Strategic guidelines for the development of the banking system scientific work. Strategy for the development of the banking sector of Russia. Measures to develop banking services for the non-financial sector of the economy and the population

22.03.2022

The banking system of the Russian Federation includes the Bank of Russia, credit institutions, as well as branches and representative offices of foreign banks.
One of the main and integral structures in the economy is the banking system. The development of banks went in parallel and was closely intertwined with commodity production and circulation. At the same time, banks contribute to the growth of the productivity of social labor and significantly increase the overall efficiency of production through cash settlements, lending to the economy and acting as intermediaries in the redistribution of capital.
The main sphere of the national economy of any developed state is the modern banking system. Its practical role is as follows: managing the system of payments and settlements in the state, directing the savings of the population to firms and production structures, carrying out most of its commercial transactions through deposits, investments and credit operations. Commercial banks regulate the movement of cash flows, affecting their total mass, including the amount of cash in circulation, the rate of turnover of cash flows and emission, act in accordance with the monetary policy of the state. Ensuring a constant price level, upon reaching which market relations affect the economy of the national economy in the most effective way, and the key to reducing inflation rates is the stabilization of the growth of the money supply.
The modern banking system is a sphere of diverse services: from traditional cash settlement and deposit and loan operations, which determine the basis of banking, to the latest forms of financial and monetary instruments used by banking structures (trust, leasing, factoring, etc.).
The goal of the reform program is to create a banking system capable of effectively performing three key macroeconomic functions: maintaining a balance between money demand and supply, ensuring intersectoral capital flow, and transforming savings into investments.
To achieve this goal, it is supposed to solve the following tasks:
- expansion of the base of long-term resources of the banking system (the target is to reduce the average share of demand liabilities in the attracted funds of banks, excluding Sberbank, to at least 40%);
- achievement by banks of the level of provision with own capital that meets international requirements (standards of the Basel Committee);
- formation of liquid, capacious and stable financial markets, which play a significant role in the placement of bank funds and financing of enterprises;
- creation of a system for ensuring information transparency of borrowers, as well as effective legal mechanisms for protecting banks from credit risks;
- approximation of the degree of concentration of resources of the Russian banking system to the level of developed industrial countries of continental Europe.
The main areas of reform, which determine the success of the transformation as a whole, should be: stimulating the concentration of banking resources (consolidation of banks) and the formation of a capacious market for highly liquid corporate debt instruments.
An increase in the concentration of banking resources will lead to the formation of a wide layer of banks with a highly diversified client base and loan portfolio, which will solve a whole range of critical problems:
- reduce the level of credit risks of banks;
- increase the liquidity of banks;
- expand bank lending to enterprises, form a mechanism for the redistribution of capital between diversified enterprises that form a circle of clients and borrowers of specific banks.
The development of the corporate debt instruments market will allow:
- eliminate the contradiction between banks' orientation towards short-term allocation of resources and the dominance of demand for long-term and medium-term borrowings from enterprises;
- provide banks with profitable and at the same time liquid assets;
- offer a collateral instrument for the interbank loan market, which will facilitate the redistribution of resources in the banking system
- expand the range of tools for regulating the money supply by the monetary authorities (through operations on the open corporate securities market).
At the same time, a set of measures is being deployed aimed at increasing the capitalization of banks, expanding the base of long-term resources of banks, creating an adequate legal environment, and ensuring information transparency of economic agents.
As a result of these measures, three complementary groups of banks may be formed, interconnected through the money markets: large banks specializing primarily in lending; banks are strategic investors in the corporate securities market, concentrating long-term resources (this group may include Sberbank); other banks acting as short-term investors in the corporate securities market and creditors of the first two groups of banks. Such a structure will ensure the most complete involvement of the savings accumulated by banks in financing the national economy.

22.2. Overcoming deformations in the banking system and the role of credit in the development of the country's economy

The strategic maneuver to bring the banking sector to the level of its effective functioning is as follows.

