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The collection of supervisory data and its dissemination is not part of any accepted international framework. The IMF is investigating the use of macro-prudential indicators as part of the SDDS framework. As of now, the banking sector data required to be compiled under the SDDS is that on the analytical accounts that should include, at a minimum, money aggregates and domestic credit broken down by sub-sector.

119 Sound Practices for Banks’ Interactions with Highly Leveraged Institutions, BCBS, January 1999.

Supervisors have traditionally been reluctant to disclose micro-data on individual institutions for reasons of confidentiality— either due to legal constraints or because of the anticipated effect on the institution. This hesitation is steeped in traditional supervisory approach of addressing bank problems with the minimum of publicity for fear of the effect of information on institutional soundness may have on the system as a whole. On the other hand, the release of regular assessments of the banks and the banking sector by the supervisors would meet part of the data requirements of the other participants.

As discussed earlier, the type of data required by the users to assess bank soundness are those which are already disclosed in published accounts by banks in several countries.

As a first step, we recommend countries agree on a minimum disclosure requirement for banks, which mirror the requirements raised by users, and which supervisors collect and publish in aggregate. These data series would cover capital adequacy, asset quality, earnings and liquidity indicators.

Frequency of release of these data is important. Where published, such data are normally available annually, either because of the publication cycle of the supervisors’

annual report or due to the fact that banks may be publishing their accounts annually.

However, most supervisors tend to get such data on a more frequent basis. Banks that are listed on the exchanges, too, are normally required to publish at least quarterly results, though once again country practices may vary. The supervisors could put together published data with similar data from other banks obtained through internal reporting and make them public on at least a quarterly basis. In summary, a quarterly release of indicators by the supervisors would meet the demand of most users.

Data based on the published financial statements of banks is often put together by private agencies such as credit rating agencies, investment banks, and financial databases largely for their own internal use or for paid subscribers. An argument could be that if the private sector is in a position to do this, then there is no reason for the public sector through the supervisory agency, to duplicate this effort. However, if the collection and dissemination of these data is seen as a public good which will in the long run enhance the credibility of the banking sector and hence help reduce overall credit costs of the economy, then there is certainly merit in this role being taken up by

the supervisors. Being close to the institutions data would add credibility to the supervisory authorities data. Some countries may have difficulty in implementing this proposal straight away because of the different accounting periods followed by the banks, the different frequency of reporting and because of legal requirements inhibiting release of individual institution data or even the lack of authority to bring about changes in reporting and disclosure requirements. However, once these issues are on the international agenda then the supervisors would be assisted in their efforts towards this end.

A similar argument holds true for disclosure and transparency efforts. It has been argued that countries with a weak financial sector may suffer from the onset of disclosure, but this would be a short term loss which would be outweighed by the long term gains of enhanced credibility arising out of availability of realisable data. The release and re-release of non-performing loans data by Japan during 1998 was quoted at the Workshop as a recent example of how the release of data, perceived as unreliable, can have an adverse impact on credibility.

A related issue that will become of increasing concern is that of the organisational frameworks in place in different countries for the collection and dissemination of data on supervised institutions. In response to the developments in the financial markets over the past few years, an integrated approach to supervision that puts all supervisors under one agency is being adopted in many countries. This is also often accompanied by separation of the supervision function from the central bank. This development is countercyclical to the emerging need for macro-prudential surveillance that requires both macro-economic and supervisory data to be part of the common data set for monitoring stability. As the systemic monitoring function remains with the central bank but the supervisory data source moves away from it, there arises a need for the development of an institutional mechanism for the co-ordination of efforts at the national level for the monitoring and handling of financial crises. This is an issue which countries will have to deal with individually, given their institutional frameworks.

Finally, it also has to be noted that supervisors in different countries are subject to country specific constraints and practices, hence international efforts to harmonise data

collection and dissemination may not meet with the same results, even if the national supervisors are agreed on the need for disclosure and transparency.

4.6 Recommendations

We recommend that national supervisory agencies take upon themselves the responsibility for the collection, compilation and dissemination of data on banks to meet the needs of users. These data would be at least at the peer group and aggregate level; both on solo and consolidated basis; and include key indicators of capital, asset quality, earnings and liquidity such as capital adequacy ratios, non-performing loans as a percentage of total assets, return on assets and equity and a breakdown of assets and liabilities by maturity. Data should be published on a quarterly frequency.

The above list is only a suggested bare minimum and not a comprehensive list of indicators. A common disclosure template in the form of a minimum requirement could be agreed upon through the aegis of the BCBS and this could be so designed to meet the needs of macro-prudential surveillance. This could require implementation of greater disclosure requirements than those currently applicable in many countries, and possibly even legislative changes to augment the authority of the supervisors to ask for and to publish these data. We recommend that countries take up this task with the priority it deserves.

We are also in agreement with the recommendations made by the BCBS in their reports on Core Principles of Effective Banking Supervision, Enhancing Bank Transparency and Sound Practices for Loan Accounting, Credit Risk Disclosure and feel that all countries should aim to gradually move towards adopting them. The report also recommends that all countries publish the assessment made by them of the Core Principles of Effective Banking Supervision so as to provide users with information about the regulatory and supervisory regime in place and the steps being taken to bridge the gaps.