关于银行贷款损失准备制度的调查报告——以我国五家上市银行为例的分析

An investigation on the System of Provisioning for Loan Losses-the Analysis of the Five Listed Banks in China

本报告总结了我国贷款损失准备制度的历史沿革,分析了五家上市银行贷款损失准备计提情况,并对辖区相关机构进行了调研,发现:(1)五家上市银行贷款损失准备有明确的计提范围,但行际之间计提范围有差异;(2)贷款损失准备计提比例符合监管当局的原则性要求,但各行提取比例有差异;(3)计提损失准备时各行对抵押物金额扣除不同;(4)不良贷款拨备覆盖率呈逐年上升(除深发展)趋势,抗风险能力趋于增强;(5)部分机构逻辑上存在利用贷款损失准备操纵利润的可能;(6)仅仅从贷款损失准备比例看,大多未体现周期特征,在经济周期高点可能相对少计提;(7)调查中发现五级分类目前还存在问题,贷款损失准备计提的基础不牢靠。在此基础上,结合调研掌握的具体情况,本报告认为:(1)银行监管、财政、税务等部门应加强协调,进一步规范贷款损失准备计提制度;(2)进一步完善贷款五级分类制度,夯实损失准备计提的基础;(3)结合我国目前信用环境,需要研究五级分类、贷款损失准备计提这两个环节抵押品、有效担保的处理原则,避免重复考虑、高估价值,使贷款损失准备计提更加审慎;(4)五级分类、特种准备、一般准备、专项准备以及分红政策等方面要充分考虑经济周期或者行业周期波动的影响,以使贷款损失准备的计提更为前瞻、审慎,确保提足损失准备,及时弥补损失,增强资本基础,提高抗风险能力;(5)区别对待,分类监管;(6)重视贷款损失准备、资本充足率监管在货币政策传导方面的作用及其产生的宏观效应。

With the summary of provisions for loan losses history and the investigation on the financial institutions in the Northwest part of China, the paper analyses the provisioning for loan losses in five listed banks and finds that: 1) Specific bases are set individually in the five listed banks, but the bases differ slightly; 2) The percentages of provisioning for loan losses are in line with the 'Guidance on Provisioning for Loan Losses', but the percentage differs with each other in the five banks; 3) Mortgage values are deducted differently in setting aside provisions for loan losses; 4) The coverage of provisions for NPL is on a annually rising trend(excluding the Shenzhen Development Bank) and the capability to forestall risks is improving; 5) Logically some financial institutions may manipulate the profit with the provisions for loan losses; 6) Most of the percentages of provisions for loan losses show no economic cycles, comparatively less provisions may be set aside on the economic cycles peak; 7) Through the investigation, many problems are found on the five-grade loans classification, maybe incorrect provisions are set aside for loan losses. Based on the above issues, the paper arrives the following conclusions: 1) The system of provisioning for loan losses should be further standardized with the coordination of banking regulatory sector, fiscal and tax sectors; 2) The five-grade loans classification system should be improved to better side aside the provisions for loan losses; 3) Considering the present credit environment in China, the operation principles for the mortgage and effective guarantees should be reformed in five-grade loan classification and provisioning for loan losses to avoid duplicated calculation and over-evaluation, so as to create a prudent system of provisioning for loan losses; 4) The economic cycles or industry cycle fluctuation should be taken into account in the five-grade loan classification, specific, general and special reserves, and bonus policy, thus more forward-looking and prudent provisioning for loan losses should be stipulated, so as to set aside adequately the provisions for loan losses and cover the losses, improve the capital quality and the capability to forestall the risks; 5) Different category measures should be applied in supervising the financial institutions; 6) Importance should be attached into the macro-effect of the supervision of provisions for loan losses and the capital adequate ratio.