First of all, the questions raised
Affected by the slowdown in economic growth, the non-performing loan ratio of commercial banks is still rising, approaching 2%. The "scissors gap" between non-performing loans and overdue loans is still widening, and potentially risky loans continue to grow. At the same time, the loss of rapid disposal of non-performing loans has been increasing, and the recovery rate of disposal has been hitting a new low, especially the huge loss of bulk transfer and disposal of non-performing loans, which has brought great burden to the bank's operating efficiency and financial costs. Simply containing non-performing loans only delays or delays the risk exposure, slows down the current or short-term increase of non-performing loans, treats the symptoms rather than the root cause, does not break away from the external environment that produces non-performing loans, eliminates potential risks, and does not fundamentally solve the internal factors that produce non-performing loans.
Macroeconomic fundamentals determine the basic state of the quality of bank credit assets, and the non-performing loan ratio of commercial banks is a reflection of macroeconomic operation to a great extent. Although the problems in macroeconomic operation will not be immediately reflected in the quality of bank credit assets, when the economic growth is in a downward or weak trend for a long time, or the problems in macroeconomic operation cannot be fundamentally reversed in a short time, it will eventually have a substantial impact on the quality of bank credit assets.
According to the current loan management regulations of commercial banks, interest is generally settled quarterly, and the financing period is mostly 6~ 12 months or 1 year. Only when the loan is in arrears or cannot be repaid for more than 90 days after maturity will the risk be exposed and determined as a non-performing loan. For some problem loans, in order to preserve assets, banks usually take refinancing, extension, signing supplementary agreements to adjust the original contract elements and other ways to expose loan risks. In addition, many potential risky loans will only be exposed after being influenced or triggered by many other factors. Therefore, there is generally a long or short transition period from loan issuance to non-performing. In the initial stage of economic slowdown, credit risk exposure will be relatively slow. However, when economic growth continues to be weak, not only new credit risks will be exposed quickly, but some slowly released credit risks will deteriorate again, and the accumulated potential risks will be transformed into real risks, thus significantly accelerating the exposure of bank credit risks, and the non-performing loan ratio will rise rapidly, even exceeding the growth rate of bank operating income and net profit continuously, and even causing liquidity risks in serious cases.
From the analysis of the current situation, the basic factors of economic slowdown have not changed substantially, various uncertain factors in macroeconomic operation have not been eliminated, and some deep-seated problems continue to accumulate, which continues to affect the operating environment of bank credit. For example, some enterprises with low technology content, backward technology, lack of competitiveness of products and difficulties in production and operation are increasing. Some industries with serious overcapacity have heavy assets and high liabilities, and it is difficult to adjust and transform, and the situation of declining benefits may exist for a long time. Some traditional business models and physical shopping malls have shrunk with the changes in emerging market formats. In particular, some small and micro enterprises have great market demand and can survive and develop during the economic period. However, when the economy fluctuates, they will be the first to be hit, resulting in difficulties in capital turnover and broken capital chains. And this situation will be transmitted to its upstream and downstream fields, causing more and more enterprises to have difficulties in production and operation, and the cash flow is insufficient or broken, leading to the continuous spread of credit risk in customers, industries, regions and other dimensions, seriously affecting the stability of bank credit assets quality. In addition, risks such as counterparty risk, cooperative institution risk, private lending and bank financing are cross-infected and spread, and a large number of external risks flock to banks across industries and borders, which has become a new source of credit risk, further increasing the difficulty and complexity of bank credit risk management and control, and the upward trend of non-performing loans will be difficult to curb.
