欧盟的宏观审慎政策——关于制度背景和治理安排的思考

Elias Bengtsson
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引用次数: 0

摘要

为应对全球金融危机,宏观审慎政策已牢固确立为防止金融部门过度冒险并减轻其对实体经济影响的金融政策领域。它已彻底融入全球标准制定者和国际组织(FSB, BCBS, IOSCO, IMF, BIS等)的工作计划以及区域和国家层面的金融监管。然而,宏观审慎政策要发挥其遏制系统性风险的作用,就需要应对与其政治敏感性和制度背景相关的若干挑战。本政策说明讨论了这些挑战,并描绘了当前关于管理这些挑战的最适当治理安排的政策辩论。此后,它提供了欧盟宏观审慎政策的概述,无论是在欧盟范围内的法律和法规,并在国家层面。政策说明继续讨论制度背景和治理安排如何影响危机后欧盟国家宏观审慎政策的实施。根据这些发现,本文最后提出了一些政策结论,并将其与当前关于宏观审慎政策的国际政策辩论进行了对比:-宏观审慎政策制定者的不作为偏见似乎最好通过任命一个具有强烈透明度要求的单一宏观审慎当局来抵消。单一当局通常表现出更强烈的政策立场,并与更强的独立性和问责制安排联系在一起。透明度很重要,因为开放和透明会减少政治或其他影响:-问责制和独立性安排似乎在解释政策结果方面的能力较弱。这并不是说它们不重要,而是说它们的相互作用可能比个人影响更重要。然而,独立也可能导致以牺牲公众利益为代价的“利己主义”。-多层复杂的政策框架给如何确保宏观审慎当局充分的机构自主权和政策能力带来难题。其中一个例子是欧元区,欧洲央行在国内宏观审慎政策中具有覆盖功能。——围绕宏观审慎政策的政策问题不太可能有灵丹妙药。特别需要在宏观审慎政策领域进行更多的辩论、研究和政策制定;尤其是考虑到它的分配后果,也因为它重新定义了公共权力相对于私人利益的角色。
本文章由计算机程序翻译,如有差异,请以英文原文为准。
Macroprudential Policy in the EU–Reflections on Institutional Contexts and Governance Arrangements
In response to the global financial crisis, macroprudential policy is now firmly established as a financial policy area to prevent excessive risk taking in the financial sector and mitigate its effects on the real economy. It has become thoroughly integrated in the work programmes of global standard setters and international organisations (FSB, BCBS, IOSCO, IMF, BIS etc.) and in financial regulation at the regional and national levels. However, for macroprudential policy to fulfil its role in curbing systemic risk, it needs to manage several challenges relating to its political sensitivity and institutional context. This policy note discusses these challenges, and maps the current policy debate on the most appropriate governance arrangements to manage them. Thereafter, it provides an overview of macroprudential policy in the EU, both in terms of EU-wide law and regulation, and at the national level. The policy note continues by discussing how institutional contexts and governance arrangements appear to have influenced the exertion of macroprudential policy across EU countries in the post crisis period. Drawing on these findings, this note ends with a presentation of a number of policy conclusions and contrast them with the current international policy debate on macroprudential policy: -Macroprudential policy makers’ inaction biases appear to be best counteracted by appointing a single macroprudential authority with strong transparency requirements. Single authorities display generally more intense policy stances, and are associated with stronger independence and accountability arrangements. Transparency matters since openness and transparency reduce political or other influences: - Both accountability and independence arrangements appear to have weaker power to explain policy outcomes. This does not suggest they are unimportant, but rather that their interaction may matter more than individual effect. However, independence may also lead “self-interest capture” at the expense of public interest. - Policy frameworks that are multi-layered and complex pose conundrums on how to ensure sufficient institutional autonomy and policy capacity among macroprudential authorities. One such example is the Euro zone area, where the ECB has an overlay function in domestic macroprudential policy. - It is unlikely that there is panacea to the policy problems surrounding macroprudential policy. Additional debate, research and policy development in the field of macroprudential policy is especially warranted; not least given its distributional consequences and since it redefines the role of public authority over private interest.
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