影子银行监管与银行风险防范

Shadow Banking Regulation and Bank Risk Prevention

完善的现代金融监管体系是我国金融业稳定健康发展的重要保障。本文研究发现,2014年针对买入返售业务的影子银行监管政策(银发[2014]127号)显著地降低了银行杠杆率,并使影子银行活动的风险显性化,抑制了银行破产风险。但监管政策实施后,银行创新出同业投资、同业链条的新模式,继续从事影子银行活动,使期限错配问题加剧,流动性风险提高。这表明,影子银行的业务模式在金融创新和监管政策的博弈过程中不断演变,政策制定具有时间局限性,难以一劳永逸解决未来的所有风险。本文研究的政策含义在于,监管政策应遵循“疏堵结合”的思路,在规范化、透明化影子银行业务的同时,拓展正规信贷业务,保障银行盈利来源,从而提升金融监管的效果,助力实体经济发展。

Since 2009,China's regulators have issued a series of measures to address shadow banking activities and have achieved remarkable results.It can be seen that the results do not come from a single policy,but stem from repeated games between financial institutions and regulatory authorities.Therefore,this paper tries to take China's shadow banking regulation as an"anchor"to explore the inherent relationship between the logic of financial regulation and institutional market reflection.The development history of China's shadow banking and regulatory evolution can be divided into three stages:the first stage(2008-2013),governance channel business,curbing the non-standard out of the table of the regulatory stage;the second stage(2014-2016),regulating interbank business and outsourcing investment stage;the third stage(2017-),improving the compliance of shadow banking and the comprehensive regulatory stage.Among the above three stages,the regulatory policies in the"interbank business"stage are relatively focused and specific.The Notice on Regulating Interbank Business of Financial Institutions[2014]No.127,as a shadow banking regulatory measure targeting interbank business,effectively solved the legacy problems after the restriction of channel business in the previous stage,but also led to a new shadow banking business model,reflecting the important feature of the repeated games between the development of China's shadow banking and the evolution of regulation.Therefore,this paper takes the Notice issued in 2014 as an exogenous shock and tests the relationship between shadow banking regulation and bank risk by constructing a DID model using the annual panel data of 178 commercial banks in China from 2010 to 2017.The empirical results show that shadow banking regulatory policies significantly reduce bank insolvency risk.The mechanism analysis finds that Document No.127 enhances transparency in the shadow banking business,significantly reduces bank leverage ratios,and improves risk profiles;at the same time,the policy also encourages the development of interbank certificate of deposit business,which protects the profit source of banks.However,the business model of shadow banking is also evolving during the game of financial innovation and regulatory policy,which may weaken the policy effect.We find that after the issuance of Document No.127,the interbank investment and interbank chain model emerge,receivables-based investment has become a new vehicle for shadow banking business,and the maturity mismatch problem of banks has not been effectively solved.The policy implications of this paper are as follows.First,financial regulatory policies should adhere to the"combination of blocking and dredging"approach.Regulatory policies need to"block"high-risk businesses while paying more attention to"dredge"the objective supply and demand of the credit market.Second,regulatory policies should follow the idea of dynamic adjustment.Supervisory authorities should possess a certain level of policy foresight,timely adjust the regulatory targets,and pay attention to the changes in the market business model after introducing regulatory policies.The contributions and significance of this paper mainly lie in the following aspects.First,the existing literature extensively discusses the effectiveness of regulatory policies.Still,it lacks an assessment of the effect of specific policies in typical regulatory scenarios and an exploration of the mechanism.This paper focuses on China's shadow banking regulatory policy and explores the internal mechanism of the impact of regulation on micro-institutions.Second,the academic community has not yet reached a consensus on whether to regulate shadow banking activities.The findings of this paper,to a certain extent,respond to the necessity and effectiveness of shadow banking regulation.Third,it discusses the changes in the shadow banking business model and the legacy risks caused by the disappearance of the original arbitrage space after the implementation of regulatory policies,which helps to clarify the idea of dynamic adjustment of a series of shadow banking regulatory policies in China.