2008-07-17
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The Financial Services Agency issued this directive to implement a new rating system for deposit-taking financial institutions, aiming to promote voluntary management improvement and enhance inspection efficiency. The system evaluates institutions across ten key areas, including governance, legal compliance, and risk management, using a four-grade scale from A to D. These ratings directly influence selective regulatory measures, such as the frequency and scope of future inspections, with full implementation scheduled for April 2007.
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(Provisional translation)
*This translation is provisionally prepared and subject to change without notice. Financial Inspection Rating System (Financial Inspection Rating System for Deposit-taking Financial Institutions) February 2007
Inspection Bureau No. 370
July 1, 2005
To: Director-Generals of Local Finance Bureaus Director-General, Okinawa General Bureau Inspection Administrator Chief Financial Inspectors Senior Financial Inspectors Special Financial Inspectors Financial Inspectors From: Masao Nishihara, Director-General, Inspection Bureau, Financial Services Agency Financial Inspection Rating System for Financial Inspections In December last year, the Financial Services Agency (FSA) developed and released the “Program for Further Financial Reform - Japan's Challenge: Moving toward a Financial Services Nation,“ which charted the course of its actions in the coming two years. Based on the recognition that the current financial system is “entering a new forward-looking phase aiming at establishing a desirable financial system for the future, having now moved beyond the emergency reaction against the non-performing loans problem,” the Program aims to create a desirable financial system through the efforts of the private sector, rather than under the initiative of the public sector. To that end, it proposed a “sharp, effective and selective administrative response through the introduction of a rating system into inspections that is based not only on the financial situation, but also on various viewpoints of financial institutions.” Based on the deliberation results, etc. of the Financial Inspection Rating System Study Group, we have developed and decided to implement the Financial Inspection Rating System for financial institutions as shown below, which you are asked to fully acquaint yourself with and internalize.
Inspection Bureau and request a review.
(3) The final rating results shall be notified to the inspected financial institution as part of the inspection result report.
6. Reflection in Selective Regulatory Measures
The rating results shall be reflected in the frequency, scope and depth of subsequent inspections.
7. Implementation Date, etc.
The Financial Inspection Rating System shall be put into effect on April 1, 2007. Rating results based on inspections to be notified thereafter (or inspections to be started thereafter, in the case of inspections without notice) shall be reflected in selective regulatory measures. With regard to financial institutions other than major banks, however, rating results based on inspections to be notified on and after January 1, 2008 (inspections to be started on and after January 1, 2008, in the case of inspections without notice) shall be reflected in selective regulatory measures.
Rating Grades/Points of Attention in Rating
(Financial Inspection Rating System)
February 2007
(Attachment)
Rating Grades
Points of Attention in Rating, etc.
[Basic Points of Attention]
institution. It should be noted that the inspector shall take care to avoid making excessive intervention in matters that concern the management decisions of the financial institution.
important for the inspector to check whether measures have been taken to make up for this, through dialogue with the financial institution. Regarding the independence of the internal audit division, in cases where an employee allocated to the division works concurrently for another division, it is important for the inspector to identify the cause and background of this situation and examine whether it is undermining efforts to ensure the effectiveness of internal audits, through dialogue with the financial institution.
Rating Grades
2. Legal Compliance
A:
A strong compliance system has been established by the management of the financial institution. Any recognized weakness is minor and has an insignificant effect on the appropriateness of the financial institution’s business operations. B:
A sufficient legal compliance system has been established by the management of the financial institution, although minor violations of Laws are recognized. Although there are weaknesses in the system, they are not so serious as to have material effects on the appropriateness of the financial institution’s business operations, and the financial institution has already taken appropriate measures to address them on a voluntary basis, or can be expected to do so in the future. C:
The legal compliance system established by the management of the financial institution is insufficient, as non-minor violations of Laws are recognized. The system needs to be improved because the efforts made by the management of the financial institution to ensure legal compliance are insufficient, and this inadequacy is deemed to be affecting the appropriateness of the financial institution’s business operations. D:
The legal compliance system established by the management of the financial institution is defective or seriously defective, with violations of Laws involving the management itself being recognized, for example. The deficiency of the system may lead to, or has led to, the occurrence of a violation of Laws that could threaten the ability of the financial institution to continue operating as such.
