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Regulation and Supervision of Financial Cooperatives by Rodrigo Coelho, Jose Angelo Mazzillo, Jean-Philippe Svoronos and Taohua Yu

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Regulation and Supervision of Financial Cooperatives by Rodrigo Coelho, Jose Angelo Mazzillo, Jean-Philippe Svoronos and Taohua Yu Financial Stability Institute FSI Insights on policy implementation No 15 Regulation and supervision of financial cooperatives by Rodrigo Coelho, Jose Angelo Mazzillo, Jean-Philippe Svoronos and Taohua Yu January 2019 JEL classification: G21, G28, G32, G38, P13 Keywords: cooperative, network, regulation, supervision, governance, capital, proportionality FSI Insights are written by members of the Financial Stability Institute (FSI) of the Bank for International Settlements (BIS), often in collaboration with staff from supervisory agencies and central banks. The papers aim to contribute to international discussions on a range of contemporary regulatory and supervisory policy issues and implementation challenges faced by financial sector authorities. The views expressed in them are solely those of the authors and do not necessarily reflect those of the BIS or the Basel-based committees. Authorised by the Chairman of the FSI, Fernando Restoy. This publication is available on the BIS website (www.bis.org). To contact the BIS Media and Public Relations team, please email [email protected]. You can sign up for email alerts at www.bis.org/emailalerts.htm. © Bank for International Settlements 2019. All rights reserved. Brief excerpts may be reproduced or translated provided the source is stated. ISSN 2522-2481 (print) ISBN 978-92-9259-200-4 (print) ISSN 2522-249X (online) ISBN 978-92-9259-201-1 (online) Contents Executive summary ........................................................................................................................................................................... 1 Section 1 – Introduction ................................................................................................................................................................. 2 Section 2 – Overview of the FC sector ...................................................................................................................................... 5 Market relevance ...................................................................................................................................................................... 5 Business models ....................................................................................................................................................................... 7 Main challenges ........................................................................................................................................................................ 9 Section 3 – Access to capital and funding............................................................................................................................. 11 Main characteristics of member shares ......................................................................................................................... 11 Accounting treatment .......................................................................................................................................................... 12 Treatment as regulatory capital ....................................................................................................................................... 12 FCs’ capital and customer protection issues ............................................................................................................... 15 Section 4 – Governance ................................................................................................................................................................ 17 Section 5 – Regulation, supervision and crisis management......................................................................................... 20 Regulation ................................................................................................................................................................................. 20 Supervision ............................................................................................................................................................................... 22 Crisis management ................................................................................................................................................................ 24 Section 6 – Concluding remarks ................................................................................................................................................ 26 References .......................................................................................................................................................................................... 28 Annex 1 – Financial cooperatives in Australia ...................................................................................................................... 30 Annex 2 – Financial cooperatives in Brazil............................................................................................................................. 34 Annex 3 – Financial cooperatives in China ............................................................................................................................ 39 Annex 4 – Financial cooperatives in France .......................................................................................................................... 45 Annex 5 – Financial cooperatives in Germany ..................................................................................................................... 53 Annex 6 – Financial cooperatives in Ireland ......................................................................................................................... 59 Annex 7 – Financial cooperatives in Kenya ........................................................................................................................... 65 Annex 8 – Financial cooperatives in South Africa ............................................................................................................... 69 Annex 9 – Financial cooperatives in the United States .................................................................................................... 73 Regulation and supervision of financial cooperatives iii Regulation and supervision of financial cooperatives1 Executive summary In many jurisdictions, financial cooperatives (FCs) are the most numerous financial institutions although their share in total banking assets is typically limited. As such, most FCs are small, with a simple business model based on deposit-taking and lending. However, in some European jurisdictions, FCs make up a larger share of the financial system, with some institutions considered to be systemically important. How FCs do business and organise themselves differs significantly across jurisdictions. At one end of the spectrum, FCs are small, with a simple business model, and serve only their members. At the other end, FCs pool resources and form federations with internal solidarity schemes or even consolidated groups. These centrally coordinated networks may resemble those of large banking groups, conducting business with non-members and providing a wide variety of services. FCs and commercial banks differ mainly in terms of their ownership structure and aims. In a traditional FC, each member has one vote, regardless of the number of shares held. In addition to being owners, members are also depositors and borrowers, with some participating in the FC’s governance bodies Furthermore, an FC’s main purpose is to serve its members by providing affordable financial services. Although FCs need to be profitable to sustain their activities, maximising profitability to distribute revenues to owners is not their sole or even primary aim. FCs have certain competitive advantages. Funding is frequently cheaper and generally more stable than that of most commercial banks, as it is sourced mainly from members’ deposits and member shares. Also, thanks to their local focus, FCs traditionally have – or are perceived to have – closer client relationships and may be better able to customise services. Finally, FCs may be better placed to cooperate with each other to achieve scale economies than are rival commercial banks. These characteristics also create challenges. FCs’ local focus of operations, common bond requirements and typically small size mean that they are more exposed to concentration risks in both their assets and liabilities. In addition, their capacity to increase resilience or expand their business is limited since capital growth relies mainly on accumulating retained earnings and expanding membership. Finally, the governance structure, in which members of the board of directors and of the senior management are also owners and customers, can give rise to a wider range of conflicts of interest than at commercial banks Moreover, the ownership structure and legal nature of those entities make some of the standard bank resolution approaches unsuitable for failing FCs. Changes in technological developments may be eroding some of FCs’ competitive advantages. In particular, the use of technology such as online and mobile banking allows competitors to offer a wider variety of financial services in geographical areas where they have no physical branches, and at a lower cost. 1 Rodrigo Coelho ([email protected]) and Jean-Philippe Svoronos ([email protected]), Bank for International Settlements, Jose Angelo Mazzillo ([email protected]), Central Bank of Brazil, and Yu Taohua ([email protected]), People’s Bank of China. The authors are grateful
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