| Liquidity risk is a concomitant of commercial banking and is one of the most important,deadly and insidious risks facing commercial banks.In the course of commercial banks' operations,the maturity mismatch of short borrowing and long lending makes commercial banks naturally susceptible to liquidity risk.With the intensification of downward macroeconomic pressure in China and the deepening of painful reforms in the financial market as a whole,the potential risk of liquidity risk for small and medium-sized banks has been accumulating.In particular,since 2019,liquidity risk events of small and medium-sized banks have been frequent.The receivership and bankruptcy of Baoshang Bank,the strategic restructuring of Jinzhou Bank and the concentrated run-off events of Yingkou Coastal Bank and Henan Yichuan Rural Commercial Bank exposed the prominent problems in liquidity risk management of small and medium-sized banks.Following the outbreak of these risk events,the banking industry experienced significant volatility in liquidity and soaring interbank borrowing costs.Therefore,the importance of the sound operation and liquidity risk warning and control of small and medium-sized banks to the real economy cannot be overstated.Liquidity risk of small and medium-sized banks refers to the risk that small and medium-sized banks are unable to obtain sufficient funds at a reasonable cost and in a timely manner to pay debts as they fall due,meet other payment obligations and meet other funding requirements for normal business operations.Judging from domestic and international cases,liquidity risk occurs once a small or medium-sized bank is unable to repay a certain scale of debts as they fall due,which is the immediate trigger for a small or medium-sized bank to get into trouble,while what is really fatal for a small or medium-sized bank is a serious liquidity break.There are many triggering factors,which may be due to simple liquidity risk itself or to the contagion mechanism of credit risk and operational risk.As far as the liquidity risk itself of small and medium-sized banks in China is concerned,the current ones are mainly manifested in the following three aspects:Firstly,the liquidity risk of small and medium-sized banks is aggravated by the compression of interbank business and the return of assets to the table.Secondly,the new capital management regulations and series of documents have amplified the maturity mismatch risk of small and medium-sized banks.Third,financial innovation and interest rate market initiatives exacerbated the risk of bank deposit loss.In the process of liquidity risk regulation and control,a double dilemma of market failure and government failure has emerged.Therefore,the use of legal means to regulate and identify and prevent and resolve the liquidity risks faced by small and medium-sized banks is not only about the systemic safety of the financial system,but also about the operation of the country's overall economy.In the legal system for regulating the liquidity risk of small and medium-sized banks,provisions have been made in the Commercial Bank Law,the Banking Supervision and Administration Law and the Measures for Liquidity Risk Management of Commercial Banks,etc.However,with the changes in the situation of the financial industry in recent years,the existing legal system is still flawed in the following aspects: firstly,the regulatory concept is lagging behind,secondly,the legal status of regulation is low,thirdly,the regulatory approach is rigid and fourthly,the The regulatory system is not perfect,etc.The reasons for this are not only the reasons of the small and medium-sized banks themselves but also the macroeconomic factors,as well as the factors of regulatory indicators,regulatory methods and regulatory systems.In particular,small and medium-sized banks have problems that are difficult to overcome in their own development.Small and medium-sized banks have a weak ability to absorb deposits,rely heavily on interbank financing and are under greater pressure for liquidity control.According to statistics,some urban commercial banks derive 49.7% of their liabilities from interbank,with a seriously low proportion of core deposits,a high leverage ratio,a serious imbalance on the liability side and greater liquidity risk.Moreover,some shareholders of small and medium-sized banks disregarded national regulations and related transactions or even irregularly diverted funds from small and medium-sized banks.At the same time,the banking industry is facing unprecedented changes,with the rapid development and expansion of internet finance and financial technology breaking the monopoly position of the original banks in the financial market.The innovation and popularity of financial technology has led to huge changes in the channels,means and content of banking services,and the new competitive market dynamics have made it necessary for the original banking and financial institutions to face competition from fellow banks and new non-bank market participants.All these factors have made the issue of liquidity risk supervision for small and medium-sized banks increasingly complex and important.Based on the comparative analysis of liquidity indicators and data of many small and medium-sized banks in China,it is proposed that China should learn from the relevant documents of the Basel Committee and other countries,and set up the appropriate tiered liquidity risk supervision indicators in conjunction with China's own reality.In the process of building a legal regulatory system for liquidity risk,the cooperation of various parties is required.At the macro level,a stable monetary policy is needed to address the underlying causes of excessive "leveraging" and high interest rates.At the micro level,banks should return to their roots,serve the real world,focus on their main business,and do a good job in credit-based credit operations to avoid excessive innovation that could lead to instability.In terms of the philosophy of legal regulation of liquidity risk for small and medium-sized banks the concept of fit-for-purpose regulation should be implemented,i.e.to determine the appropriate regulatory rules and supervisory behaviour according to the risk characteristics and systemic importance of the bank.The emergence of China's legal system of liquidity regulation from scratch is a process of imitation and innovation of the system in a late-developing country,and it is also a process of persistence and effort to maintain financial security and guard the bottom line of no systemic risk.The current liquidity regulatory system in China is mainly based on low-level regulations and normative documents,which have too many policy bases and insufficient legal bases,and cannot adapt to the deep integration of the current financial market.In this regard,from the perspective of further reforming the current regulatory system and making it more responsive to the deeper integration of China's financial markets and the need for comprehensive business reform,it is important to formulate and amend relevant financial laws to provide for uniform rules and indicators for liquidity regulation with adaptability. |
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