Points of Attention in Rating, etc.
[Basic Points of Attention]
In giving a rating, the inspector shall pay due consideration to the “Checkpoints” in
the “Checklist for Legal Compliance.”
In giving a rating, the inspector shall put priority on examining whether an effective
legal compliance system has been established in light of the checklists contained in “I. Development and Establishment of Legal Compliance System by Management” and “II. Development and Establishment of Legal Compliance System by Manager.”
In giving a rating, the inspector shall take account of which of the relevant processes –
the formulation of the policy regarding the legal compliance system, the establishment of the system, and the review of the policy and system – involves a problem.
With regard to the issues pointed out on the occasion of the last inspection (non-minor
issues in particular), it is important for the management to take the initiative in developing and implementing effective improvement measures. If only stop-gap measures or insufficient improvement measures have been taken, the inspector shall focus on grasping how the management recognizes the current situation and on identifying the cause and background of the lack of sufficient improvement measures, and give a rating in light of this. It should be noted that the evaluated improvement in the issues pointed out on the occasion of the last inspection shall be considered as a factor when judging whether the financial institution can be expected to take improvement measures on a voluntary basis with regard to the issues pointed out in the current inspection. [Positive Factor]
If the evaluation and improvement activities of the Board of Directors, etc. and the
manager in charge of the compliance control division are effective and create a virtuous circle of constant improvement efforts by officers and employers of the financial institution, this shall be considered as a positive factor in giving a rating. [Negative Factor]
If any of the following is recognized through the process of inspection, it shall be
considered as a negative factor in giving a rating, since it may be taken as evidence that the financial institution has no shortage of weaknesses in its legal compliance system but has taken insufficient improvement measures. (1) A case where the financial institution has concealed or tolerated a violation of Laws, or intentionally neglected to report it to the authorities. However, it should be borne in mind that it is necessary to determine the seriousness of the case by identifying its extent, the roles played by the management and the circumstances regarding how the concealed violation of Laws has come to light, and take account of the seriousness in giving a rating. (2) A case where the financial institution has intentionally made an inaccurate disclosure of the amount of non-performing loans. (3) A case where similar inappropriate incidents have occurred at two or more branches, etc. or a number of such incidents have occurred in succession, because measures for preventing the recurrence of inappropriate incidents are ineffective. [Other Points of Attention]
In evaluating the financial institution’s policy regarding the legal compliance system,
the inspector shall bear in mind that the key point is whether the policy prescribes a strict stance on anti-social forces, the prevention of money laundering and inappropriate incidents, etc. and whether the policies are effective and suited to the actual state of the financial institution’s business operations. It should be noted that the inspector shall take care to avoid making excessive intervention in matters that concern the management decisions of the financial institution.
The inspector shall bear in mind that although the scale and nature of the financial
institution need to be taken into consideration when evaluating the establishment of necessary arrangements and procedures at the compliance control division and the improvement of the control environment for legal compliance at individual operational divisions, sales offices, etc., these factors cannot constitute an excuse for any violation of Laws. With this in mind, the inspector shall grasp the effects of any detected violation of Laws on the management of the financial institution, as well as the cause and background of the violation, and give a rating in light of this.
In giving a rating, the inspector shall take into consideration the cause and background
of any detected violation of Laws, as well as its impact on the management of the financial institution, even if the violation concerns laws other than those specified in “III. Specific Issues.”
With regard to response and improvement measures taken in relation to a violation of
Laws, it is important for the management to take the initiative in developing and implementing rigorous and effective measures in light of the cause and background of the violation. If only stop-gap measures or insufficient improvement measures have been taken, the inspector shall focus on grasping how the management recognizes the current situation and on identifying the cause and background of the lack of sufficient measures, and give a rating in light of this.