Another problem is that the bank's credit operation has not been substantially adjusted and improved with the change of the external economic environment, and the risk of new financing has not been effectively controlled. With the economic downturn, the investment demand for stimulating economic growth has been greatly reduced, and the manufacturing industry is still in the process of deep de-capacity. Consumption can only increase gradually, while exports face many uncertainties, and it is difficult to have a big rebound in the short term. In this context, enterprises with normal production and operation generally repay bank loans by issuing short-term financing bonds, short-term financing bonds, medium-term financing bonds and various corporate bonds to reduce financing costs. This means that normal business enterprises not only reduce the demand for bank loans, but also repay the original loans, directly reducing the loan balance. In order to ensure that the total amount of credit does not decrease and the growth rate does not decrease, banks should not only make up for the loans repaid by enterprises by issuing bonds, but also look for new enterprises with financing needs, and most of these enterprises are relatively difficult to operate and have great potential risks. In other words, if we continue to issue loans in an inertial and traditional way and do not make adjustments, the risk may be even greater.
The above analysis shows that the current bank credit risk problem is mainly affected by external economic environment and other factors. However, as far as the bank's own reflection is concerned, it must not end there, or at most, it is considered that some branches or related personnel are not in place and their business operations are not in place, but should be deeply analyzed from their own risk management. Some of these risks seem to be caused by external factors, some are accidental and sudden, or are individual problems of some enterprises or certain types of enterprises, some branches and a certain region, but the essence is that some banks ignore the management of credit strategic risks.
At present, the distribution of new non-performing loans among commercial banks is uneven, and the rate of non-performing loans varies greatly. In the same region and the same external environment, some banks have low NPL ratio and some banks have high NPL ratio; Even in the same area, different branches of the same bank are unbalanced, some branches have high non-performing loan ratio, and some branches have low non-performing loan ratio. The main reason for the difference in non-performing loan ratio between these banks and their branches is the difference in credit structure. Different credit asset distribution structures have different risks. If the proportion of credit assets in some high-risk areas or departments is too large, the corresponding non-performing loan ratio will be higher. For example, regional risks in Wenzhou and Erdos, risks in industries with serious overcapacity such as steel and electrolytic aluminum, commodity financing risks and hidden factoring risks in bank credit products, and mutual insurance, joint guarantee and joint guarantee risks in loan guarantee methods. Because behind the credit assets are credit customers, customer default is manifested in the deterioration of credit assets. Therefore, the difference of non-performing loans between banks is actually the difference of credit customer structure. The greater the difference of credit customer structure, the greater the difference of credit asset quality; Moreover, this difference is not formed in a short time, nor can one or two businesses adjust it.
Therefore, evaluating the quality of credit assets of commercial banks can not only look at the overdue loan ratio and non-performing loan ratio, they only reflect the quality of credit assets in the current period, but not the long-term credit quality. At present, the low rate of overdue loans and non-performing loans does not mean that its future risks are controllable and the quality of credit assets is good. In fact, only looking at the current non-performing rate itself is not comprehensive, because it contains the factors of write-off and disposal. To judge the quality and stability of bank credit assets, we must deeply analyze the credit structure, including the customer distribution structure, industry distribution structure, regional distribution structure and product distribution structure of credit assets, so as to discover the true quality and potential risks of bank credit assets, judge the credit risk management of a commercial bank more accurately, and judge the future loan deterioration pressure in combination with the external economic environment.
Further analysis will find that the difference of inter-bank credit structure is essentially the difference of credit strategy and strategic risk management. Whether it is the rational prevention and control of strategic risks or the decision-making judgment of risk preference, the strategic risks and structural risks of credit must be prevented in advance, and it is difficult to control them effectively once they occur. This is also a prominent problem in the current bank credit risk management. Although the non-performing loan ratio of some banks has increased in the current period, from the long-term factors such as credit strategic risk, the risk is still controllable; Although the NPL ratio of some banks in the current period is not high, from the perspective of long-term credit strategic risks and other factors, the potential risks are very large, and some of them are already very serious, which is likely to lead to regional or even systemic financial risks.
