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BANKING SUPERVISION AND EXAMINATION 420 Rural Banks

IN THE PHILIPPINES
25 Cooperative Banks
INTRODUCTION
7 Quasi-banking entities
Several observers have pointed out that the 1997 Asian
financial crisis has revealed weaknesses in banking 63 Non-stock savings and loan associations
supervision in Asian jurisdictions, including the 13 Foreign Bank Representative Offices
Philippines.
authorized institutions in the Philippines
As a response, banking supervisors across the region
have set out to improve the practice of banking Assets of Philippine banks posted a double-digit growth
supervision in their respective jurisdictions, either in end May as the COVID-19 pandemic continued to
through their individual efforts or through regional threaten economies and financial systems around the
efforts via the different regional groups of banking world.
supervisors.
Data from the Bangko Sentral ng Pilipinas (BSP)
THE BASEL COMMITTEE showed total resources of the Philippine banking system
reached P19.14 trillion in end May, or P1.69 trillion
The Basel Committee on Banking Supervision (BCBS) higher than the P17.45 trillion booked in end May last
is the primary global standard setter for the prudential year.
regulation of banks and provides a forum for regular
cooperation on banking supervisory matters. Its 45 The total assets of big banks or universal and
members comprise central banks and bank supervisors commercial banks grew by 11.3 percent to P17.68
from 28 jurisdictions. trillion from P15.89 trillion, while that of small banks or
rural and cooperative banks inched up by 5.8 percent to
THE BASEL COMMITTEE MANDATE P291 billion from P275 billion.
The BCBS is the primary global standard setter for the On the other hand, the resources of mid-sized banks or
prudential regulation of banks and provides a forum for thrift banks declined by 9.3 percent to P1.16 trillion
cooperation on banking supervisory matters. Its mandate from P1.28 trillion.
is to strengthen the regulation, supervision and practices
of banks worldwide with the purpose of enhancing AGENCIES THAT SUPERVISE THE DIFFERENT
financial stability. INSTITUTIONS IN THE PHILIPPINE
FINANCIAL SYSTEM
OVERVIEW OF THE PHILIPPINE FINANCIAL
SYSTEM Bangko Sentral ng Pilipinas

The Philippine financial system is dominated by banks. Securities and Exchange Commission
However, other financial institutions are also active.
These include non-bank financial institutions, pre- need Insurance Commission
companies, and insurance companies.
FINANCIAL SECTOR FORUM
In the recent list provided by the Bangko Sentral ng
Sector Forum (FSF) was established through a master
Pilipinas (August 2020) there are:
memorandum of agreement (MOA) signed on July 5,
21 Universal banks (3 Government-owned, 6 foreign 2004, by the heads of four financial regulators: Governor
banks) Rafael B. Buenaventura of the Bangko Sentral ng
Pilipinas (BSP), Chairman Lilia T. Bautista of the
25 Commercial Banks (5 Domestic, 2 Foreign bank Securities and Exchange Commission (SEC),
subsidiaries, 18 Foreign bank branches) Commissioner Eduardo T. Malinis of the Insurance
Commission (IC); and President Ricardo M. Tan of the
47 Thrift Banks Philippine Deposit Insurance Corp. 
The chairman of the FSF is the governor of the BSP. mixed conglomerates controlled by a few affluent
Unlike in other jurisdictions where a single entity families. 
regulates the entire financial system, such as the
Monetary Authority of Singapore (MAS), regulation in A more risk-based approached was necessary to keep up
the Philippines and regulatory legislation are with the growing complexity of the banking business. At
fragmented. the same time, increasing and simultaneous demands on
available but limited supervisory resources prompted the
The FSF is a voluntary endeavor of the four agencies “to search for an alternative approach that would permit a
provide an institutionalized framework for coordinating more efficient allocation based on identified priority
the supervision and regulation of the financial system needs.
while preserving each agency’s mandate” and to provide
a “venue for the agencies to update each other on the The implementation of consolidated supervision was
latest developments in their respective industries and any driven by the emergence of complex banking groups and
concerns that may have systemic repercussions”. mixed conglomerates controlled by a few affluent
families. 
The FSF is essentially a cooperative effort without any
specific  legal authority, and thus it is not intended to A more risk-based approached was necessary to keep up
function as an integrated supervisory body. The FSF with the growing complexity of the banking business. At
primarily serves as a forum for the separate financial the same time, increasing and simultaneous demands on
regulators to coordinate and discuss matters of common available but limited supervisory resources prompted the
concern.  It meets on a regular bi-monthly schedule.  search for an alternative approach that would permit a
more efficient allocation based on identified priority
FINANCIAL SECTOR FORUM FOCUS needs.