Rating Grades
3. Customer Protection Management
A:
Systems for managing elements of customer protection, such as the Customer Explanation Management System, the Customer Support Management System, the Customer Information Management System and the Outsourcing Management System, have been strongly established by the management and are functioning properly. Any recognized weakness is minor and has an insignificant effect on the appropriateness of the financial institution’s business operations. B:
Systems for managing elements of customer protection, such as the Customer Explanation Management System, the Customer Support Management System, the Customer Information Management System and the Outsourcing Management System, have been sufficiently established by the management. Although there are weaknesses in the systems, they are not so serious as to have material effects on the appropriateness of the financial institution’s business operations, and the financial institution has already taken appropriate measures to address them on a voluntary basis, or can be expected to do so in the future. C:
The systems established by the management for managing elements of customer protection, such as the Customer Explanation Management System, the Customer Support Management System, the Customer Information Management System and the Outsourcing Management System, are insufficient, as non-minor deficiencies of the systems are recognized. The systems need to be improved because the efforts made by the management of the financial institution to ensure customer protection are inadequate and this inadequacy is deemed to be affecting the appropriateness of the financial institution’s business operations. D:
The systems established by the management for managing elements of customer protection, such as the Customer Explanation Management System, the Customer Support Management System, the Customer Information Management System and the Outsourcing Management System, are defective or seriously defective. For example, the systems are
insufficient. The deficiency of the system may lead to the defection of customers and threaten the ability of the financial institution to continue operating as such, or have already led to such a situation.
Points of Attention in Rating, etc.
[Basic Points of Attention]
descriptions to facilitate their understanding, rather than providing abstract explanations, and the financial institution reviews and revises these materials on an ongoing basis in order to make them easy-to-understand and suited to the needs of customers, by reflecting the opinions of customers in the revisions. (2) The Customer Explanation Management and Customer Support Management are effectively coordinated to produce synergy effects. For example, the financial institution promptly and properly reviews and revises the Customer Explanation Manuals in light of problems identified in the process of customer support management. (3) The financial institution not only makes proper efforts to enhance the Customer Explanation Management System, the Customer Support Management System, the Customer Information Management System and the Outsourcing Management System, but also ensures the effectiveness of customer protection by properly managing other processes it has determined to be essential to customer protection and improving customer convenience. (4) Assessment and improvement activities conducted by the Board of Directors, etc. and the managers in charge of customer protection produce effective results, leading customers to constantly appreciate improvements made by the financial institution. [Negative Factor]
Rating Grades
4. Comprehensive Risk Management
A:
A strong comprehensive risk management system suited to the scale and nature of the financial institution has been established by the management. All major risks have been consistently identified, kept track of and managed in an effective manner, and any recognized weakness is minor and has an insignificant effect on the soundness of the financial institution’s business operations. B:
A sufficient comprehensive risk management system suited to the scale and nature of the financial institution has been established by the management. Most major risks and problems have been identified, kept track of and managed. Although there are weaknesses in the system, they are not so serious as to have material effects on the soundness of the financial institution’s business operations, and the financial institution has already taken appropriate measures to address them on a voluntary basis, or can be expected to do so in the future. C:
The comprehensive risk management system established by the management is insufficient considering the scale and nature of the financial institution. The system needs to be improved because the management’s comprehensive risk management capability is inadequate and this inadequacy is deemed to be affecting the soundness of the financial institution’s business operations. D:
The comprehensive risk management system established by the management is defective or seriously defective. The deficiency of the system may lead to, or has led to, an inappropriate incident or an unexpected loss that could threaten the ability of the financial institution to continue operating as such.
Points of Attention in Rating, etc.
