德意志銀行中國銀行業報告：金融去槓桿——政策緊縮方向不變，但保持底線 金穩委成立是去槓桿最重要一步

德意志銀行中國銀行業報告：金融去槓桿——政策緊縮方向不變，但保持底線

報告摘要和基本結論

近期的監管和貨幣政策措施的總結

A summary of recent regulations and monetary policy measures

The pace of releasing new regulations has accelerated notably. Three rules

were unveiled by CBRC over the weekend. The direction is clearly on the

tightening side: cracking down on shadow banking and reducing wholesale

funding. On the other hand, to hold the bottom line of no systemic risks, the

PBOC has increased liquidity injections (by Rmb1.6tr in 2017, equivalent to

110bps RRR cuts) and announced a few pre-emptive measures, e.g. a

temporary RRR cut and relaxation in the automated pledging financing facility.

As such, we expect financial deleveraging to continue but the process is likely

to be orderly, given the low risk of an uncontrollable 「liquidity event」.

更嚴格的規定：堵塞漏洞，但更協調

Tighter regulations: closing loopholes, but being more coordinated

Since the first meeting of the Financial Stability and Development Committee

on 8 Nov 2017–the 「super-regulator」 coordinating financial regulators–the

pace of releasing new regulations has accelerated notably (Fig. 2). This

weekend, the CBRC released 3 regulations targeting entrusted loans, banks』

concentration risks and shareholding management. These regulations, in

general, target a crack down on shadow banking by closing loopholes and

reducing regulatory arbitrage. What makes this round of tightening different

from the past is that with the new committee leading, the regulations are more

coordinated and most have considerable grace periods. Starting with The

Asset Management Guideline (note), an overall guideline, the regulations are

targeting particular sub-markets/sectors one-by-one and step-by-step.

貨幣政策：利率較高但流動性充裕，採取先發制人的措施

Monetary policy: higher rates but ample liquidity with pre-emptive measures

PBOC has hiked OMO rates 25bps in 2017; we expect another 20-45bps in

2018, but liquidity vol. should stay ample, as we believe that, while tightening,

PBOC also needs to prevent systemic risks. Indeed, in 2017, PBOC injected

Rmb1.6tr liquidity mainly via MLF and PSL, equivalent in size to 100bps RRR

cut or sufficient to fund 10% of banking asset expansion. Recent relaxation on

automated pledged financing suggests smaller banks in temporary liquidity

troubles should have access to bigger-amt funding provided by PBOC. Also

temporary RRR cut during Chinese New Year may release Rmb1.5-2.0tr

liquidity for 1 mo., which should smooth liquidity tightness by then. We expect

relatively remote likelihood of bank run in wholesale funding market.

對銀行系統和個別銀行的影響：短期銀行資產增速放慢

Implications for the system and individual banks

Longer term, we see most deleveraging measures as necessary to strengthen

China』s financial stability, generating net positive to financial system and real

economy. Near term, for financial system, we expect slower banking asset

growth, modest yield curve steepening & lower actual risk-free rate. For real

economy, we forecast moderate credit growth with shrinking shadow banking

and hence, slower economic growth. Yet, it should come with benefit of

slower build-up in leverage & better transparency. Retail banks (big

4/CMB/CRCB) should benefit from higher rates & yield curve steepening due to

solid deposit franchises. Other smaller banks will experience ongoing funding

and capital pressure. Our order remains BOC/ABC/CCB/ICBC/CRCB/BoCom.

Catalysts: better results, introduction of CCyB and D-SIB, apt. of governor of

new committee and Southbound inflow.

On the regulation side, since the first meeting of the Financial Stability and

Development Committee – the 「super-regulator」 coordinating financial

regulators – on 8 Nov 2017, the pace of releasing new regulations has

accelerated notably (Figure 2). This weekend, the CBRC released three

regulations targeting entrusted loans, banks』 concentration risks and

shareholding management. These regulations, in general, aim to crack down

on shadow banking by closing loopholes and reducing regulatory arbitrage.

What makes this round of tightening different from the past is that – with the

new committee leading, these regulations are more coordinated. Starting

with The Asset Management Guideline, an overall guideline, the following

regulations are targeting particular sub-markets/sectors one-by-one and stepby-

step. Also, most regulations have considerable grace periods. So the

shocks to system liquidity should be largely manageable.

The establishment of the Financial Stability and Development Committee is

the biggest step in the financial deleveraging process,in our view. China

announced that it will set up a new and high-level committee during its fifth

National Financial Working Conference during 14-15 July 2017. This new

committee is led by one of China』s vice premiers (currently led by Premier Ma

Kai) and is set on top of the PBOC and other financial regulators. It is designed

to be the coordinating entity within the State Council on major issues related

to financial stability and financial reform and development.

We see the establishment of this new committee as a crucial step to

strengthening China』s financial regulatory framework and lowering systemic

risks. In the past, one of the key drivers to the proliferation of China』s shadow

banking has been its fragmented regulatory framework, as there has been a

lack of sufficient communication and coordination among the four financial

regulators. In some instances, there was even competition between regulators,

leading to aggressive expansion in some asset management products. A new

committee led by a more senior leader of government and set above existing

regulators should help improve regulatory coordination and curb the regulatory

arbitrage of financial institutions by closing loopholes and reducing regulatory

competition. In our view, this should contain growth and reduce the murkiness

of China』s shadow banking system.

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