I, the problem raised
By the slowdown in economic growth, the current commercial bank loan delinquency rate is still rising, has been close to 2%, non-performing loans and overdue loans "scissors" are still expanding, the potential risk of loans continue to grow. At the same time, the loss of rapid disposal of non-performing loans is getting bigger and bigger, and the disposal recovery rate keeps hitting a new low, especially the loss of disposal of non-performing loans in bulk transfer is huge, which brings a bigger burden to the operational efficiency and financial cost of the bank. Simply curbing non-performing loans, only delay or postpone risk exposure, in the current or short-term to slow down the increase in the rate of non-performing, treating the symptoms but not the root cause, did not detach from the external environment that produces non-performing loans, eliminating the risk of hidden dangers, but also did not fundamentally solve the internal factors of non-performing loan generation.
Macroeconomic fundamentals determine the basic state of the quality of bank credit assets, commercial banks' non-performing loan ratio is, to a greater extent, a reflection of the macro-economic operating situation. Although problems in macroeconomic operations will not be immediately reflected in the quality of bank credit assets, when economic growth appears to have a longer period of downward or weak trend, or problems in macroeconomic operations cannot be fundamentally reversed in the short term, it will ultimately have a substantial impact on the quality of banks' credit assets.
According to the current loan management regulations of commercial banks, interest is usually settled quarterly, and the financing period is mostly 6 to 12 months or more than 1 year. Risks are only exposed and identified as non-performing loans when the loans are in arrears of interest or cannot be repaid for more than 90 days after maturity. For some problem loans, banks usually also refinance, roll over, and sign supplemental agreements to adjust the original contractual elements in order to preserve their assets so that the loan risk is delayed and exposed. In addition, many potentially risky loans are affected or triggered by a variety of other factors before they are exposed. As a result, there is generally a long or short transition period from the time a loan is disbursed to the time it becomes non-performing. In the early stage of economic growth slowdown, credit risk exposure will be slow. However, when economic growth continues to be weak, not only will new credit risks be exposed at an accelerated rate, but some of the mitigated credit risks will also deteriorate downward again, and the accumulated potential risks will be transformed into real risks, thus accelerating the exposure of banks to credit risks significantly, and the rate of deterioration of loans will climb rapidly, and may even persistently outpace the growth of banks' operating revenues and net profits, and in severe cases, liquidity risks will also be triggered.
From the analysis of the current situation, the basic elements of the slowdown in economic growth has not undergone a substantial transformation, the macroeconomic operation of a variety of uncertainties have not been eliminated, and some of the deep-rooted problems continue to accumulate, continuing to affect the bank's credit operating environment. For example, some enterprises with low technological content, backward technology, lack of competitiveness of their products, and difficulties in production and operation have seen an increasing number of shutdowns and semi-shutdowns. Some industries with serious overcapacity have heavy assets and high liabilities, and it is difficult for them to adjust and transform, and the decline in efficiency may persist for a long time. Some of the traditional business model and physical shopping malls and centers, with the changes in the emerging market business has shrunk. Especially some small and micro-enterprises, in the economic upturn in the market demand, can still survive and develop, but when the economic fluctuations will be the first to be hit, the emergence of capital turnover difficulties, the situation of broken capital chain. And this situation will be transmitted to its upstream and downstream areas, resulting in more and more enterprises with production and operation difficulties, insufficient cash flow or broken, leading to credit risk in the customer, industry, region and other dimensions of the continuous proliferation of trends, seriously affecting the stability of the quality of the bank's credit assets. In addition, counterparty risk, cooperative risk, private lending and bank financing and other risks of cross contagion, the spread of proliferation, a large number of external risk of cross-industry cross-border influx of banks, becoming a new source of credit risk, so that the difficulty and complexity of the bank's credit risk management and control is further increased, and the momentum of the rise of non-performing loans will be difficult to curb.