[Basic Points of Attention]
[Negative Factor]
Rating Grades
5. Capital Management
A:
A strong capital management system suited to the scale and nature of the financial institution has been established by the management, and the financial institution has a strong level of capital in terms of both quality and quantity. B:
A sufficient capital management system suited to the scale and nature of the financial institution has been established by the management, and the financial institution has a sufficient level of capital. Although there are weaknesses in the system, they are not so serious as to have material effects on the soundness of the financial institution's business operations, and the financial institution has already taken appropriate measures to address them on a voluntary basis, or can be expected to do so in the future. C:
The capital management system established by the management is insufficient considering the scale and nature of the financial institution, or the financial institution has an insufficient level of capital. The system needs to be improved because the management’s capital management capability is inadequate and this inadequacy is deemed to be affecting the soundness of the financial institution’s business operations. D:
The capital management system established by the management is defective or seriously defective. The deficiency of the system may reduce, or has reduced, the financial institution’s capital amount to such a low level as to threaten the ability of the financial institution to continue operating as such.
Points of Attention in Rating, etc.
[Basic Points of Attention]
(1) The discrepancy between the capital adequacy ratios before and after the inspection is 10% or higher. (2) Although the discrepancy between the capital adequacy ratios before and after the inspection is less than 10%, a significant defect is recognized in the calculation process. For example, there are a number of incorrect calculations regarding the amounts of credit risks and assets that may be offsetting the erroneous effects of one another, thus limiting the discrepancy in the capital adequacy ratio.
Rating Grades
6. Credit Risk Management
A:
A strong credit risk management system suited to the scale and nature of the financial institution has been established by the management. Any recognized weakness is minor and has an insignificant effect on the soundness of the financial institution’s business operations. B:
A sufficient credit risk management system suited to the scale and nature of the financial institution has been established by the management. Although there are weaknesses in the management of the screening process, they are not so serious as to have material effects on the soundness of the financial institution’s business operations, and the financial institution has already taken appropriate measures to address them on a voluntary basis, or can be expected to do so in the future. C:
The credit risk management system established by the management is insufficient considering the scale and nature of the financial institution. The system needs to be improved because the management’s credit risk management capability is inadequate and this inadequacy is deemed to be affecting the soundness of the financial institution’s business operations, as problems are recognized in the management of the screening process or excessive credit concentration is being detected, for example. D:
The credit risk management system established by the management is defective or seriously defective. The deficiency of the system may threaten, or is threatening, the ability of the financial institution to continue operating by further credit concentration or by the deterioration of asset quality due to the worsening business performance of the borrowers where credit is concentrated.
Points of Attention in Rating, etc.
[Basic Points of Attention]
(2) Through thoroughly communicating to the Marketing and Sales division the purpose of the supplement to the financial inspection manual: treatment of classifications regarding credits to small and medium-sized enterprises, the financial institution makes efforts to grasp the management status of SMEs and support their business rehabilitation, thereby enhancing the credit risk management system. (3) Through activities such as monitoring, management consultations and advice, the financial institution seeks to maintain close communications with SME borrowers, precisely grasp their management status and properly reflect the results in its credit risk management. (4) The financial institution engages in efforts to support the rehabilitation of SMEs that have fallen into a business slump or that are about to do so, thereby reducing the overall credit risk of the financial institution. (5) With regard to the future business potential of SMEs, the financial institution engages in efforts to enhance the ability to make appropriate judgment and strengthen the credit screening system, thereby preventing the occurrence of problem loans, or increasing the chance to discover companies with promising potential.
[Other Points of Attention]
Rating Grades
7. Asset Assessment Management
A:
Strong systems for elements of asset assessment management, such as self-assessment, write-offs and loan loss provision, suited to the scale and nature of the financial institution have been established by the management. Any recognized weakness is minor and has an insignificant effect on the soundness of the financial institution’s business operations. B:
A sufficient asset assessment management system suited to the scale and nature of the financial institution has been established by the management, ensuring a sufficient level of write-offs and loan loss provision suited to the credit risk level. Although there are deficiencies regarding the accuracy of self-assessment, they are not so serious as to have material effects on the soundness of the financial institution’s business operations, and the financial institution has already taken appropriate measures to address them on a voluntary basis, or can be expected to do so in the future. C:
The asset assessment management system established by the management is insufficient considering the scale and nature of the financial institution, or the level of write-offs and loan loss provision is not suited to the credit risk level. The system needs to be improved because the management’s asset assessment management capability is inadequate, and this inadequacy is deemed to be affecting the soundness of the financial institution’s business operations, as deficiencies are recognized in the systems for self-assessment and write-offs and loan loss provision. D:
The asset assessment management system established by the management is defective or seriously defective. The deficiency of the system may threaten or is threatening the ability of the financial institution to continue operating as such, with a substantial shortfall being recognized in the amount of write-offs and loan loss provision, for example.
