金融控股公司监管的国际经验

International Experience in the Supervision of Financial Holding Companies

目前世界各国对金融控股公司的界定尚无统一标准,对金融控股集团实质上定义有较大差别。这种差别使得不同国家对金融控股集团的设立条件和监管表现出不同特征。金融控股公司的设立既要以自身特点和未来战略定位为出发点,在此前提下规划应纳入哪些金融业务或附属业务才能实现业务的互补和资源的协同,同时要兼顾风险传染和利益冲突等问题。为了规范金融控股公司的设立,美国、日本都以法律的形式对金融控股公司的设立条件和业务范围做出了规定。与单个金融机构相比,金控集团风险的整体性、关联性和交叉性更加突出,因此国际组织和各金融发达国家均对金控集团的管理目标、风险要素和监管方法进行理论和实践探索,已形成相对成熟的监管经验。金融控股公司的监管以并表监管为基石,也就是“对金融控股集团整体实力定性和定量的评价”,在监管中重点关注内部风险传递、资本充足率、监管套利、内部利益平衡和系统重要性金融机构。

Each country has its own understanding, which leads to the great differences in the conditions for the establishment and regulation of financial holding groups. The establishment of a financial holding company should not only be based on its own characteristics and future strategic position, but also on the premise of planning which financial businesses or subsidiary businesses should be included in order to achieve business complementarity and resource coordination. Moreover, issues such as risk contagion and conflict of interest should also be taken into account. In order to regulate the establishment of financial holding companies, both the United States and Japan have stipulated the standards in the form of laws. Compared with general financial institutions, the risks of the financial holding groups are more integrated, correlated and cross-linked. Therefore, international organizations and developed countries have conducted theoretical and practical exploration on the management, risk avoidance and supervisory methods of the financial holding groups, and have formed relatively mature regulatory experience. The supervision of financial holding companies is based on consolidation supervision, which is “qualitative and quantitative evaluation on the overall strength of financial holding groups”. The consolidation supervision focuses on internal risk trans-mission, capital adequacy ratio, regulatory arbitrage, internal balance of interests and systemically important financial institutions.