Another problem is that the bank credit operating conditions have not been substantially adjusted to improve with the changes in the external economic environment, and the risk of new financing has still not been effectively controlled. With the economic downturn, pulling the economic growth of investment demand has been reduced significantly, the manufacturing industry is still in the depth of the process of production capacity, consumption can only be gradual growth, exports are facing a lot of uncertainty, it is difficult to have a major rebound in the short term. In such a background, the production and operation of normal enterprises are generally through the issuance of ultra-short-term financing, short-term financing, medium-term notes and a variety of corporate bonds to return bank loans, reduce financing costs. This meant that enterprises with normal operations not only reduced their demand for bank loans, but also repaid their original loans, directly reducing their loan balances. In order to ensure that the total amount of credit is not reduced, the growth rate is not reduced, the bank in addition to make up for the enterprise debt repayment of loans, but also to look for new enterprises with financing needs, and most of these enterprises are some relatively difficult to operate, the potential risks of enterprises. In other words, if you continue to put loans according to the inertia and the traditional way without adjustment, the risk may be greater.
The above analysis shows that the current credit risk problems of banks are mainly affected by the external economic environment and other factors. But in terms of the bank's own reflection, must not be over it, or at most that some branches or relevant personnel are not due diligence, business operations are not in place triggered by the credit risk, but should be from their own risk management to make a deeper analysis. Some of these risk exposures seem to be caused by external factors, and have a certain degree of chance, sudden, or some enterprises or a certain type of enterprise, some branches, or a regional case, but the essence is that some banks have neglected the management of credit strategy risk.
At present, the new non-performing loans among commercial banks are not distributed in a balanced manner, and the non-performing loan ratio varies greatly. In the same region, the external environment is the same, some banks have a low NPL rate, some banks have a high NPL rate; even in the same region of the same bank's different branches are not balanced, some branches have a high NPL rate, some branches have a low NPL rate. The main reason for the differences in the NPL ratios of these banks and branches is the differences in credit structure. Different credit asset distribution structures have different risks, if credit assets are over-represented in certain risky areas or segments, then the corresponding NPL ratio will be higher. For example, the regional risk of Wenzhou and Ordos, the risk of steel, electrolytic aluminum and other industries with serious overcapacity, the risk of commodity financing in bank credit products, the risk of dark factoring, and the risk of mutual guarantee, joint guarantee, and associated guarantee in the way of loan guarantee. Since credit assets are backed by credit customers, customer defaults are manifested as credit asset deterioration. Therefore, the difference in non-performing loans among banks is actually the difference in credit customer structure. The greater the difference in credit customer structure, the greater the difference in credit asset quality; and this difference is not formed in the short term, nor can it be adjusted by one or two operations.
So, the evaluation of the quality of commercial banks' credit assets can not only look at the rate of overdue loans and non-performing loans, which only reflect the quality of credit assets in the current period, and can not reflect the long-term credit quality. The current overdue loan rate and non-performing loan rate are relatively low, which does not indicate that its future risk is controllable and the quality of credit assets is necessarily good. In fact, looking only at the current non-performing loan rate itself is also incomplete, as it includes the factor of write-offs and disposals. In order to judge the quality and stability of a bank's credit assets, it is necessary to analyze the credit structure in depth, including the distribution structure of credit assets by customer, industry, region and product, etc., so as to figure out the real quality of the bank's credit assets and the potential risks, and to judge more accurately the strengths and weaknesses of the commercial bank's credit risk management, as well as the future deterioration of loans in the light of the external economic environment. The only way to judge more accurately the credit risk management of a commercial bank is to judge the magnitude of future loan deterioration in light of the external economic environment.
Further analysis reveals that the differences in credit structure among banks are essentially differences in credit strategy and strategic risk management. Whether it is rational strategic risk prevention and control, or risk appetite decision-making judgment, the strategic risk of credit and its structural risk must be prevented in advance, once the occurrence of strategic risk is very difficult to then effectively control. This is also a more prominent problem in the current credit risk management of banks. Some banks, despite the current non-performing loan ratio increase, but from the perspective of credit strategy risk and other long-term factors, the risk is still controllable; some banks, although the current non-performing loan ratio is not high, but from the perspective of long-term credit strategy risk and other factors, the potential risk is very large and some have been very serious, and is very likely to trigger a regional or even systemic financial risk.
