthen their technical capacities and to
    refine cooperation and coordination arrangements
    between them.
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