1. Harmonization and coordination of supervisory The Bangko Sentral initially adopted a gradualist
and regulatory methods and policies approach in effecting the shift to consolidated
2. Reporting and information exchange and supervision and the risk based approach, cognizant of
dissemination the importance of managing change and ensuring
3. Undertake initiatives on consumer protection sufficient buy-in of major stakeholders involved.
and education
The Bangko Sentral first started to move in the direction
BANKING SUPERVISION IN THE PHILIPPINES of consolidated supervision in 1998 by adopting a
common cut-off date for examination of banks and their
LEGAL AND SUPERVISORY FRAMEWORK subsidiaries/affiliates
Republic Act No. 7653 as amended, otherwise known as The shift to a risk based supervision approach from a
the New Central Bank Act of 1993 authorized the compliance based one started in 1997 when the BSP
Bangko Sentral ng Pilipinas to exercise supervision over gradually redirected its supervisory thrust to focus more
the operations of banking institutions and quasi-banks on the measurement and management of banks’ risk
including their subsidiaries and affiliates engaged in exposures, rather on financial audit of sample
allied activities.  transactions occurring within a specified period
generally reckoned from the immediately preceding
LEGAL AND SUPERVISORY FRAMEWORK
examination the identification of breaches of provisions
This provides the legal basis for the implementation of of law or banking regulations. 
consolidated supervision. The adoption of the risk based
approach in the conduct of banking supervision, on the
other hand, is supported by the General Banking Law of
2000 (R.A. No. 8791).

The implementation of consolidated supervision was


driven by the emergence of complex banking groups and
The BSP’s new supervisory approach now favors an On the other hand, a Report of Examination that is
assessment of the quality of risk management practices completed and shared shortly after an on site
and generally allows banks to take risks so long as the examination, one that is well written and clearly presents
banks demonstrate the ability to manage, absorb and major supervisory conclusions, contributes significantly
price for those risks, in contrast to the traditional to the preparation of an updated assessment of bank risk
approach that cautioned banks against taking on risks profile.
that seem too high.
The interdependency and close coordination of work
In carefully loosening the regulatory grip on banks’ risk units discharging those separate tasks should serve to
taking activities, the BSP must necessarily underscore foster teamwork and build mutual trust.
the responsibility of the bank’s board of directors and
senior management to ensure the soundness and stability The on-site examination assumes a different focus, from
of their respective banks. BSP’s role is primarily to a compliance-based exercise to one that puts emphasis
evaluate the quality of oversight, the adequacy of on the soundness of governance and risk management
policies and procedures, the robustness of the risk and the effectiveness of the audit function.
management system and the effectiveness of the internal Its conduct entails reliance on  enhanced analytic skills
audit function. and judgment calls of examiners.

