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Annex A.1
IMF FSAP/FSSA 2015
| Recommendations and Authority Responsible for Implementation |
| Time |
Banking Oversight
| Develop a remedial action program focusing on new tools, earlier step-up enforcement and heavier fines to expedite corrective action (FBA, BARS, relevant Ministries of Finance and Justice). |
| NT |
| Strengthen provisioning under IAS by issuing standards to encourage conservative assumptions on impairment by banks (FBA, BARS). |
| MT |
| Enact new Laws on Banks and amend relevant legislation addressing deficiencies in supervisory powers, consolidated supervision, and identification of ultimate beneficiary owners (FBA, BARS, CBBH, Ministries). |
| I |
| Conduct additional AQRs in banks with weak solvency and liquidity indicators (FBA, BARS). |
| I |
| Assure that banks continue implementing IFRS and external auditor implement IAS (FBA, BARS). |
| MT |
Insurance Oversight
| The appointment of the FBiH-ISA director should be based on the relevant law (Government). |
| MT |
| The new insurance law in the FBiH should be approved if it shows improved convergence towards the EU insurance directives (FBiH-ISA). |
| I |
| Introduce a formal channel of information sharing with banking agencies (FBiH-ISA). |
| I |
| Update solvency regime by a gradual incorporation of risk elements, develop an early warning system, including prompt corrective actions. Capacity building is required (ISAs). |
| I |
Financial Safety Net, Resolution of NPLs, and Systemic Liquidity Management
| Revise the reserve requirements, maturity mismatch, and the liquidity ratio (CBBH, FBA, BARS). |
| NT |
| Design and implement the LCR, adapted to BiH (FBA, BARS). |
| MT |
| Revise the consequences to banks for not complying with reserve requirement (CBBH). |
| MT |
| Enable prompt depositor pay-out (DIA). |
| I |
| Provide resolution powers to the FBA and BARS for banks in their respective jurisdictions on the new Laws on Banks, following the FSB Key Attributes and EU BRRD (FBA, BARS, DIA, relevant Ministries) |
| I |
| Broaden the scope to draw on the existing DIF for funding bank resolution using least-cost solution (DIA) |
| I |
| Establish a Financial Stability Fund (FSF)—under the DIA—to provide for open bank resolution and limited and temporary liquidity support in systemic crisis (DIA, CBBH, FBA, BARS, Governments). |
| MT |
| Strengthen, regularly review, and test bank contingency plans of SCFS members (SCFS). |
| I |
| Strengthen the cooperation between DIA and financial safety net players (DIA, CBBH, FBA, BARS). |
| I |
| Add macroprudential analysis and policy to the coordination MoU. Define and collect additional information for the assessment of vulnerabilities and macroprudential tools (CBBH, FBA and BARS). |
| NT |
| Streamline collateral execution procedures by allowing a final auction at no reserve price if previous rounds of auctions failed and specify realistic criteria for asset market values (RS/FBiH Ministry of Justice). |
| I |
| Consider tools and incentives to facilitate restructurings and debt resolution as well as adoption of out- of-court restructuring guidelines. (RS/FBiH/BiH MoF, FBA, BARS). |
| I |
| Revise the insolvency framework by introducing incentives to initiate proceedings early and expand the insolvency framework to cover businesses run by individuals. (RS/FBiH MoJ). |
| NT |
Financial Market Infrastructure
| Strengthen the legal framework to designate payment systems, and to protect settlement finality and netting in line with international standards (CBBH). |
| NT |
| Develop a comprehensive risk management framework for the RTGS system (CBBH). |
| I |
| Stress test the RTGS system, including the default of the largest participant and affiliates (CBBH). |
| NT |
| Establish a recovery time objective for the RTGS system following disruptive events (CBBH). |
| I |
| Establish a new oversight unit in Payment Systems Department, which is staffed with sufficient resources to carry out oversight responsibilities (CBBH). |
| NT |
I-Immediate” is within one year; “NT-near-term” is 1–3 years; “MT-medium-term” is 3–5 years.