Second, strengthen the credit strategy risk management
Although the current problem of rising non-performing loans of commercial banks is difficult to be resolved in the short term, but this does not mean that the bank will do nothing about it, but to wait for changes in the external economic environment. Commercial banks should respond with a positive attitude, seize the opportunity of the current economic growth slowdown, accelerate the transformation of their credit operations, deepen the reform, improve the mechanism, address both the symptoms and the root causes, and effectively solve the deep-rooted problems restricting and affecting the management of credit risk; not only should we prevent and control and reduce the credit risk of the current period, but also strengthen and improve the management of long-term credit risk, adjust and clarify the credit strategy, prevent and control the credit strategy risk, so that the credit business can have a sound and stable business. The credit business can have a sound long-term development trend.
The so-called credit strategy risk refers to the possibility of a large and persistent credit risk in the future, which is extremely significant to commercial banks and may even lead to the bank's bankruptcy. Credit strategic risk management is to determine the credit strategic objectives and strategic layout according to the external environment and its own risk appetite, in order to prevent and control the strategic credit risks that may be brought about by future macroeconomic fluctuations.
Analyzing credit risk and non-performing loans from the level of credit strategy, it is not difficult to find that the credit asset quality of each bank is closely related to its credit strategy and its risk management. One of the important lessons is that some banks lack a clear credit strategy, rational credit layout, and requirements for prevention and control of hidden credit risks beforehand, and do whatever they can, only to fulfill the current operating targets, and excessively invest in loans in certain areas of higher returns, creating a large number of credit assets with high potential risks. Once the market environment changes, they are in deep trouble of continuous and large-scale exposure of risks. Therefore, in order to address both the symptoms and root causes of the bank's non-performing loan problem and to strictly prevent strategic credit risks, commercial banks should, on the basis of a sufficiently clear understanding of the external economic environment and their own credit operating conditions and risk identification capabilities, formulate a strategic credit risk management plan in the spirit of prudent risk appetite, determine the total volume of credit and structural objectives, and make adequate long-term provision for risk losses.
The key to strategic risk management of bank credit, one is to clearly define the moderate growth of total credit within a certain period of time to ensure that the total amount of risk is controllable. That is, the total amount of risk and risk preparation, financial capacity to match, this is the bank's sound operation of the full embodiment, but also the inherent requirements of risk management. If the credit business develops too fast in the short term, the quality of risk management will be affected and potential risks will accumulate faster accordingly. In particular, the current economic transformation and structural adjustment is not yet in place, some new markets have not yet formed the actual demand for credit, if the bank's total new credit is too much, including loans to new customers and the incremental loans of old customers, a little inadvertence will follow the inertia to continue to invest in the traditional manufacturing industry, wholesale and retail trade, and even some technological backwardness, serious environmental pollution, resource consumption, and overcapacity is serious in the field. Because in these areas, the enterprise operating efficiency decline, rising costs, tightening of the capital chain, there will be a greater demand for financing. If too many loans are disbursed too quickly, the pressure of risk exposure will increase, and it is very easy to lead to new non-performing loans. Therefore, reasonable and moderate control of the total amount of credit should be the basic goal of credit strategy risk management.
The second is to dutifully guard the bottom line of credit strategy risk without wavering and realize the credit strategy goal without wavering. Of course there is a cost to keep the risk bottom line, there is a cost, as far as possible to balance the relationship between short-term gains and long-term risk, market opportunities and risk prevention and control. Only in this way can we avoid large-scale or plate-like deterioration of credit assets when there are fluctuations in the macro-economy; only in this way can there be a basic guarantee of the stability of the quality of the bank's credit assets, the matching of the distribution of credit assets, the controllability of the customer's risk, and the sustainability of the comprehensive income.
Thirdly, it is necessary to determine the future goals of the credit structure within the total amount of credit. The credit structure and the concentration risk prevention and control of each constituent segment is a major issue to be solved by the credit strategy risk management. On the one hand, it is necessary to strictly control the degree of new loan investment structure to avoid structural or concentration risk. Especially at present, the investment growth rate has fallen back to below 10%, the economic growth is gradually transformed from investment-driven to investment- and consumption-driven, and banks should adjust their credit strategy accordingly to increase the proportion of investment in the consumer credit segment. On the other hand, we need to conduct a comprehensive analysis of the structure and concentration of the stock of credit in terms of customers, industries, regions, products, etc., and improve the preventive and control measures for the potential risks therein in a timely manner, as well as continuously optimize the adjustment.
