Sunday, 30 June 2024

Criteria for the Regulation & Supervision Awards

Regulators will be evaluated according to three basic functions of regulatory oversight that they may perform - macroeconomic regulation, systemic and prudential regulation and conduct of business oversight and their effectiveness in fulfilling these roles. This is done using three scorecards developed to capture the essence of the role of regulators, their effectiveness and the benchmarks they need to adhere to. The indicators used to evaluate the dimensions listed in each of these scorecards, tend to be more qualitative rather than quantitative. This is because an assessment of this kind needs to take into account the various shades of grey that exist around how regulators go about performing their duties. We believe a binary scoring model would not be able to capture the true essence of regulation, given its peculiar challenges and constraints.

Balanced Scorecard for the Best Macroeconomic Regulator Awards

This scorecard has been designed primarily to assess and benchmark central banks and the role that they play in maintaining financial stability. Central banks use risk management, monetary analysis and liquidity management as the core tools to ensure macroeconomic financial stability. These combined with other indicators such as their perception among domestic banks and businesses, level of international co-ordination and the level of technology and operations can help assess regulators of this kind.

Evaluating Dimension Weightage(%)
1. Market intervention capability 20
  Frequency and impact of interest rate intervention
  Effectiveness of price stability measures taken
  Effectiveness of open market operations
  Ease of collection of data for market activity, transaction prices & counterparty exposures for market participants
2. Liquidity Management 20
  Types of liquidity tools used
  Effectiveness in the past 2 months
3. Independence and governance structure 15
4. Degree of International co-ordination 15
  Senior representation in international forums such as the G20 and BCBS.
5. Technology and Operations 15
  Level of automation in treasury operations
  Level of automation in business processes
  Level of automation in clearing and settlement
6. Quality and consistency of reports 10
  No. of different types of reports [ more variety higher score]
  Frequency of each report [ higher frequency-higher score]
  Comprehensiveness in topics covered
  Usability of data
  Availability and ease of use online
  Annual report- level of comprehensiveness (policies explained, boxed case studies etc.)
  Size of recent investment in technology
  Level of automation in treasury operations
7. Perception of domestic banks and businesses 5
  "They may not like you, but do they respect you?"
  Final Score 100

Balanced Scorecard for the Best Macroeconomic Regulator Awards

Keeping in check, the build-up of systemic risk in the system- safeguarding the so called too big to fail financial institutions, the collapse of any one of which can paralyze the entire financial system- is understood to be the job of the macro- prudential regulator responsible for the oversight of all deposit-taking institutions. This scorecard assesses how the regulator perceives its own role, whether it has the capability to carry out that role and if it does a good job in fulfilling that role. In this scorecard we rely heavily on the philosophy of looking at what the regulator does rather than the approach it uses as evidenced in evaluating dimensions that take into account, the health of the systemically important institutions being regulated.

Evaluating Dimension Weightage (%)
1. Self-defined scope of coverage 20
  Clarity in defining policy on intervention
  Transparency and consistency in conduct
2. Independence and governance 10
  Appointment procedures of senior staff of the agency
  Quality of accountability mechanisms (if any)
3. Profile of institutions regulated 10
  Number of institutions
  Total loans as a percentage of GDP
  Market share of top 10 ( if applicable) by total assets
4. Quality of institutions regulated 20
  Current average CAR (Tier 1) of the top banks representing more than 70% of the country’s total bank assets
  Current average NPL ratio of the top banks representing more than 70% of the country’s total bank assets
  Current average LTD ratio of the top banks representing more than 70% of the country’s total bank assets
5. Control of foreign institutions operating in the country 10
  No. of full license foreign institutions in the country
  Percentage of total assets of the banking system held by foreign institutions [More assets, system more susceptible to systemic risk]
6. Coordination with other agencies (central bank, government etc.) 10
7. Quality of recent systemic risk aversion exercise 20
  Was there one?
  Was it necessary?
  Was it handled well?
  Final Score 100

Best conduct of business regulator

The conduct of all firms, including all those authorised and subject to prudential supervision and their dealings with ordinary retail consumers, in wholesale markets and market conduct in general falls under the purview of the conduct of business regulator. The main idea behind its existence is to be able to ensure confidence in financial services and markets, with a particular focus on protecting consumers and ensuring market integrity. Apart from being transparent and independent, the composition of the regulatory board - industry players being a part of the board- play a major role in measuring its effectiveness.

Evaluating Dimension Weightage (%)
1. Transparency 20
  Clarity in the agency's mandates, objectives, rules responsibilities and procedures
  Appointment procedures of senior staff of the agency.
  Strength of Accountability mechanisms
2. Independence and governance 20
  Method of appointment of the managing board
  Method of appointment of governor
  Immunities if any enjoyed by the governor and/or board members
3. Conflict of interest Vs. closeness to the industry 20
4. Presence of an Ombudsman in the system (not necessarily in this institution) 15
  Track record in resolution of issues
5. Right to punitive enforceable action 25
  Exists
  Does not exist
  Exercised in the past 3 years?
  Final Score 100