Two. Strengthen the strategic risk management of credit
Although it is difficult to solve the problem of rising non-performing loans of commercial banks in the short term, it does not mean that banks can do nothing about it and can only passively wait for changes in the external economic environment. Commercial banks should seize the opportunity of the current economic slowdown with a positive attitude, accelerate the transformation of their own credit management, deepen reform, improve the mechanism, treat both the symptoms and the root causes, and effectively solve the deep-seated problems that restrict and affect credit risk management; We should not only prevent and reduce the current credit risk, but also strengthen and improve the management of long-term credit risk, adjust and clarify the credit strategy, prevent and control the credit strategic risk, so as to make the credit business have a stable and long-term development trend.
The so-called credit strategic risk refers to the large-scale and persistent credit risk that may appear in the future, which will have a great impact on commercial banks and even lead to bank bankruptcy. Credit strategic risk management is to determine the credit strategic objectives and strategic layout according to the external environment and its own risk preference, so as to prevent and control the strategic credit risks that may be brought about by future macroeconomic fluctuations.
From the perspective of credit strategy, it is not difficult to find that the quality of each bank's credit assets is closely related to its credit strategy and risk management. One of the important lessons is that some banks lack a clear credit strategy, a reasonable credit layout and requirements for prevention and control of credit risks in advance, and do whatever they want, only to complete the current business indicators, and put too many loans into some areas with higher returns, forming a large number of credit assets with higher potential risks. Once the market environment changes, it will fall into the dilemma of sustained risk and large-scale exposure. Therefore, in order to treat both the symptoms and root causes of bank non-performing loans and strictly guard against strategic credit risks, commercial banks should formulate credit strategic risk management plans based on prudent risk preferences, determine the total amount of credit and structural objectives, and make long-term and adequate preparations for risk losses.
The key to the strategic risk management of bank credit is to clearly stipulate that the total amount of credit should be moderately increased in a certain period of time to ensure that the total amount of risk can be controlled. That is to say, the total risk is matched with the risk preparation and financial tolerance, which is the full embodiment of the steady operation of banks and the inherent requirement of risk management. If the credit business develops too fast in a short time, the quality of risk management will be affected, and the potential risks will accumulate faster accordingly. In particular, the current economic transformation and structural adjustment are not in place, and some new markets have not yet formed actual credit demand. If the total amount of new credit of banks is too much, including loans to new customers and incremental loans to old customers, they will continue to invest in traditional manufacturing, wholesale and retail, and even some areas with backward technology, serious environmental pollution, high resource consumption and serious overcapacity. Because in these areas, the operating efficiency of enterprises is declining, the cost is rising, and the capital chain is tightening, there will be greater financing demand. If the loan is put in too much and too fast, the risk exposure pressure will increase, which will easily lead to new non-performing loans. Therefore, reasonable and moderate credit total control should be the basic goal of credit strategic risk management.
Second, we should do our duty, keep the bottom line of credit strategic risk unshakable, and achieve the credit strategic goal unshakable. Of course, there is a cost to keep the risk bottom line, and we should take into account the relationship between short-term benefits and long-term risks, market opportunities and risk prevention and control as much as possible. Only in this way can we avoid the deterioration of large-scale or plate-type credit assets during macroeconomic fluctuations; Only in this way can we basically ensure the stability of bank credit assets quality, the matching of credit assets distribution, the controllability of customer risks and the sustainability of comprehensive income.
The third is to determine the future credit structure target within the total credit amount. The prevention and control of concentration risk of credit structure and its constituent elements is the main problem to be solved in credit strategic risk management. On the one hand, it is necessary to strictly control the degree of new loans invested in the structure to avoid structural or concentration risks. In particular, the current investment growth rate has dropped below 10%, and economic growth has gradually shifted from investment-driven to investment-driven and consumption-driven. Banks should also adjust their credit strategies accordingly and increase the proportion of consumer credit departments. On the other hand, it is necessary to comprehensively analyze the structure and concentration of customers, industries, regions and products of stock credit, improve the prevention and control measures of potential risks in time, and constantly optimize and adjust.