From the customer dimension, the quality structure of credit customers is the foundation of the bank's credit asset quality basis. The good quality and structure of customers indicates that the bank's long-term credit asset quality has a stable foundation. The selection of customers is mainly determined by the bank's risk appetite, and different risk appetites will result in different customer choices. The key is the bank's risk identification ability, and it is difficult to select the right customers without identifying material risks. In implementing the credit customer strategy, banks should make full use of the advantages in data deposition and technical processing, realize risk identification and precise selection of customers through big data, effectively predict and control customer risks, and increase the proportion of good customers, which will become the focus of banks' future innovation and market competition. At the same time, it is necessary to speed up the exit of the stock of customers identified with potential risk factors, especially those with more traditional institutional mechanisms, lack of core competitiveness and excessive financing. Micro and small business customers are more special, not only to commercial principles to evaluate their substantive risk, the total amount of financing to match their own risk management capabilities, risk tolerance, but also from a strategic perspective to cultivate customers, can not overemphasize the risk of the bottom line and give up micro and small business customers.
From the industry dimension, the credit industry distribution has a great impact on the stability of credit asset quality, different industries have different development cycles, different risk performance, so the layout of the industry sector should be in line with the economic development and trend. At present it is to invest credit resources in emerging industries, weak cyclical industries and other industries with relatively low long-term financing risks, and to increase their structural share; for industries with serious overcapacity, serious impact on environmental safety, and serious backwardness in process technology, the total amount of credit should be reduced as soon as possible to lower the structural share; and for industries with strong cyclicality, strict control should be exercised to avoid an overly large share. It is also necessary to pay attention to some industries with large profits in the past, which attracted a lot of investment in the short term, but when this simple high-profit model becomes **** knowledge, it will be transformed into a low-yield industry, and the risk will rise steeply. If such industries account for a higher proportion of financing, then the pressure of credit asset deterioration will be greater in the future, and therefore must be adjusted urgently compression.
From the regional dimension, credit strategy risk management, also need to pay attention to the ratio of total regional credit and regional GDP relationship, the ratio is too large in the region, the potential credit risk will also increase. At present, due to the decline in investment efficiency, the profitability of enterprises, each percentage point of GDP growth to increase more investment than in the past, so that the ratio of total credit growth rate and GDP growth rate in certain regions is rapidly expanding, while the risk is also rapidly accumulating. Banks should differentiate between different situations in terms of credit investment in each region. For regions that have completed or will complete industrialization and urbanization in the process of economic growth, and where transformation and upgrading are relatively smooth, as well as regions with lower levels of industrialization and urbanization and abundant demographic dividends, credit growth can continue to be moderate. On the other hand, regions with a relatively homogeneous industrial structure and little potential for industrialization and urbanization may become depressions of economic growth, and the investment of credit resources needs to be prudently controlled. If too much credit resources to the marginal efficiency of the region, then the future of regional credit risk will increase.
From the product dimension, the structure of credit products is also an important factor affecting asset quality. Lower-risk financing products can keep the quality of credit assets stable, while riskier financing products need to be prudent and should not account for too large a proportion despite higher returns. Especially in the period of economic slowdown or downturn, some traditional credit products with higher returns not only have increased risks, but also have narrowed market demand, and the total volume should be steadily compressed. At the same time, new financing products should be launched at the right time according to market changes, especially to actively innovate, develop the consumer loan market, launch some risk-controllable, suitable for the market demand for consumer financing products, and increase the proportion of consumer financing products.
Third, the necessary conditions for the implementation of credit strategic risk management
The determination of the objectives of credit strategic risk management is not the same as the realization of the objectives, but also need to have a supporting environment and conditions, including the use of new concepts, new mechanisms, new requirements for the management of credit strategic risk. There should be a plan for preventing and controlling large boards and large areas of credit risk and a policy system to match it.
(I) Improve the credit risk management mechanism and clarify risk management responsibilities
To realize the goals set by the credit strategic risk management, it is necessary to improve the operation mechanism of credit risk management, not only to prevent and control the current credit risk, but also to carry out effective prevention and control of the strategic risk and to ensure the high efficiency of customer service. Not only to solve the existing credit risk management in the management level, long operation process and other efficiency problems, but also to solve the front, middle and back departments of mutual checks and balances alienated into the mechanism of risk management responsibilities unclear problem.