For off-site monitoring, the challenge is to be able to


DATA COLLECTION AND STORAGE identify sources of potential threats to financial and
reputational soundness. Critical thinking abilities and
New Financial Reporting Package (FRP) was crafted sound judgment skills are very crucial.
that is consistent with the Philippine Accounting
Standards (PAS) and Philippine Financial Reporting Bank supervision staff assigned to do this task need to
Standards (PFRS). alert higher management of what he perceives as
potential threats, based on all available information. 
In 2005, the PAS/PFRS was amended to fully align with
the IAS/IFRS for enhanced financial transparency. As the central point of contact, he is also expected to
thoroughly understand and be updated on the business of
The FRP, submitted electronically, is meant to facilitate a bank. These assessments are synthesized in an
gathering more relevant data leading to improved and Institutional Overview (IO) document that is updated on
timely analysis that will support the supervisory process. a quarterly basis.
A Data Warehouse System has also provided ready
access to all supervisory data by authorized personnel
and brought ease in doing vertical and horizontal SKILL SETS AND TRAINING
analysis of data, peer group comparisons and trending. 
Accounting and auditing skills. These are being
developed through in-house structured training programs
OVERHAUL OF THE EXAMINATION/ OFFSITE and specialty courses designed with the assistance of
MONITORING PROCESS outside experts provided through technical assistance
from the IMF (funded by the Japanese Government),
Risk based supervision features a balanced First Initiative (administered by the World Bank) and
complementation of on-site examination and off-site USAID. All supervisory personnel are required to go
monitoring. An effective off site monitoring mechanism through these continuing training programs. 
that yields an updated assessment of the changing risk
profile of a banking unit or group serves as a valuable  A major objective of the technical assistance is also the
input to the scoping and planning of an on-site development of in-house trainors from the supervisory
examination.  staff to facilitate mass training at affordable cost.
In addition to classroom-based training, a Resident For the broader population of normally operating
Advisor and short-term consultants funded from IMF financial institutions, the set-up allows the highly
technical assistance also delivers practical training. flexible, dynamic and scalable application of risk-based
supervision methods through the coordinated efforts of
The BSP has also strongly encouraged and subsidized off-site relationship managers for continuity and on-site
the acquisition by staff of international certification for examination terms that bring together various specialist
relevant skills such as Chartered Financial Analyst skills depending on the risk profile of target financial
(CFA), Certified Internal Auditor (CIA), Professional institutions. 
Risk Manager (PRM), Financial Risk Manager (FRM),
and Certified Information System Auditor (CISA) for IT The arrangement is complemented by the centralized
examiners.  delivery of critical services such as
licensing, policy development, data management,
It  has also been sending staff including lawyers to consumer affairs management, and administrative
universities for graduate and post-graduate education in services.
relevant fields supporting the expanding requirements of
banking supervision. The hiring policy for supervisory For the better management of bank examination activity,
personnel has been expanded as well to be able to take an Examiner Resource Scheduling System (ERSS) is
on new talent from disciplines other than finance and under development and will be deployed in 2008.
accounting such as statistics, economics, mathematics
and operations research. It utilizes network flow programming and other
operations research techniques to aid management
achieve optimal solution to two challenges.

ORGANIZATION OF THE BSP SUPERVISION ORGANIZATION OF THE BSP SUPERVISION


AND EXAMINATION SECTOR (SES) AND EXAMINATION SECTOR (SES)