From the customer dimension, the quality structure of credit customers is the basis of the quality foundation of bank credit assets. Good customer quality and excellent structure show that the quality of long-term credit assets of banks has a stable foundation. The choice of customers is mainly determined by the risk preference of banks, and different risk preferences will have different customer choices. The key is the ability of banks to identify risks. Without identifying substantive risks, it is difficult to choose the right customers. When implementing the credit customer strategy, banks should make full use of the advantages of data precipitation and technical processing, realize risk identification and accurate customer selection through big data, effectively predict and control customer risks, and increase the proportion of outstanding customers, which will become the focus of future innovation and market competition of banks. At the same time, it is necessary to speed up the withdrawal of existing customers with potential risk factors, especially those with traditional institutional mechanisms, lack of core competitiveness and excessive financing. Small and micro enterprise customers are special. We should not only evaluate their real risks according to commercial principles, but also match their total financing with their own risk management ability and risk tolerance. We should also cultivate customers from a strategic perspective, and we should not overemphasize the risk bottom line and give up small and micro enterprise customers.
From the perspective of industry, the distribution of credit industry has a great influence on the stability of credit asset quality. Different industries have different development cycles and different risk performances, so the layout of industry sectors should conform to economic development and trends. At present, it is necessary to invest credit resources in industries with relatively low long-term financing risks, such as emerging industries and weak cycle industries, and increase their structural proportion; For industries with serious overcapacity, serious impact on environmental safety and seriously backward technology, it is necessary to reduce the total amount of credit and reduce the proportion of structure as soon as possible; For industries with strong periodicity, it is necessary to strictly control and avoid excessive proportion. We should also 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 a science, it will turn into low-profit industries and the risks will rise sharply. If the financing of such industries accounts for a relatively high proportion, the pressure on the deterioration of credit assets in the future will be relatively large, and it needs to be quickly adjusted and reduced.
From the regional dimension, in the credit strategic risk management, we should also pay attention to the proportional relationship between the total regional credit and the regional GDP. If the ratio is too large, the potential credit risk will also increase. At present, due to the decline of investment efficiency and profit rate of enterprises, every percentage point of GDP growth needs more investment than in the past, which makes the ratio of total credit growth rate to GDP rise rapidly in some fields and risks are accumulating rapidly. The bank's credit supply to various regions should be treated differently according to different situations. For areas that have completed or will complete industrialization, urbanization and smooth transformation and upgrading in the process of economic growth, as well as areas with low levels of industrialization and urbanization and rich demographic dividends, they can continue to maintain moderate credit growth. However, areas with single industrial structure and little potential for industrialization and urbanization may become depressions for economic growth, and credit resources should be carefully controlled. If too much credit resources are invested in areas with low marginal efficiency, the future regional credit risk will increase.
From the product dimension, credit product structure is also an important factor affecting asset quality. Low-risk wealth management products can keep the quality of credit assets stable, while high-risk wealth management products should be cautious despite their high returns, and the proportion should not be too large. Especially in the period of economic slowdown or downturn, some traditional credit products with higher returns not only increase risks, but also reduce market demand, and the total amount should be steadily reduced. At the same time, it is necessary to launch new financing products in time according to market changes, especially actively innovate, open up the consumer loan market, launch some consumer financing products with controllable risks and suitable for market demand, and increase the proportion of consumer financing products.
Three, the necessary conditions for the implementation of credit strategic risk management
Determining the goal of credit strategic risk management does not mean achieving the goal, but also needs supporting environment and conditions, including managing credit strategic risk with new ideas, new mechanisms and new requirements. There should be a plan for preventing and controlling large-scale credit risks and a corresponding policy system.
(1) Improve the credit risk management mechanism and clarify the risk management responsibilities.
