整合,合并或?qū)I(yè)金融市場(chǎng)主管:有一個(gè)最優(yōu)的解決方案嗎?
Insurance & Pension Funds Supervisory Commission,

The article discusses the issue of the financial market supervision in its institutional context and explores its various dimensions. Its intention is to review the origins and directions ofinstitutional restructuring of the supervision taking place in the last 15 years and to discussits opportunities and threats. The actual debate is preceded by an analysis of recentfinancial market trends as well as regulatory and supervisory developments. The message ofthe article is that there are no ideal supervisory models and each jurisdiction has to find itsown way. In doing so, it should always care for the preservation of the most criticalproperties of the supervisory system: its independence, accountability, transparency,integrity and market responsiveness.
Keywords: supervision; consolidated supervision; insurance regulation; supervisory process;supervisory models
Introduction
The dramatic growth in the importance of the financial markets over the last decadesfor the economic well-being of nations has generated rapidly an increasing body ofliterature on various aspects of regulation and supervision. This literature covers suchissues as scope and size of regulation and supervision; its benefits and costs; therespective roles of regulation and self-regulation; aims and tools of regulatory andsupervisory activities; the components of regulatory and supervisory layout; theinterplay between regulation and supervision; and cross-border regulatory and
supervisory cooperation and the like.Most recently, particular attention has been given to the institutional aspects of
financial regulation and supervision. This reflects recent changes taking place inseveral countries in the institutional set-up of financial markets regulation and
supervision and the need for the clarification of its drivers as well as its consequences.
In particular, the convergence of specialized sectoral supervisors in banking, insuranceand securities into more or less integrated regulatory and supervisory agencies hasbeen by and large put through as political rather than economic or managerial
projects.
* The paper is an outcome of a lecture presented at the 22nd Progress International Seminar, held on 30–31st
March, 2006, in Geneva.
The Geneva Papers, 2007, 32, (151–162)
r 2007 The International Association for the Study of Insurance Economics 1018-5895/07 $30.00
www.palgrave-journals.com/gpp
Increased emphasis in the current debate is given to the question of the possible#p#分頁(yè)標(biāo)題#e#
impact of the particular institutional structures on the efficiency of regulation and
supervision in achieving their major objectives.
The intention of the present paper is to review major issues of the above discussion
of the topic and to offer some analytical framework for further debate. The paper
starts with a presentation of some major market trends in the financial sector, which
are the final drivers of the regulatory and supervisory changes. It is followed by a brief
review of regulatory and supervisory trends. The next section discusses the notion of
an integrated supervisor and examines various directions and degrees of integration. It
is followed by an assessment of the drivers of supervisory integration as well as its
constraints. Finally, the potential rewards and costs of integration are discussed.
Financial market trends
Over the last decades financial services and financial markets have been growing
dynamically in all parts of the world, thus confirming their fundamental role in the
current economy. By the end of 2004 the world total of financial assets was estimated
at USD152 trillions, of which 37 per cent were accounted for by EU, 31 per cent by the
United States and 14 per cent by Japan.1 The value of these assets exceeds significantly
GDP level in the world (369.2 per cent), EU (457.8 per cent), U.S. (460.6 per cent) and
Japan (467.2 per cent). In Luxembourg, the value of the financial assets surpasses
national GDP by 25 times.
Particular growth drivers of the financial market in recent years have been,
increasingly, institutional investors that have taken over the lead from a traditional
banking industry. As of 2004, bank assets accounted only for around one-third of the
world total financial assets and in the United States only for about 18 per cent of the
total. In the EU, this share was substantially higher; however, it has decreased in
recent years.
In OECD countries alone, institutional investors managed in 2003 financial assets of
a value close to USD 47 trillions, representing roughly 160 per cent of their GDP.
They are spread evenly between insurance companies (about USD14.5 trillions in
2004) pension funds (USD15.3 trillions in 2004) and investment companies (USD16.2
trillions in 2004). Hedge funds play still a minor role, representing roughly only
USD0.9 trillions in 2004 (see Table 1).