It must be clear that credit risk is mainly the risk of customer default, so credit risk management must also be centered on the customer to clarify the position responsibilities of the department and staff, the implementation of the risk responsibility, whoever manages the customer who will bear the risk responsibility. In the whole credit risk management, the main responsibility of the front-end marketing department is to market customers, maintain customer relations, manage customers in the whole process, and bear the main responsibility for customer risk; the independent review of the middle-end risk review department is mainly to assist the marketing department in the identification of customer risk and prevention and control of the gatekeepers, and bear the corresponding responsibility; the back-end monitoring and control department's main responsibility is to unify the customer's view, conduct all-around monitoring of the customer's risk, and report to the customer in a timely manner. The main responsibility of the back-office monitoring department is to unify the customer view, carry out all-round monitoring of customer risks, and promptly alert the marketing department of the customer risk trends that require attention before and after the loan, so as to help do a good job of customer risk control. Through the synergistic cooperation of the three departments, a risk management operation mechanism is formed with the marketing department as the main body, the risk review department and the risk monitoring department as the auxiliary department, which is the premise of each other, mutual constraints, and the unification of responsibilities and powers. Only by improving the responsibility mechanism and clarifying the respective duties in each link of the credit business can we effectively ensure the smooth promotion and implementation of the credit strategy risk management, and make sure that the customers, industries and regions to be entered can be entered efficiently, and the customers, industries and regions to be exited can be exited strategically.
Under the current bank operation and management system, which is mainly based on regional board management and supplemented by business line management, it must be made clear that the basic responsibility of each credit business department is to provide risk decision makers at all levels of institutions with decision-making reference bases as well as relevant policies, products and other services, and to bear the main responsibility for inadequate risk revelation, risk prevention, control or mitigation, and inadequate policy requirements. The decision of whether to do or not to do the financing business of the customer must be made by the head of the institution. Therefore, the heads of institutions at all levels are the final decision makers of credit business and should bear the main responsibility for risk decision making.
Based on the clear mechanism of responsibility, it is necessary to synchronize and improve the matching mechanism of responsibility and rights. Marketing departments bear the main responsibility for customer risk, it is necessary to give full authorization. Not only should they be authorized to conduct due diligence and daily post-loan management of customer credit and debt business, and strictly control the customer's real credit demand, real risk mitigation, and real loan usage, but they should also be responsible for credit business policy guidelines, customer or business access, loan pricing, and product innovation initiation, etc., and take the lead in coordinating the overall allocation and scheduling of resources of various product departments and regions, as well as the individual business related to legal person customers. and its risks to carry out cross-departmental extended marketing management, etc.
In order to improve the efficiency and quality of service to customers, enhance market competitiveness, and avoid the risk of credit customer access selection and the risk of credit investment deviating from the strategic objectives of credit in branches, it is necessary to relatively concentrate marketing resources, adjust marketing methods and strategies, and for the segments that have a greater impact on the credit strategy, the emerging business areas, and the businesses with strong individualized demand, complex product structures, and difficult risk prevention and control. On the basis of the unification of customer selection standards, service standards, risk identification standards, and business operation standards, the direct mechanism of credit top layout and high-level decision-making shall be further improved, and the level of direct customer management shall be upgraded. In addition to small and retail credit business, the grassroots institutions mainly provide the required financial services to customers and assist the higher-level banks to do a good job in customer marketing, so as to provide customers with a full range of integrated financial services in a more complete, professional and efficient manner, and to completely change the current practice of actually having the various grassroots institutions decide on the direction of credit and the credit structure based on the demand of the local market, even causing the problem of reverse adjustments.
(2) Innovative credit risk management
The realization of credit strategic risk management goals requires not only a perfect responsibility mechanism, but also a perfect innovation mechanism, through which limited resources are invested in credit strategic risk management. Under the current complex internal and external environment, to maintain the healthy development of credit business, only through innovation and transformation can we stimulate the vitality of risk prevention and control and improve the efficiency of risk prevention and control. Considering from the perspectives of concept, layout, management, approach and products, credit strategic risk management is itself full of innovation. When all the innovations are brought together they can form a huge innovation dividend, which is manifested in the strategic credit risk management, that is, the credit asset quality remains stable and excellent for a long period of time, the unilateral deterioration of loans continues to be reduced, the potential credit risks have been effectively resolved, the credit structure is constantly optimized, and the return on credit assets is further improved.
