Research On The Governance Of State-owned Commercial Banks' Repeated Investigations And Repeated Offenses

Repeated inspection of recidivism refers to the phenomenon of violations that are found frequently in various kinds of inspections,but still occur or even prohibited repeatedly after correction.It has the characteristics of "repeated inspection,repeated rectification and repeated occurrence".The problem of repeated offences is mostly endogenous risk within the controllable scope,and in most cases there is no inevitable connection between risk loss and income generation.The reasons for the repeated occurrence and repeated prohibition of irregularities in commercial banks involve many aspects.In addition to the weak sense of responsibility of employees,weak awareness of compliance risks,low operational skills and personal moral hazards,there are more factors related to management,supervision,inadequate assessment measures and defects in the system and process system.This paper starts from the definition of the concept,according to the actual situation of ICBC’s repeated investigation and treatment,combined with the author’s in-house investigation,based on the relevant data of ICBC Shanghai P sub-branch,focuses on the analysis of commercial bank’s repeated investigation and treatment from two dimensions of business operation and system inspection.Business operation category is repeatedly investigated and committed,which refers to the problems found in system monitoring.It is mainly the risk that the business operation risk management system automatically captures through the risk module.System inspection refers to the problems found in manual inspection.Mainly for external institutions such as CBRC or banks themselves to develop inspection plans and inspection focuses,check the integrity,compliance and accuracy of business in accordance with the system provisions,and strengthen risk management and tracking implementation.Firstly,the third chapter analyzes the situation of repeated violations of business operations.After governance,the repeated violations of business operations have been improved to some extent,but they still happen from time to time.The main problems are(1)high frequency.Due to inadequate closed-loop management,rapid change of system update,and lagging management process,there were 180 risk events in 2016,which occurred once every two days on average.Even after governance,there were 83 internal risk events in 2018,with a high probability of repeated violations.(2)Volatility.Due to the reasons such as new employees working independently and post changes,the number of repeatedly found problems is on the rise and on the decline from the first quarter to the second quarter,and the number of risk events is relatively large from the third quarter.(3)Differences.P sub-branch is a first level sub branch with more than 400 employees.At present,it has 18 outlets under its jurisdiction.There are differences in repeated violations in 18 second level institutions.Some outlets have a small probability of risk events,while some remain high,and repeated violations are relatively serious.Secondly,the fourth chapter analyzes the situation of repeated system inspection.The main problems are(1)concentration.From the perspective of internal inspection,the problems are mainly focused on "double recording" of financial management and account opening management.From the perspective of external inspection,in recent years,the problems and penalties found in the on-site inspection of ICBC by Shanghai Banking and insurance regulatory bureau are mainly concentrated in the fields of credit and personal financial management;there are frequent problems in the "three checks" of loans and "double records" of financial management.(2)Externality.Some of the bank’s risks come from external environment and other factors,especially the non-performing assets in credit business.To a large extent,the adjustment of administrative environment and industrial structure leads to the poor operation of enterprises and the decline of repayment ability.(3)Hazard.The biggest difference between system inspection and operation inspection is the huge risk exposure.In addition to causing customer disputes,the more serious result is the criminal risk of employees and bank reputation risk.Many problems involve a large amount of money,which has a direct impact on regulatory indicators and is more likely to touch criminal charges.On this basis,the fifth chapter takes Smith’s policy implementation process model as the theoretical framework,and analyzes suggestions from four dimensions:idealized policy,implementing agency,target group and environmental factors.With reference to other application experience,combined with the actual situation of ICBC,the management of repeated violations is idealized in terms of strengthening closed-loop management,improving the effectiveness of policies.Executing agency:timely updating the system,promoting paperless management and strengthen three-level inspection,implement hierarchical assessment.Target group:implementing teachers and apprentices,enhancing compliance awareness and strengthen personnel screening,behavior management.In the aspect of environmental factors,we should implement risk matching and transform the functions.Hope that through these measures,to solve the problem of repeated investigation and treatment of repeated offenders has some help.