한국의 거시건전성정책체계 설계: 2 - 단계 최소접근법

The formal institutional framework for macroprudential policy is yet to be created in Korea. Although Korea has been operating for years a couple of informal channels for discussion of major themes in its macroeconomy and finance including macroprudential policy issues relating to systemic risk and financial stability, recent evidence shows that they cannot be relied upon at all to serve the role of the macroprudential policy authorities. This stands in stark contrast to the fact that many countries each have already been formally operating their own institutional arrangements for macroprudential policy, on the heels of the global financial crisis. This paper aims at designing the Korean institutional framework for macroprudential policy that should meet the basic requirements for the effective conduct of macroprudential policy and, at the same time, be adequately attuned to the institutional realities in Korea. In order to do so, Section II provides a literature review, which leads us to the finding that central banks are generally expected either to be charged with macroprudential policy as the competent authority or to play at least an important role therein. The emphasis given to the role of central banks reflects the general understanding that the effective conduct of macroprudential policy requires “a strong institutional framework” that should be built on both the “willingness to act” and the “ability to act.” Further, several typologies of stylized theoretic models found in the literature are briefly reviewed and discussed. On the basis of this literature review and in full consideration of institutional realities in Korea, Section III of the paper comes up with a two-step minimalist approach in its exploration of an appropriate model that should suit Korea properly and effectively. As a result, the paper finds one in the two-party council, tentatively titled the Macroprudential Policy Council (MaPC), in which participate the Bank of Korea (BOK) as the cental bank on one hand, and both the Financial Services Commission (FSC) and the Financial Supervisory Service (FSS) as the prudential regulator on the other. Note that in line with the paper’s minimalist approach MaPC consists of the two core authorities including BOK and FSC/FSS, with the Ministry of Finance and Strategy (MOSF) excluded. This feature is embedded in the model in view of the deep-rooted Confucianist cultural tradition in Korea where “the vertical institutional hierarchy” has long been entrenched. As long as the macroprudential policy framework is mandated to deal with the prevention side of crisis only, the two parties will suffice. In addition, this minimalist approach will contribute to mitigating effectively such inherent tendencies as “group-think” to which multi-agency councils are deemed vulnerable. The two-party council may well have considerable significance in the sense that it can be interpreted to be a natural arrangement resulting from the process of institutional evolution, as was evidenced in case of the Council for Cooperation on Macroprudential Policy that existed, though briefly, in Sweden for a couple of years back in 2012 and 2013. Note also that in line with the paper’s two-step approach MaPC is designed to take its first step to the beginning stage which allows each participant to buy enough time to get adjusted and prepared before taking its second step to move on to the completion stage. This feature importantly reflects the fact that BOK currently leaves much to be improved in terms of its willingness and ability to act, whereas FSC, along with the FSS, needs to learn how to cooperate and coordinate with BOK in macroprudential policy. In the first stage, BOK is left with few policy tools of its own to be used distinctively for the macroprudential policy purposes, while FSC/FSS, in their capacity of microprudential policy authorities, own and control most macroprudential tools. In the second stage, however, a few cyclical macroprudential tools could be assigned to BOK, which is generally expected to hold comparative advantage in analyzing and dealing with, if anything, the cyclical dimension of systemic risk. What is particularly unique about MaPC lies in a couple of specific rules that govern its modus operandi. The Council is supposed to apply either the ‘consultation’ rule or the ‘positive endorsement’ rule, depending on whether a proposed item on the agenda one party submits to MaPC for discussion is to request, via consultation, the other to act, or to seek positive endorsement from the other so as to carry out one’s own plan to act. Once it is either consulted or positively endorsed as the case may be, the submission will have become a recommendation issued in public by the Council with its addressee being obliged to ‘comply or explain’. Considering that most policy tools are in the hands of the financial supervisory authorities, these specific rules governing MaPC are contrived mainly for the purpose of ensuring BOK to exert checks and balances effectively upon FSC/FSS. Finally provided in Section IV are conclusive remarks on potential merits and limits of the institutional framework which this paper has proposed.