银行业不当行为风险、行为成本与金融稳定——全球金融行为监管和风险治理的焦点领域

Banking Misconduct Risk, Conduct Cost and Financial Stability——The Focus Area of Global Financial Conduct Regulation and Risk Governance

近年来国际银行的不当行为问题受到各国监管机构日趋严格的审查。文章界定了不当行为风险的定义,分析了国际银行行为成本的表现以及不当行为风险对金融稳定的影响。研究发现,不当行为风险的关注点在于消费者,在行为后果上强调行为本身带来的一系列负外部性;战略风险和声誉风险分别是不当行为风险的可能诱因及后果;操作风险、法律合规风险与不当行为风险既有联系又有区别;国际银行近年因不当行为所产生的成本已达到相当大的规模,行为成本可以大致作为银行伦理道德的衡量指标;不当行为风险及相关处罚还可能对金融稳定产生难以估量的影响。文章有益于中国银行业和监管层深化认识不当行为风险问题的严峻性,为行为成本概念的标准化、银行道德行为水平评估和判断不当行为风险防控是否有效提供参考依据,并通过该风险的治理以提高消费者福祉、防范系统性风险和维护金融稳定。

In recent years, the issue of misconduct in international banking has been increasingly scrutinized by international regulatory authorities s. This paper defines the definition of misconduct risk, analyzes the characterization of conduct costs in international banking and the impact of misconduct risk on financial stability. It comes to the conclusions as follows, firstly, the main focus of the misconduct risk is consumers, and it emphasizes a series of negative externalities of conducts in terms of consequences; secondly, strategic and reputation risks are the likely incentives and consequences of misconduct risk; thirdly, operational, legal compliance and misconduct risks have both connections and differences; fourthly, the cost of international banking has got a great scale due to the issue of misconduct in recent years, and the conduct cost can roughly serve as a measure of bank ethics; fifthly, misconduct risk and related penalties may also have an immeasurable impact on financial stability. This paper is helpful for China＇ s banking industry and regulatory authorities to deepen the awareness of the misconduct risk. It provides references for standardizing the concept of conduct cost, assessing the level of banking conduct, and determining whether the risk control is effective. Misconduct risk governance helps to improve consumers＇ welfare, prevent systemic risks and maintain financial stability.