Altogether, assets managed by institutional investors nearly tripled in 1990–2004.
Particular dynamic growth in 1990–2004 was recorded in the assets managed by
investment companies and hedge funds. Pension funds preserved their relative position
on the market. On the other hand, there was some downgrading as institutional
investors of the insurance companies.
Institutionalization of the financial market investments coincides with a growing#p#分頁(yè)標(biāo)題#e#
size and role of household financial assets. According to the U.S. market data, roughly
50 per cent of U.S. households held in 2005 mutual fund products as opposed to only
1 IMF (2006, p. 155).
The Geneva Papers on Risk and Insurance — Issues and Practice
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about 6 per cent in 1980 and 25 per cent in 1990. Mutual funds’ share of household
financial assets has climbed up from 6.8 per cent in 1980 to 20.3 per cent in 2005.2
Enhancement of the financial market and its institutionalization is paralleled by its
growing concentration and internationalization. According to the U.S. data, the top
five banking companies in this country increased their domestic deposits share from 8
per cent in 1990 to 21 per cent in 2001, whereas the share of the top 25 banking
companies climbed up from 25 per cent to 45 per cent, respectively.3 The top 10 global
insurance companies assumed over 26 per cent of the world premiums in 2004,
whereas the respective share of the 10 global life/health insurance companies in
worldwide premiums exceeded 30 per cent.4 A much higher concentration ratio is
traditionally observed in the reinsurance business. Data for 2004 suggest that over 75
per cent of the worldwide premium ceded was assumed by the top 10 global reinsurers.
It is a widely held belief that in principle a few hundred financial groups currently
dominate the world market. The same groups are by and large responsible for the
growing globalization of the market place. Its degree could be judged from the figures
related to the EU market. They indicate that the role of foreign investors in the
financial business assumed in the region increased from about 10 per cent in the early
1990s to around 25–30 per cent in 2003–2004.5
The same groups are also the principal drivers of the spread of conglomerates in the
financial market. Their market share has been rapidly increasing since the beginning of
the 1990s. The EU Commission Services estimate that, as a weighted average, financial
conglomerates account for approximately 30 per cent of the deposits and 20 per cent of
premium income in EU 15 member states. In the smaller ones, their market share
exceeds even 50 per cent.6 According to some other estimates, their share may be even
higher.7
The growth of financial conglomerates reflects the blurring of the existing
intersectoral borders and provides for the rise of cross-sectoral business offer or –
to put it in a different way –produ ct hybridization. As a result, integrated financial
Table 1 Assets under management by institutional investors in OECD countries (in trillions of USD)
1990 1995 2000 2003 2004
1. Insurance companies 4.9 9.1 10.1 13.5 —
2. Pension funds 3.8 6.7 13.5 15.0 15.3
3. Investment companies 2.6 5.5 11.9 14.0 16.2
4. Hedge funds 0.03 0.10 0.41 0.80 0.93#p#分頁(yè)標(biāo)題#e#
5. Total institutional investors 13.8 23.5 39.0 46.8 —
6. Investment/GDP (per cent) 77.6 97.8 152.1 157.2 —
Source: Global Financial Stability Report, September 2005 p. 67.
2 Antoniewicz (2006, p. 7).
3 Kapstein (2006, p. 17).
4 Insurance Information Institute (2005).
5 Financial integration monitor (2005).
6 Financial integration monitor (2004, p. 19).
7 Luna Martinez and Rose (2003, p. 10).
Jan Monkiewicz
Integrated, Consolidated or Specialized Financial Markets
153
institutions are offering bundled and integrated financial products, frequently via
integrated distribution channels.
Current regulatory trends
Financial services and financial markets are traditionally subject to public regulation.
Frequently, they are also subject to private regulation –volunta ry regulation which, in
some cases, can substitute for public intervention. This regulation has its long history
going back to the 19th century. Insurance regulation, for example, was first introduced
in the United States –in New York and Massachusetts –already in the 1860s. It was
followed by The U.K. Life Assurance Act of 1870. The American regulation was very
tight, demanding the close scrutiny of insurance contracts and prior approval of
premium rates. The British one, on the contrary, was restricted to life insurance only
and was based on the principle of ‘‘freedom with publicity’’.