In order to achieve the goal of credit strategic risk management, we must improve the operating mechanism of credit risk management, not only to prevent and control the current credit risk, but also to effectively prevent and control the strategic risk and ensure the high efficiency of customer service. It is necessary not only to solve the efficiency problems such as multi-level management and long operation process in current credit risk management, but also to solve the mechanism problem that the checks and balances between the front, middle and back offices are alienated into unclear risk management responsibilities.
It must be clear that credit risk is mainly the default risk of customers, so credit risk management must also take customers as the center, clarify the post responsibilities of departments and employees, implement risk responsibilities, and whoever manages customers will bear risk responsibilities. In the whole credit risk management, the front-end marketing department is mainly responsible for marketing customers, maintaining customer relationships, managing customers in the whole process and taking the main responsibility for customer risks; The risk review department of China and Taiwan conducts independent review, mainly to assist the marketing department in checking the identification and prevention of customer risks and assume corresponding responsibilities; The main duties of the back-office monitoring department are to unify customers' viewpoints, comprehensively monitor customers' risks, promptly remind the marketing department of the customer risk trends that should be paid attention to before lending and after lending, and help control customers' risks. Through the cooperation of the three departments, a risk management operation mechanism with the marketing department as the main body, the risk review department and the risk monitoring department as the auxiliary, mutual premise, mutual restriction and unified responsibility and rights is formed. Only by perfecting the responsibility mechanism of each link of credit business and clarifying their respective responsibilities can we effectively ensure the smooth implementation of credit strategic risk management, ensure that the customers, industries and regions that enter can enter efficiently, and the customers, industries and regions that exit can exit strategically.
Under the current banking management system, which is mainly based on regional plate management and supplemented by business line management, it must be made clear that the basic responsibility of all credit business departments is to provide decision-making reference and relevant policies and products for risk decision makers at all levels, and mainly undertake the responsibilities of insufficient risk disclosure, risk prevention or mitigation and insufficient policy requirements. Whether to do the financing business of customers must be decided by the person in charge 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.
On the basis of clarifying the responsibility mechanism, we should simultaneously improve the matching mechanism of responsibility and rights. If the marketing department bears the main responsibility for customer risk, it must be fully authorized. Not only have the right to conduct due diligence and daily post-loan management on customers' credit and debt business, but also strictly control customers' real credit demand, real risk mitigation and real loan use. They should also be responsible for credit business policy guidance, customer or business access, loan pricing, product innovation startup, etc., take the lead in coordinating the overall allocation and scheduling of resources in various product departments and regions, and conduct cross-departmental extended marketing management on personal business and risks related to corporate customers.
In order to improve the efficiency and quality of customer service, enhance market competitiveness, and avoid the risk of credit customers' access choice and credit investment deviating from the branch's credit strategic objectives, it is necessary to relatively concentrate marketing resources, adjust marketing methods and strategies, and unify customer selection standards, service standards, risk identification standards and business operation standards for sectors and emerging business areas that have a great impact on credit strategy, as well as businesses with strong personalized demand, complex product structure and difficult risk prevention and control. Apart from micro and retail credit business, grass-roots institutions mainly provide customers with necessary financial services and assist superior banks to do a good job in customer marketing, so as to provide customers with all-round and integrated financial services more completely, professionally and efficiently, and completely change the problem that grass-roots institutions actually decide credit investment and credit structure according to local market demand, and even cause reverse adjustment.
(b) Innovative credit risk management.
To achieve the goal of credit strategic risk management, we should not only improve the responsibility mechanism, but also improve the innovation mechanism, and put limited resources into credit strategic risk management through innovation. In 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. From the concept, layout, management, methods and products, credit strategic risk management itself is full of innovation. When all innovations come together, a huge innovation dividend can be formed, which is manifested in the strategic risk management of credit, that is, the quality of credit assets has remained stable and excellent for a long time, the unilateral deterioration of loans has been continuously reduced, the potential credit risks have been effectively resolved, the credit structure has been continuously optimized, and the income of credit assets has been further improved.