One is to standardize the operation of some credit businesses. In other words, consumer credit, micro-credit and other lower-risk credit businesses with controllable risks and high market potential are being standardized and transformed as the focus of credit strategy risk management innovation. As these businesses are large in volume and extensive in scope, they are time-consuming and laborious to operate, and thus require adjustments and modifications to the current credit business operations. Based on the different risk characteristics of this type of business, we set up preventive and control measures and operational processes, and utilize advanced technological innovations in business processing to improve service efficiency and reduce risk management costs. Specifically, with the help of the Internet, big data and other technologies, adopting the "data + model" approach, through networking, automation and other means, purely online or a combination of online and offline, risk prevention and control measures through the model, parameter automatic screening or combined with offline review, etc., to realize the customer's financing business independent or semi-autonomous processing. Processing. This not only facilitates customers to handle financing business without time and geographical constraints, but also relieves grass-roots organizations of a large number of business operations, fully embodying the principle of small, risk-controllable business to take a short process.
The second is the combination of innovative financing business risk management. Due to the traditional administrative management system formed a single business, single species based on the credit business operation and risk management approach, as well as the policy system to match, making the bank in the specific credit business operation is too departmentalized, product-oriented. Not only are customers' financial needs artificially cut up, but some of the bank's financing products are also cut up, making it difficult to synchronize cross-selling, and information, risk prevention and control for the same customer are also separated from being able to **** enjoy. In fact, the marketing of a certain financial product to customers is not only the need for business development, but also an effective way to understand and master customer information, and an important measure for risk prevention and control. Credit risk management should be embedded in business development, not business development and risk management can not be separated, the bank is in the process of providing financial services to customers to realize its effective risk management. Therefore, there is an urgent need to reform the current management system, change the single-business management approach, and implement a good customer strategy on the basis of legal compliance. Accelerate the realization of the overall marketing and integrated financial services of financing business of merchant banking and investment banking, self-management and agency, on-balance sheet and off-balance sheet, local currency and foreign currency, domestic and offshore, etc., and innovate more new products, programs and modes of financing, which at the same time can provide a more complete understanding of the customer's information, strengthen the portfolio risk management, and prevent and control the customer's risk from the credit strategy.
Thirdly, it is to expand new areas of financing and prevent and control new risks. In the face of the complex economic environment and changes in market financing needs, according to the traditional inertia thinking to see the market, really can not find a suitable credit market. The former exuberant demand no longer exists, the general excessive financing as well as a large number of risk exposure has been not much market demand masked, some of the demand seen is also mostly risky, low yield, difficult to manage the business. Therefore, it is important to look at the market and segment it with an innovative mindset, turning negatives into positives, so that a large number of market opportunities and financing needs can be identified. The key is to grasp the characteristics of the market in the new period from the perspective of credit strategy risk management, and to identify risks, prevent and control risks with the help of advanced risk management techniques and methods to adapt to the new market environment, new industrial formats, new business models and new risk performance. For example, there is a great potential for financing demand in service industries such as culture, tourism, health, pension and other kinds of light-asset fields that have an important impact on the layout of the credit strategy structure, as well as financing demand for new projects under the PPP approach. The key is what kind of way to do it, and how to prevent and control the risks involved, all of which require innovation and wisdom. Another example, now banks are trying to find ways to dispose of non-performing assets and problem loans, in fact, a different way of thinking, as a resource packaged into a new product to operate, will open up a new market.
(C) improve employee behavioral risk management
Employee behavioral risk management is an important foundation of the bank's comprehensive risk management, but also a necessary condition for credit strategy risk management, which has a decisive impact on the realization of credit strategy objectives. Managing employee behavioral risk well, credit risk will also be significantly reduced. Credit risk management can hardly be put into practice if we only talk about business risk management but not employee behavior risk management. In fact, strategic credit risk management is the risk management of the overall credit business, not just the risk prevention of a specific debt business, and therefore requires the continuous and dedicated efforts of all employees.