The two regulations thus represented two extreme models of public intervention into
the business activities of the financial institutions, which has continued since then
throughout the centuries. They also illustrate the major dilemma public authorities are
facing until today, as to the role of regulation and the market forces or ‘‘freedom’’,
respectively.
In the last 15 years, some fundamental changes in financial regulation have taken
place. Most important probably has been the concentration of the financial sector
regulatory activities in one single place. This was in most instances the ministry of
finance that has taken over the duties from various other administrative bodies.
The next important development was a shift towards separation of regulatory and
supervisory authorities: the first one being basically responsible for introducing rules
and principles, and the second one for putting them into practice.
A characteristic feature of regulatory developments during the last 15–20 years is the
enhanced coverage of public regulation and a tendency towards the limitation of the
role of self-regulatory institutions. The best illustration is probably the history of
Lloyds, which –afte r centuries of self-regulatory independence –has finally recently
been subordinated to the U.K. Financial Services Authority. Taking insurance as an#p#分頁(yè)標(biāo)題#e#
example, this enhanced coverage includes issues such as reinsurance, intermediation,
outsourcing, corporate governance, suitability of persons, intra-group relationships
and the like. Additionally, this enhanced coverage is accompanied by the expansion of
the existing financial safety nets, inter alia, via the development of some guarantee
systems used against financial institution failures.
Finally, one should draw attention to the accelerated convergence of regulatory and
supervisory standards both cross-sectorally and across the countries, and the special
role played in this regard by the global supervisory organizations: IAIS, Basel
Committee and IOSCO.
Current supervisory trends
Financial supervision is a twin brother of regulation; hence, it basically follows the
fortunes of the latter. From the supervisory point of view, the most critical
The Geneva Papers on Risk and Insurance — Issues and Practice
154
development in recent years was its separation from the regulatory activities. It
allowed not only for its necessary specialization and adequate resourcing –diff icult to
imagine in the existing administrative framework –but, above all, it also provided for
the political and decision-making independence by cutting it from the unduly
interference of the government machinery. Today, this supervisory independence has
become a mandatory and self-evident element of modern supervisory systems, and is
one of their classical attributes, along with such attributes as their accountability,
integrity and transparency.
Supervision has been for a long time principally concerned with compliance
tracking. Financial institutions were supposed to behave according to the regulatory
requirements, and the role of supervisory authorities was to simply check their
compliance. In the 1990s, however, financial supervision became more and more
concerned with risk detection, management and control. Dynamic risk-oriented
supervision is thus replacing currently the old-fashioned and static complianceoriented
one. Logically, this leads to a shift from a retroactive to a proactive
supervisory approach, and a necessary change of supervisory tool-kit in use.
With the growing globalization and integration of the local financial markets these
changes are, additionally, supplemented by the convergence of the supervisory models,
standards as well as policies, both across sectors as well as across countries. Thus, for
example, Basel II sets the scene for Solvency II, and the American risk-based
supervision and EU Solvency II set precedence for a new IAIS solvency concept, etc.
Traditionally, supervision was organized around individual financial sectors:
banking, insurance and securities. In the late 1990s, however, more and more
jurisdictions started to consolidate their supervisory structures. By mid-2006, out of 99#p#分頁(yè)標(biāo)題#e#
countries supervising three sectors (banking, insurance and securities), 31 of them had
fully integrated supervisory agencies, whereas 44 of them continued to have multiple
or fragmented supervisors. Eleven countries decided to pull together their banking and
insurance supervisors, eight of them consolidated securities and insurance and the
remaining five consolidated banks and securities, the latter appearing to be the leastpreferred
option.8
Particular acceleration of the integration projects has taken place during the last five
years (Table 2).
It clearly seems to be a currently winning option in all major world financial
markets –Jap an, Australia, Canada and particulary Europe –with the notable
exception of the United States, which continue with their highly fragmented and
sectorally focused supervisory system.