First, standardize some credit business operations. That is, the standardization of credit business such as consumer credit and micro-credit with controllable risks and great market potential is the focus of credit strategic risk management innovation. Because this kind of business volume is wide and the operation is time-consuming and laborious, it is necessary to adjust and transform the current credit business operation mode. According to the different risk characteristics of this kind of business, prevention and control measures and operational procedures are set up, and advanced technology is used to innovate business handling methods to improve service efficiency and reduce risk management costs. Specifically, with the help of the Internet, big data and other technologies, the "data+model" approach, networking, automation and other means, the combination of online and offline, the automatic screening of models and parameters or the combination with offline audit, risk prevention and control measures are taken to realize the independent or semi-independent handling of customer financing business. This can not only facilitate customers to handle financing business without time and geographical restrictions, but also ease a large number of business operations of grass-roots institutions, fully embodying the principle of small amount, controllable risk and short business process.
The second is the portfolio risk management of innovative financing business. Because the traditional administrative management system has formed a credit business operation and risk management model based on a single business and a single variety, and the corresponding policy system, banks are too departmental and product-oriented in specific credit business operations. Not only is the customer's wealth management demand artificially cut, but some wealth management products of the bank are also cut, making it difficult to cross-sell synchronously, and the information and risk prevention and control of the same customer are also separated and cannot be enjoyed. In fact, marketing a financial product to customers is not only the need of business development, but also an effective way to understand and master customer information and an important measure to prevent and control risks. Credit risk management should be embedded in business development, and business development and risk management cannot be completely separated. Banks have achieved effective risk management in the process of providing financial services to customers. Therefore, it is urgent to reform the current management system, change the single business management mode, and implement the customer strategy on the basis of legal compliance. Accelerate the overall marketing and comprehensive financial services of commercial banks and investment banks, self-operated and agency, on-balance sheet and off-balance-sheet, domestic and foreign currency, domestic and overseas financing businesses, and innovate more new financing products, schemes and models. At the same time, we can understand customer information more completely, strengthen portfolio risk management, and prevent and control customer risk from credit strategy.
The third is to expand new financing areas and prevent and control new risks. Facing the complicated economic environment and the change of market financing demand, we can't find a suitable credit market according to the traditional inertia thinking. The strong demand in the past no longer exists. The general over-financing and a large number of risk exposures mask the small demand in the market, and some of the demands we see are mostly high-risk, low-yield and difficult-to-manage businesses. Therefore, we should look at the market and market segments with innovative ideas and turn negative factors into positive ones, so that we will find a lot of market opportunities and financing needs. The key is to grasp the market characteristics in the new period from the perspective of credit strategic risk management, identify risks and guard against risks with the help of advanced risk management technologies and methods, so as to adapt to the new market environment, new industrial formats, new business models and new risk manifestations. For example, the service industries such as culture, tourism, health, and old-age care, which have an important impact on the credit strategic structure, and other light asset areas have great financing demand potential, and the financing demand for new projects under PPP mode is also great. The key is how to do it and how to prevent and control risks, all of which require innovation and wisdom. For another example, banks are now trying to deal with non-performing assets and problem loans. In fact, changing their thinking and packaging them as a resource into a new product will open up a new market.
(C) Improve employee behavior risk management
Employee behavior risk management is an important foundation of bank's overall risk management, and also a necessary condition of credit strategic risk management, which has a decisive influence on the realization of credit strategic objectives. If employee behavior risk is well managed, credit risk will be greatly reduced. It is difficult to put credit risk management in place only by focusing on business risk management but not on employee behavior risk management. In fact, credit strategic risk management is the risk management of the whole credit business, not just the risk prevention of a specific debt business, so it needs the continuous due diligence of all employees.