Points of Attention in Rating, etc.
[Basic Points of Attention]
the scale and nature of the financial institution in mind.
If an improvement is not recognized, it is necessary to identify the cause and background of the lack thereof, fully examine what kind of problem there is with regard to the asset assessment management system and reflect the findings in the rating.
Rating Grades
8. Market Risk Management
A:
A strong market risk management system suited to the scale and nature of the financial institution has been established by the management. Any recognized weakness is minor and has an insignificant effect on the soundness of the financial institution’s business operations. B:
A sufficient market risk management system suited to the scale and nature of the financial institution has been established by the management. Although there are weaknesses in the system, they are not so serious as to have material effects on the soundness of the financial institution’s business operations, and the financial institution has already taken appropriate measures to address them on a voluntary basis, or can be expected to do so in the future. C:
The market risk management system established by the management is insufficient considering the scale and nature of the financial institution. The system needs to be improved because the management’s market risk management capability is inadequate, and this inadequacy is deemed to be affecting the soundness of the financial institution’s business operations. D:
The market risk management system established by the management is defective or seriously defective. The deficiency of the system may lead to, or has led to, an inappropriate incident or an unexpected loss that could threaten the ability of the financial institution to continue operating as such.
Points of Attention in Rating, etc.
[Basic Points of Attention]
weaknesses of and problems in the market risk management system, thereby helping to enhance the system, this shall be considered as a positive factor in giving a rating.
Rating Grades
9.Liquidity Risk Management
A:
A strong liquidity risk management system suited to the scale and nature of the financial institution, particularly its urgency level of funds needs and its liquidity status, has been established by the management. Any recognized weakness is minor and has an insignificant effect on funds management by the financial institution. B:
A sufficient liquidity risk management system suited to the scale and nature of the financial institution, particularly its urgency level of funds needs and its liquidity status, has been established by the management. Although there are weaknesses in the system, they are not so serious as to have material effects on funds management by the financial institution, and the financial institution has already taken appropriate measures to address them on a voluntary basis, or can be expected to do so in the future. C:
The liquidity risk management system established by the management is insufficient considering the scale and nature of the financial institution, particularly its urgency level of funds needs and its liquidity status. The system needs to be improved because the management’s liquidity risk management capability is inadequate, and this inadequacy is deemed to be affecting funds management by the financial institution. D:
The liquidity risk management system established by the management is defective or seriously defective in relation to the scale and nature of the financial institution, particularly its urgency level of funds needs and its liquidity status. The deficiency of the system may lead to or has led to funds management problems, etc. that could threaten the ability of the financial institution to continue operating as such.
Points of Attention in Rating, etc.
[Basic Points of Attention]
In giving a rating, the inspector shall pay due consideration to the “Checkpoints” of
the “Checklist for Liquidity Risk Management.”
In giving a rating, the inspector shall put priority on examining whether an effective
liquidity risk management system has been established in light of the checklists contained in “I. Development and Establishment of a Liquidity Risk Management System by Management” and “II. Development and Establishment of a Liquidity Risk Management System by Managers.”
In giving a rating, the inspector shall take account of which of the relevant processes
-the formulation of the policy regarding the liquidity risk management system, the establishment of the system, and the review of the policy and the system-involves a problem.