What is an integrated supervisor? The concept of an integration ladder
As always a new phenomenon leads to some confusion among its analysts as to its real
meaning. The same applies to the notion of an integrated supervisor. An open
question until today remains its practical understanding. Interestingly enough,
8 World Bank (2006).
Jan Monkiewicz
Integrated, Consolidated or Specialized Financial Markets
155
however, in the existing literature this issue is practically not covered and it seems to be
a unanimously accepted view that ‘‘integrated’’ means cross-sectoral, that is, covering
various financial sectors and various financial institutions. If one, however,
investigates the matter more closely, this view could easily be challenged. It could
be claimed that at least two different dimensions of supervisory integration might be
identified: its breadth and its depth.
Breadth of the supervision is defined by its sectoral and/or functional coverage.
From this perspective, one could note on the one hand fragmented or mulitipillar
supervision, covering individual or partially bundled financial sectors, conventionally
split into banking, insurance and securities. On the other hand, there is a cross-sectoral
or integrated financial market supervision, represented by a unique supervisory
institution.
There is, however, another, equally important perspective, which is largely absent in
the analysis up to now –that is a functional one. The functional perspective starts
from the observation that there are a variety of supervisory functions and its
constituent elements are licensing, on-going supervision, enforcement, prudential,
market conduct supervision, etc. (see Figure 1). They all remain inherent parts of the
supervisory system; however, they could be placed under the administration of
separate bodies. One frequently overlooks in the current debate that integration of
supervisory functions in recent years has covered also integration under one roof of#p#分頁(yè)標(biāo)題#e#
licensing and on-going supervision, as well as prudential and market conduct activities
for the entirety of the financial market. These other integration dimensions could have,
as a matter of fact, much more profound effects for the supervisory efficiency and
effectiveness than those limited to the only organizational ones.
As to the depth of the supervisory integration one could identify at least three levels
of the integration projects: institutional, technical and organic. Institutional
integration is basically confined to the organizational unification of the supervisory
authority, with some minor internal shake ups, which might include eliminating some
Table 2 Establishment of fully integrated agencies
Year Country Year Country
1978 Singapore 2002 Austria
1981 Maldives 2002 Estonia
1983 Norway 2002 Germany
1987 Canada 2002 Hungary
1988 Denmark 2002 Malta
1991 Sweden 2003 Ireland
1997 Korea 2004 Belgium
1998 Australia 2004 Kazahstan
1998 Japan 2004 Netherland
1998 United Kingdom 2006 Czech Republic
1999 Iceland 2006 Poland
2001 Latvia 2006 Slovak Republic
Source: Demaestri E., Sourrouille D., Integrated Financial Supervision: Experiences in selected countries,
Inter-American Development Bank, Washington D. C. 2003 p. 2 and own research.
The Geneva Papers on Risk and Insurance — Issues and Practice
156
interfering organizational units or adding some others to cover new responsibilities. It
is de facto more a consolidation than real integration.
Technical integration on the other hand assumes unification or at least convergence
of the supervisory tool-kits used, such as models, processes and policies. It is more
painful and complex in comparison to the formal institutional integration and requires
much more effort to be completed. Therefore, it is also more common in the current
integration drive to avoid any substantial technical integration, at least in the first
phase.
The same is even more true with regard to organic integration, which includes
unification of the regulatory rules, principles and standards, thus providing for the
single legal framework. For these reasons, this level of supervisory integration remains
quite rare and the most seldom-used option of all registered integration projects.
What are the drivers and constraints of the supervisory integration?