Employee behavior risk management is to make employees abide by laws and regulations and perform their duties in the whole process of credit business operation, and it is also the core of employee behavior risk management. From the analysis of the current cases of non-performing loans in banks, although there are various internal and external factors, it is undeniable that a considerable part of them are caused by behavioral risk factors such as employees' non-compliance and lack of due diligence, which makes some risks that could have been effectively prevented and controlled inevitable. Compliance and due diligence are different things. Compliance is what can and cannot be done. What should be done must be done properly, and what should not be done must be resolutely not done. This is a red line that cannot be crossed. Compared with due diligence, compliance, especially superficial compliance, is easier to achieve, but doing all the prescribed actions does not necessarily mean due diligence. In essence, compliance can prevent and control operational risks, but it cannot completely prevent and control credit risks. Although many credit risks are caused 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 credit substantive risks.
To strengthen the risk management of employees' behavior, we must first train employees in professional ethics, respect the professional ethics and code of conduct of bank employees, and respect risk management. Be clear about your professional code of conduct, abide by high standards of professional ethics, consciously perform your duties, and be diligent and conscientious. This is also the basic content of employee behavior risk management. Secondly, it is necessary to train employees in business skills, comprehensively promote the qualification management system for credit practitioners, and regard professional qualifications as the basic requirements for engaging in credit work and the rigid constraints for handling specific businesses. Let the right people do the right things, and those who do not have the ability and quality of risk management will be resolutely adjusted. Third, it is necessary to strengthen the business skills training and post assessment of risk management professionals and branch heads, so that the quantity and quality of risk management professionals and branch heads can match the requirements of credit business development. Only when professional risk managers and institutional experts are formed, and the gradient construction of risk management professionals and branch leaders is put in place, can we have stable credit asset quality, which is an important guarantee for realizing credit strategic risk management.
(D) The regulatory authorities should pay attention to the strategic risks of bank credit.
At present, the regulatory authorities should not only adjust the regulatory policy requirements in the economic upswing period to meet the regulatory policy requirements under the condition of slowing economic growth, but also strengthen the monitoring of regional financial risks in the process of preventing and controlling systemic financial risks, so as to avoid local regional financial risks triggering a wider range of systemic financial risks. We should not only pay attention to the matching between the total amount and structure of social financing in various regions and their economic development, but also analyze whether there are serious over-financing risks and potential regional financial risks. We should also pay attention to the supervision of credit strategic risks of banking financial institutions, analyze the total amount and distribution structure of their credit assets, and do a good job of resolving and preventing potential risks that may lead to large-scale risk factors as soon as possible.
In order to conduct due diligence, the regulatory authorities must effectively monitor the credit strategic risks of the regulated objects, supervise the potential risks in the development of credit business in real time, and take regulatory measures immediately when any abnormal situation is found, instead of prompting the regulatory risks after all risks are exposed. Without strict follow-up of specific regulatory inspections, regulatory penalties and other regulatory deterrence, it is difficult to really play a regulatory role.
It should be emphasized that speed limit is a very important traffic rule and the most basic measure to ensure road traffic safety. Credit risk exposure, like traffic accidents, is mostly related to speed. From the analysis of the causes of the formation of non-performing loans in banks at present, a very important reason is that whether a certain credit business grows too fast or the whole credit business grows too fast, or the financing in a certain field grows too fast, its non-performing loans are exposed too much. The rapid development of credit business in the short term is not only unsustainable, but also has great potential risks, which may lead to a rapid rise in non-performing loans. In the same economic environment, the development of credit business should have a reasonable degree. If it is exceeded, there must be a special reason, probably a risk, at least a potential risk. For example, some institutions or regions with high risks such as steel trade financing risk, financing guarantee (circle) chain risk and private lending have experienced a period of rapid development of credit business, and the quality indicators such as non-performing loan ratio and overdue loan ratio at that time were still very good. Therefore, the financial supervision department should supervise and limit the development speed of credit business of banking financial institutions. If the credit business of a bank or its branches develops too fast, including a certain credit product, the regulatory authorities should conduct compliance inspection to see if there are any indiscretions or irregularities, instead of simply giving some risk tips.