With regard to the issues pointed out on the occasion of the last inspection (non-minor
issues in particular), it is important for the management to take the initiative in developing and implementing effective improvement measures. If only stop-gap measures or insufficient improvement measures have been taken, the inspector shall focus on grasping how the management recognizes the current situation and on identifying the cause and background of the lack of sufficient improvement measures, and give a rating in light of this. It should be noted that the evaluated improvement in the issues pointed out on the occasion of the last inspection shall be considered as a factor when judging whether the financial institution can be expected to take improvement measures on a voluntary basis with regard to the issues pointed out in the current inspection. [Positive Factor]
If the management actively involves itself in efforts to grasp and analyze the
weaknesses of and problems in the liquidity risk management system, thereby helping to enhance the system, this shall be considered as a positive factor in giving a rating. [Other Points of Attention]
The inspector shall determine how much importance should be attached to the market
liquidity risk in giving a rating, by taking account of the nature and scale of the financial institution’s risk, based on the recognition that this type of risk is a particularly important item when the relevant financial institution has a large amount of over-the-counter derivatives positions (relative to the market size), for which liquidity is limited.
When evaluating the funds operation and management, the inspector shall bear in
mind that the key point is whether the management method is effective in light of the scale and nature of the financial institution.
Rating Grades
10.Operational Risk Management
A:
A strong operational risk management system suited to the scale and nature of the financial institution has been established by the management. Any recognized weakness is minor and has an insignificant effect on the soundness of the financial institution’s business operations. B:
A sufficient operational risk management system suited to the scale and nature of the financial institution has been established by the management. Although there are weaknesses in the system, they are not so serious as to have material effects on the soundness of the financial institution’s business operations, and the financial institution has already taken appropriate measures to address them on a voluntary basis, or can be expected to do so in the future. C:
The operational risk management system established by the management is insufficient considering the scale and nature of the financial institution. The system needs to be improved because the management’s operational risk management capability is inadequate, and this inadequacy is deemed to be affecting the soundness of the financial institution’s business operations, as non-minor administrative errors or a system breakdown affecting customers are recognized. D:
The operational risk management system established by the management is defective or seriously defective. The deficiency of the system may lead to or has led to a serious system breakdown or administrative error that could threaten the ability of the financial institution to continue operating as such.
Points of Attention in Rating, etc.
[Basic Points of Attention]
[Positive Factor]
[Other Points of Attention]
Inspection Bureau No. 81
February 16, 2007
To: Director-Generals of Local Finance Bureaus Director-General, Okinawa General Bureau Inspection Administrator Chief Financial Inspectors Senior Financial Inspectors Special Financial Inspectors Financial Inspectors From: Masao Nishihara, Director-General, Inspection Bureau, Financial Services Agency Partial Revision of the Financial Inspection Rating System for Deposit-Taking Financial Institutions The Financial Services Agency (FSA) formulated the Financial Inspection Rating System for Deposit-Taking Financial Institutions (Inspection Bureau No. 370) (hereinafter referred to as the “Financial Inspection Rating System”) on July 1, 2005, and has been applying it on a trial basis since January 2006. Following the complete revision of the Inspection Manual for Deposit-Taking Institutions (Inspection Bureau No. 177) recently, the FSA has partially revised the Financial Inspection Rating System as follows, and asks that you acquaint yourself with the revisions and make sure to act accordingly.
*Revision Concerning “3. Rating Method”
“Rating Grades and Evaluating Points (Examples)” is changed to “Rating Grades/Points of Attention in Rating.” *Revision Concerning “7. Implementation Date, etc.” The following is the revised text. “The Financial Inspection Rating System shall be put into effect on April 1, 2007. Rating results based on inspections to be notified thereafter (or inspections to be started thereafter, in the case of inspections without notice) shall be reflected in selective regulatory measures. With regard to financial institutions other than major banks, however, rating results based on inspections to be notified on and after January 1, 2008 (inspections to be started on and after January 1, 2008, in the case of inspections without notice) shall be reflected in selective regulatory measures.”
2. The Rating Grades and Evaluation Points (Examples), an attachment to the “Financial Inspection Rating
System for Deposit-Taking Financial Institutions”, is revised as the Rating Grades/Points of Attention in Rating.
3. Implementation Date
The Financial Inspection Rating System shall be applied to inspections to be notified on and after April 1, 2007 (inspections to be started on and after April 1, 2007, in the case of inspections without notice).
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Source: Financial Services Agency Japan — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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