The BSP-SES headed by a Deputy Governor is the 1. how can examiner resources be efficiently
specific component of the BSP that is responsible for allocated in ensuring the “best fit” group of
carrying out its responsibility from bank supervision. examiners is deployed to each bank according to
The SES is in the process of completing a deep and risk profile; and
sweeping reorganization to effectively implement its 2. what is the appropriate deployment schedule that
risk-based supervisory approach. balances need for timely examinations,
continuous examiner training, scheduled leaves,
natural personnel movements as well as
personnel emergencies and other contingencies.
ORGANIZATION OF THE BSP SUPERVISION
AND EXAMINATION SECTOR (SES) OTHER SUPERVISORY TOOLS
SES is divided into four major sub-sectors, to provide: 1. Bank Performance Reports (BPR) system
2. Bank Early Warning System (EWS)
1. sufficient controls and accountability over
specific activities in the supervision process; Bank Performance Reports (BPR) system
2. specialization and focus in highly technical
areas; Is very useful in monitoring the financial performance of
3. consistency in the interpretation and application supervised entities in between on-site examinations. The
of supervisory policies and rules and BPR contains in one compact report key performance
regulations; and indicators that support CAMELS soundness analysis. 
4. timeliness in the submission of reports of
examination and accomplishment of critical Bank Early Warning System (EWS)
supervision tasks. Is a statistical model that generates one-year ahead
forecasts of key bank performance variables, especially
solvency and asset quality. The output of EWS is used to
help prioritize on-site examinations and validate The examination procedures, on the other hand, have
judgmental assessments of bank condition. been improved to support the adoption of the risk-based
supervision framework. This started in 2005 when the
Manual  on Supervision and Examination of Banks (the
Manual) was revised to conform to the risk- based
COMPLIANCE WITH THE BASEL CORE
approach with the help of technical assistance from the
PRINCIPLES FOR EFFECTIVE BANKING
United States Agency for International Development
SUPERVISION
(USAID). 
The 2002 IMF assessment on the Philippines’
The development of the Manual was done
compliance with the Basel Core Principles for Effective
simultaneously with the implementation of a technical
Banking Supervision revealed that although compliance
assistance from First Initiative that aimed to develop a
overall is quite high, important gaps still existed. 
sustainable and relevant formal foundation training
These gaps included, among others, strengthening the program for BSP examiners. The focus of the training
legal protection for supervisors, formalization of program was the conduct of risk-based examination. 
information sharing and cooperation with other local and
The new framework now communicates to the
foreign supervisory agencies through MOUs or other
supervised entities in clear terms when and how the BSP
mechanisms, improving the conduct of consolidated
will deal with potential problems in bank operations in
supervision and the examination procedures, enhancing
order to prevent more serious problems from arising that
the framework for prompt corrective action and problem
would necessitate more drastic measures. For banks that
bank resolution, and the application of appropriate
are beyond corrective measures, a number of procedures
standards for banks’ risk management systems.
are in place, but application can be hampered by gaps in
There is already a formal platform for information the law.
exchange and cooperation among the local financial
The BSP has also formally implemented appropriate
supervisors through the FSF. As to information
standards for banks’ risk management systems. This
exchange arrangements with foreign supervisory
started with the guidelines on the minimum standards for
agencies, the BSP has formal agreements in place with
risk management of financial derivatives.
five (5) foreign supervisory agencies, and is negotiating
with seven (7) others. This was followed by the guidelines on the minimum
standards that banks must observe in designing and
The BSP has started operationalizing consolidated
using an internal credit risk rating system for the
supervision since 1998. This was followed by a massive
reorganization of the BSP to support the practice of underwriting and on-going monitoring of their credit
exposures.
consolidated and risk-based supervision.
The BSP has also formally implemented appropriate
BSP’s supervision over banking groups is constrained by
standards for banks’ risk management systems. This
its Charter and the banking law to supervising and
started with the guidelines on the minimum standards for
examining only those subsidiaries and affiliates that are
risk management of financial derivatives.
engaged in allied activities.
This was followed by the guidelines on the minimum
There is no provision for obtaining information from
standards that banks must observe in designing and
non-allied affiliates or the possibility of looking into the
using an internal credit risk rating system for the
operations of these firms even if there is enough reason
underwriting and on-going monitoring of their credit
to do so. Greater flexibility in these areas is in the list of
exposures.
proposed revisions to the existing BSP Charter. In the
interim, cooperative arrangements in the context of the ADOPTION OF INTERNATIONAL STANDARDS
FSF have provided an adequate work-around to these
constraints.  Basel Core Principles for Effective Banking
Supervision
 Third quantitative impact study (QIS) of Basel
II 
 Philippine Financial Reporting Standards
(PFRS)
 Philippine Accounting Standards (PAS)

DEVELOPMENTAL INITIATIVES

The BSP has more confidently pursued a targeted


developmental agenda to promote further development
of the Philippine financial system while maintaining
prudential standards.

These initiatives include:

1. capital market development through


contributions to foreign exchange liberalization,
domestic bond and derivatives market
development and payments systems upgrades;
2. enhanced access to banking services by the poor
through sustainable microfinance practices of
banks and innovative deployment of mobile
banking services; and
3. promoting financial literacy.

The BSP has also prioritized in its legislative advocacy


the establishment of a comprehensive credit information
system through enactment of the Credit Information
System Act, the modernization of the payments system
through the Payment System Act, and the reform of the
bankruptcy framework through the Corporate Recovery
Act. 

It also supports various capital market development-


oriented bills such as the Personnel Equity Retirement
Act which promotes private long-term saving for
retirement income augmentation.

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