Employee behavioral risk management is to make employees in the whole process of credit business operations to achieve compliance, due diligence, which is also the core of employee behavioral risk management. From the current analysis of the bank's non-performing loan cases, although there are various internal and external factors, but it can not be denied that a significant portion of them are due to employee non-compliance, non-diligence and other behavioral risk factors, so that some of the original can be effective prevention and control of the risk can not be avoided. Compliance and due diligence are not one level. Compliance is what can be done, what can not be done, should be done must be done, should not be done resolutely do not do, this is the red line can not be overstepped. Compared with due diligence, compliance, especially superficial compliance, is easy to do, but to do all the required actions, it is not necessarily due diligence. In essence, compliance can prevent and control operational risk, but it cannot completely prevent and control credit risk. Although many credit risks are triggered by non-compliant operations, no matter how specific the compliance requirements are, it is difficult to cover complex credit risks, and compliance management cannot replace due diligence in preventing and controlling substantive credit risks.
Strengthening employee behavioral risk management, first of all, we must train employees in professional conduct, reverence for the professional ethics and behavioral norms of bank employees, reverence for risk management. Clearly its professional behavioral norms, abide by high standards of professional conduct, consciously perform their duties, diligence and diligence. This is also the basic content of employee behavioral risk management. Secondly, employees should be trained in business skills, comprehensively promote the qualification management system for credit practitioners, and make professional qualifications the basic requirements for engaging in credit work and the rigid constraints for handling specific businesses. We should let the right people do the right things, and resolutely adjust those who do not have risk management ability and quality. Thirdly, it is necessary to strengthen the business skills training and job evaluation of risk management professionals and branch heads, so that the number and quality of risk management professionals and branch heads match the requirements of credit business development. The professionalization of risk management personnel, the expertization of agency heads, and the real implementation of the gradient construction of the team of risk management professionals and heads of branches are the only way to have stable credit asset quality, which is an important guarantee for the realization of credit strategic risk management.
(D) Supervisors should pay attention to the strategic risk of bank credit
Currently, the supervisory authorities should not only adjust the regulatory policy requirements during the period of economic upturn to those under the conditions of economic growth slowdown, but also strengthen the monitoring of regional financial risks in the process of preventing and controlling systematic financial risks, so as to avoid a wider range of systematic financial risks triggered by the local regional financial risks. systemic financial risks. It is not only necessary to pay attention to the total volume and structure of social financing in each region to match its economic development, analyze whether there is a serious risk of over-financing, whether there are potential regional financial risks; should also pay attention to the supervision of the credit strategy risk of banking financial institutions, analyze the total volume of their credit assets and their distribution structure, and do a good job of solving and preventing the hidden risks of the factors that may lead to a large area of risk at an early date.
Supervisory authorities to due diligence supervision, it is necessary to supervise the object of credit strategy risk effective monitoring, the development of credit business in the process of the potential risk of real-time supervision, found that there is anomalies should immediately take regulatory measures, should not wait for the risk are exposed to supervisory risk tips. There is no specific regulatory inspection, regulatory penalties and other regulatory deterrent strict follow-up, it is difficult to really play a regulatory effect.
It needs to be emphasized that speed limits are very important traffic rules and are the most basic measures to ensure road traffic safety. Credit risk exposure, like traffic accidents, is mostly also related to speed. From the current analysis of the reasons for the formation of bank non-performing loans, one of the very important **** reason, is that regardless of a credit business growth rate is too fast or the entire credit business growth rate is too fast institutions, or a region of the financing growth rate is too fast, and its non-performing loans are also exposed to more. Not only is it difficult to sustain the growth of credit business too fast in the short term, but the risk potential can be significant, and a rapid rise in non-performing loans may ensue. In the same economic environment, the development of credit business should have a reasonable degree, more than must have its special reasons, is likely to be risk, at least potential risk. Such as the occurrence of steel trade financing risk, financial guarantee (circle) chain risk, as well as private lending and other large risks in some institutions or regions have had a period of high-speed credit business development, and then the non-performing loan rate, overdue loan rate and other quality indicators are still very good. Therefore, the financial regulator of the banking financial institutions of the credit business development speed should be regulatory restrictions, which bank or its branches of the credit business development is too fast, including the development of a credit product is too fast, the regulator should carry out compliance checks to see whether there is a lack of prudence or non-compliance, and can not simply do some risk tips on the matter.