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Bankers time to make plans for the self-healing of banks, the Central Bank decided. Guidelines for their development regulator sent to banks and expects the first results by the end of the year. Bankers hope that recommendatory status of the document will not lead to sanctions for non-compliance. In Central banks are considering the implementation of recommendations as a test of transparency.

Guidelines for the development of recovery plans by credit institutions financial stability in the Bank of Russia has sent a letter to N 193-T on December 29, 2012 its regional offices to bring the contents of the letter to the bank. This letter (there are at the disposal of "b") regulator recommends that banks begin to develop options to address possible financial difficulties.

The main risks to the banking system, the Bank of Russia sees a significant slowdown of the Russian economy, the significant decline in oil prices, rising interest rates and falling stock markets. For such scenarios, the controller asked to develop plans that would maintain the necessary level for capital adequacy and liquidity. For example, the Bank of Russia has its own options and the bank in a difficult economic situation. So, to maintain a sufficient level of equity to consider the possibility of raising capital from shareholders (existing and new), the termination of any payments to the founders, the conversion of existing obligations in the bank capital. And to strengthen the liquidity situation is proposed (in addition to standard tools, such as raising funds from the Central Bank) to analyze the opportunities to raise additional funds from the bank-affiliated structures, redistribution of cash flows within the banking group, and to provide additional collateral for future creditors. The only thing that should include plans drawn up by banks - is getting support from the state. It if necessary, will provide a rehabilitation plan systemically important players, compiled by the Central Bank, but the bank they will be classified.

In preparation for self-improvement plan, banks will have to conduct stress tests on various negative scenarios of the economic situation. The base scenario CB offers this: reduction of Russia's GDP by 1.5%, a decline of stock indices by 30-50%, as well as a sharp rise in yields on government (by 200-350 basis points) and corporate (500-1000 bp) bonds. In this case, the Bank's initiative to develop their own additional criteria for the stress tests is welcome.

Except the recovery plan of the Central Bank also offers banks to independently develop a system of indicators determine when the need to put in place the prepared action. Here recommendations rather vague, such as "a steady decline in the capital adequacy ratio," "steady and significant increase in the share of problem loans," "significant decrease in credit ratings," "steady flow of customers."

"In principle, the appearance of such advice is clear - says CEO of Alfa Bank Alexey Marey. - This is a tendency on the part of regulators in many countries. However, as it will be positive for our banking system, while we can not say. European banks for the formulation of such plans is justified, because their business is much more dependent on the investment division and the stock market than the business of Russian banks, so as this is justified for our market issue. " "For Russia, this is irrelevant task - agree Deputy Chairman of VTB Bank Herbert Moos. - Indeed, the West has created a situation in which the state is not ready to save the banks and offers his own to attend to the matter. In Russia, the budget surplus, the Central Bank and the banks have accumulated adequate margin of safety. However Central Bank does not want to be out of the trend, and so followed a formal request. "

Meanwhile, make a quality plan to resolve the crisis is not easy, say bankers. "Year after year, the regulatory burden is increasing, - says CEO UniCredit Bank Mikhail Alekseyev. - I am afraid that many commercial banks are the plan formally. But if something happens, will not act on the plan, but based on the current situation. " "Unfortunately, the market is very few professionals who can make a real working plan for self-improvement, - the financial director of BIN Bank Alexei Kitaev. - In banks, and the" Big Four "auditors, and perhaps, in the Central Bank. Though net labor there is not much - to plan and maintain it need one expert. But where is it from? "

All the plans for self-improvement promises to evaluate the CB, in the future, a year or two, perhaps, and take them into account when assessing the economic situation of the banks. Range of banks, which is proposed to develop a financial recovery plan, the document is not clearly delineated. It implies that it is a systemically important and especially the big players, it does not exclude from the process of the preparation of plans and all other market participants. Time frame for the first plans in the letter are not given, but, according to vice-president of the Bank of Russia Mikhail Sukhov, the regulator considers it appropriate that their development was started before the end of this year. According to him, the bank plans to evaluate compiled securities will be primarily for realism. Punishment for the banks formally approached the preparation of plans, are not provided, but in terms of the degree of realism control plan will reflect the bank's penchant for transparency and ultimately determine the overall attitude of the controller to a particular player.

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