The spread of ‘‘integrated’’ supervisory systems, basically meaning the proliferation of
institutional cross-sectoral consolidation, reflects in principle the search by individual
jurisdictions for more efficiency and effectiveness in the supervisory activities in a
period of increasing complexity of the financial system. This search, however, has had
–as a rule –different individual triggers in different countries. In some of them –and#p#分頁(yè)標(biāo)題#e#
this seems to be the most natural –it was an unsatisfactory performance of the existing
mulitipillar, fragmented supervision. It is always best tested during a financial crisis,
which usually uncovers all the hidden weaknesses of the supervisory system in place. It
was precisely for that reason that Korea, Japan and Australia shifted from mulitipillar
to consolidated supervision, after experiencing financial failures of some of their big
Licensing On-site inspections Off site supervision Enforcement
Shareholders Supervisory boards Management boards Organisation Procedures
corporate governance
capital adequacy
Assets Liabilities
Assets
risks
Policyholders Intermediaries Outsourced institutions Capital borrowers
Liabilities
risks
Asset-liability risk
management
Market
Supervisory authority
Supervised entity
Figure 1. Principal elements of supervisory process.
Jan Monkiewicz
Integrated, Consolidated or Specialized Financial Markets
157
financial institutions. Incidentally, crisis experience has always been until today
accompanied also by frequently sweeping regulatory changes. The Sarbanes–Oxley
Act of 2002 is probably the best living example of what the regulatory power of big
financial failures today is.
Sometimes supervisory institutional integration was a direct answer to the excessive
level of the supervisory fragmentation. This was apparently an important argument
for the reform of the financial supervision in the United Kingdom, where there were
nine specialized financial supervisory institutions in 1998 when the decision on
merging them into the Financial Services Authority was undertaken.9
In some instances, integration of supervisory institutions responds to national
market developments, in particular to its conglomeration. As indicated before, current
market structures are frequently characterized by the emergence of complex financial
conglomerates. If this happens, it naturally calls for the supervisory structures able to
match their complexity. An excellent example is provided by the Dutch experience
where recent institutional consolidation of the supervisory structures came into effect
mainly due to the spread of national financial conglomerates.10 According to available
statistics, they represented in 2004 about 60 per cent of the national banking and
insurance assets. There were therefore strong market arguments favoring supervisory
integration.
Integration of the supervisory institutions may also result from the increased
pressure on the available supervisory resources. By its nature, it is more common in
small than large jurisdictions. This explains why small countries are at the forefront of
the supervisory integration. They simply may have no choice but to pool their scarce#p#分頁(yè)標(biāo)題#e#
supervisory resources together to match market demands.
Finally, supervisory integration may have its roots in the regulatory integration,
which creates strong demand for the single supervisory partner that could balance its
powers and provide more equilibrium to the financial system.
Last but not least supervisory integration may also reflect the spread of the
demonstration effect across the countries that are willing to imitate solutions adopted
in their benchmarking jurisdictions.
On the other hand, there are also strong constraining factors of the integration
projects. They include first of all traditional separation of the financial market
regulatory base and hence separation of the supervisory competences. They include
further different supervisory goals of the main sectoral supervisors. The Basel
Committee for example defines the major goal of banking supervision as: ‘‘to ensure
that banks operate in safe and sound manner and that they hold capital and reserves
sufficient to support the risks that arise in their business’’. IAIS, on the other hand,
declares that the role of insurance supervision is ‘‘to maintain efficient, fair, safe and
stable insurance market for the benefit and protection of policyholders’’. IOSCO
requests from supervision ‘‘investors’ protection, ensuring fair, efficient and
transparent markets and reduction of systemic risk’’. Thus, banking supervision is
9 Briault (1999, p. 6).
10 Witteeven (2006).
The Geneva Papers on Risk and Insurance — Issues and Practice
158
principally concerned with systemic stability, whereas insurance supervision is more
about consumer protection and securities about investors’ protection.
Another constraint that arises from these differences is the business and risk profiles
of the supervised institutions. Banks suffer primarily from the insufficient quality of
their assets, whereas insurers clearly depend more on the quality of their liabilities.
Investment companies on the other hand are mainly hurt by their market misbehavior.
To bring all these different considerations under one roof is not an easy task for the
integrated supervisor.
Last but not least some role in constraining supervisory integration is played by the
existing sectoral structure of international standard setters that –in spite of a growing
cooperation –continue to produce standalone standards and rules addressed to
individual financial sectors.
