은행지주회사의 그룹 내부통제체계 실태와 개선 방향

This paper examines the current status of a group-level internal control system (ICS) of bank holding companies (BHCs) and suggests policy implications for improving BHCs' group-level ICS along with referring to international standards and overseas cases. As a result of assessing the current status of a group-level ICS based on the reports of each BHC's self-inspection, it is found that BHCs have been passive in their internal control activities at a group level, despite expanding their group-level business activities. In particular, the board of directors and senior management of a BHC are not responsible for the subsidiaries' internal control related to group-level business activities. There is also a lack of awareness of the three-lines defense at a group level. Information sharing and communication at a group level are insufficient. Human resources for group-level internal control activities are not adequately supported. There is a lack of consistency in BHCs' group-level internal control standards. In result, it seems that the firm-level internal control of each subsidiariest has been prioritized rather than the group-level internal control within a BHC and its subsidiaries. In order to establish a group-level ICS for BHCs, it is necessary to remedy the above problems. It is also important to promote practical operation of a group-level ICS and conformity to international standards. However, it may take long time to improve a group-level ICS in legal, so it is desirable for BHCs to voluntarily improve their own group-level ICS first.