What are the potential rewards of the integrated financial supervision?
An integrated supervision has a number of potential advantages that, however,
contrary to what some people could think, are not emerging automatically and
unconditionally.
It undoubtedly allows for better understanding of cross-sectoral risks and issues and#p#分頁(yè)標(biāo)題#e#
improved oversight of complex financial institutions. The more ‘‘interwoven’’ a
financial system in a given jurisdiction and the greater the role of financial groups and
conglomerates in there, the more arguments exist for a unified financial supervision.
This is particularly the case when these groups themselves apply a centralized
approach to risk management and risk taking.11 Having all supervisory powers under
one roof, an integrated supervisor is able to better catch the problems of such complex
organizations. It can also better match their institutional powers and thus better
defend its own independence.
An integrated supervisor will also more likely achieve the situation in which there
are similar rules for similar activities across all segments of the financial system and
therefore the possibilities of regulatory arbitrage are eliminated or at least limited. As a
result, a more level playing field across various financial sectors and various financial
institutions can be installed. Integration of supervision should additionally eliminate
the danger of accountability diffusion particulary in cases of regulatory failures. It can
also provide for better communication, coordination and cooperation among different
supervisory departments and officers, thus increasing the operational efficiency of the
organization.
An important argument in favor of the integrated supervision is related to the
potential economies of scale. This could be achieved through centralized regulatory
functions leading to the development of joint support functions such as administration,
information technology, accounting, legal services, etc. This could be additionally
reinforced with respect to the better use of qualified people and other scarce resources
as well as the optimal staff deployment within the integrated organization. Potential
11 Llewellyn (2006, p. 18).
Jan Monkiewicz
Integrated, Consolidated or Specialized Financial Markets
159
economies of scale may be particulary relevant for small countries where expertise in
supervision is in short supply, less for big economies. In both cases, however, a bigger
and stronger agency may seem to offer better career prospects and may thus be more
able to attract better people.
Finally, integrated supervision also offers potential economies of scope (synergies)
via diffusion of best supervisory tools and practices from individual supervisory
institutions.
What are the potential hazards of the integrated supervision?
It is interesting to note that so far proactive decisions on restructuring of financial
supervision –at least in Europe –have been in most cases delivered as political
initiatives and, as such, never preceded by wide expert discussions. Only in cases of
retroactive actions –followin g financial crisis –have public debates come usually to#p#分頁(yè)標(biāo)題#e#
play an important role.
There are in principle four groups of concerns related to the transition from
fragmented to integrated supervision that in the end may jeopardize the whole idea
and question its rationality. Generally speaking, it will happen when the costs of
changing the existing structures outweigh the benefits of an integrated supervisor. It
should be stressed at the same time that other things being equal, however, the success
of an integrated supervision is highly dependent upon the strengths of its predecessors.
The old principle ‘‘rubbish in –rub bish out’’ maintains its full validity also in
consolidation attempts. We should also underline that the integration process should
be carried out only in a time of stability of the financial system.12
The first concern about the integrated supervision is about the temporal
deterioration of market supervision at the time of transition from multiple supervisory
architectures to a single one. It is quite natural that merging existing institutions leads
to the major reorganization of its functions, roles and policies and creates a feeling of
increased uncertainty among staff members and loss of momentum.13 Some officers
with vital skills may leave the services and seek other career opportunities, thus
increasing the likelihood of the organizational disruption.
The creation of a single supervisor may also involve a loss of valuable information
due to the application of an integrated approach or simply due to the loss of critical
staff. As indicated by some researchers, this period of lowered organizational
efficiency may last up to two years, depending on the conditions in individual
countries.14
It is an important variable therefore in the decision on timing of the restructuring
operation. It should avoid to the maximum extent possible a situation in which
existing sectoral supervisors are already under fire from current challenges that need to
be promptly and efficiently resolved or in market turbulences.
12 Siregar and Williams (2004, p. 7).
13 Fiechter (2006).
14 Luna Martinez and Rose (2003).
The Geneva Papers on Risk and Insurance — Issues and Practice
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The second group of concerns is even more serious, as there is a possibility that in the
long-term integrated supervision will be less effective and efficient than its sectoral
predecessors. This situation may result both from the improper or premature merging
as well as from the inadequate staffing and resourcing of the new institution or else
from its poor management. As in any consolidation project there is a potential danger
of lowering the market value of the new consolidated institution instead of increasing it.
The third group of concerns relates to the risk of bureaucratic inefficiency of a single
institution, unable to differentiate its tools and approaches and to rapidly respond to#p#分頁(yè)標(biāo)題#e#
market failures. There is a danger that within such a big cross-sectoral institution,
necessary differences between different financial institutions are not taken care of and
a tendency towards a unified approach will dominate. Critically important in
particular is supervisory responsiveness and innovativeness to keep pace with financial
market trends and developments.
Finally, the fourth concern is about the risk of eliminating the existing checks and
balances in the supervisory structure system and excessive concentration of power in
one single authority. It is therefore of utmost importance to ensure an adequate system
of political control and rules of political accountability of the newly created institution.
Some conclusions
As we have seen from the foregoing analysis, there are many alternative supervisory
models that could be chosen by national jurisdictions. There are also a variety of
‘‘fragmented’’ and ‘‘integrated’’ solutions. Institutional consolidation is only one
possible measure to improve market supervision. Although it may not be necessarily
the most critical one, at the same time its importance should not be overlooked.
Different structures may have different implications for the costs of supervision. They
may also impact on the overall effectiveness of supervision via its differentiated
mandate (focused or diversified) and coverage.
It is important to stress that chosen models of supervisory architecture should
reflect local circumstances and should always be made to measure. The selection
process is particularly burdensome if the country is not starting its supervision from
the scratch but has some supervisory institutions already in place. As a matter of fact,
this is exactly the dilemma that policymakers are facing in a real world. A question
then to be addressed would be, what is a more optimal solution: fine tuning or
fundamental restructuring? A fundamental issue in particular to be considered is the
role of the central bank in the supervisory context, especially in bank-based financial
systems.
Finally, it should be underlined that when undertaken, integration projects should
properly take account of timing, duration, pace of integration process and governance
aspects of the new institution. Otherwise transaction costs may eat all potential
benefits of the new institutional layout.
References
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Commission, Washington, DC.
Jan Monkiewicz
Integrated, Consolidated or Specialized Financial Markets
161
Briault, C. (1999) The rationale for a single national financial services regulatory, Occasional Paper Series 2,
FSA (May).
Fiechter, J.L. (2006) Aligning supervisory structures with country needs, Remarks at the World Bank/IMF#p#分頁(yè)標(biāo)題#e#
Global Conference, Washington, D.C. (June 5).
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Insurance Information Institute (2005) International Insurance Fact Book, New York: III.
Kapstein, E.B. (2006) Architects of stability? International cooperation among financial supervisors, BIS
Working Papers, No. 199 (February), Basel.
Llewellyn, D.T. (2006) Institutional Structure of Financial Regulation and Supervision: The Basic Issues,
Paper presented at a World Bank Seminar Aligning Supervisory Structures with Country Needs,
Washington D.C. (6–7 June).
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World Bank Policy Research Working Paper 3096 (July).
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SEC (2005) Financial integration monitor 2005, Commission Staff Working Document, SEC (2005) 559.
Siregar, R.Y. and Williams, J.E. (2004) Designing an integrated financial supervision agency: selected lessons
and challenges for Indonesia, Discussion Paper No. 405, CEIS, University of Adelaide, Australia
(October).
Witteeven, D. (2006) View of DNB on Supervision 2006–2010, Warsaw (10 March).
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About the Author
Jan Monkiewicz is Professor of Financial Management, Department of Production
Engineering, Warsaw Technical University, Warsaw, Poland. From 2002–2006, he has
been Chairman of The Insurance and Pension Funds Supervisory Commission in
Poland and was a member of the Executive Committee of IAIS during that same
period.
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