1. Formation of the institutional base of the banking system based on a package of laws providing for:

Increased requirements for risk insurance systems for various types of activities of credit institutions and the degree of mutual consistency of these systems within an individual bank (Basel 2 standards);

Instead of reducing the participation of the state (in the form of appropriate management and regulatory structures within the legal framework) in providing guarantees for bank loans, it is necessary not only to restore the previously existing regime, but also to strengthen the institution of state guarantees for loans provided by banks to enterprises in the real sector in within the framework of targeted federal programs and the operation of special state investment funds. Refusal of state guarantees due to the inability of the relevant structures to carry out this activity cannot be the reason for the rejection of this institution.

The complex of problems of the strategy for enhancing bank advances for economic growth includes increasing the stability of bank liabilities, activating the policy of forming credit resources based on stimulating savings of individuals and legal entities in the national currency, as well as concessional lending to investment projects that are not included in the list of federal target programs.

FINDINGS

1. Reforming the credit and banking system in the 1990s gave rise to a number of contradictions and threats to economic security, including: an increase in intra-system contradictions (the policy of the Central Bank of the Russian Federation and the commercial interests of Russian banks) and a decrease in the reproductive activity of the monetary system as a whole; the withdrawal of monetary capital from the national economy, as well as the intensive development of the "shadow" (informal or unregulated within the framework of the legislative framework) economy, etc.

2. Bringing the banking sector in the 1990s. into a state of systemic instability and increased threats to economic security in this area unequivocally determined the regressive direction of the development of the banking sector and monetary relations in general, since:

a) the dominant of competition in the evolution of banks was not realized;

b) the credit potential of banks was initially suppressed by the repressive behavior of the financial authorities and the restrictive policy of the monetary authorities;

c) there was no institutional basis for equality of conditions and rights for each bank, which led to the hypertrophy of the functions of individual banks and the crisis situation in the field of banking services.

3. Threats to national interests in the banking sector are associated with the monetary policy pursued by the Central Bank of the Russian Federation: a) complete disregard for the needs and demand of real sector structures in investment funds; b) the indifference of monetary policy instruments (reserve requirements, refinancing rates, etc.) in relation to stimulating the activities of credit institutions.

4. Key directions of the strategy for sustainable development of the banking sector: implementation of a system for monitoring threats to economic security in the environment of banking services for their timely identification; use of the entire arsenal of means and methods of banking regulation, supervision and control for the timely prevention of threats to economic security in the banking sector and their elimination; promotion
the responsibility of each participant in the banking services market for the fulfillment of their mutual obligations.

CONTROL QUESTIONS AND TASKS

1. What are the basic principles of the functioning of the Russian banking system and their compatibility with national interests and ensuring economic security (the Central Bank of the Russian Federation and the banking sector)?

2. What is the deformation in the functioning of Russian banks in the 1990s? What is their impact on the emergence of crisis situations in the Russian economy and the slowdown in economic growth?

3. Suggest directions for preventing and eliminating deformations in the functioning of the banking system (the Central Bank of the Russian Federation and the banking sector), for regulating banking activities in accordance with the requirements of economic security, as well as for providing: a system for identifying (monitoring) conditions and factors that cause crisis phenomena in banking environment.

1.Ignatiev SM. Speech at the XII International Banking Congress "The Banking Sector and Sustainable Economic Growth"//Bulletin of the Bank of Russia. 2003. No. 3?

2. Models for assessing the stability of commercial banks and their development at the present stage. M., 2002.

3.Finance, monetary circulation and credit: Proc. / Ed. chagov. M. Prospekt, 1999.

4. Formation of the national financial strategy of Russia: Path to recovery and prosperity / Ed. . M.: Delo, 2004. Ch. 6.

5.Economic security: production - finance - banks / Ed. chagov. M.: Finstatinform, 1998. Ch. nineteen.

The measures implemented by the Government of the Russian Federation and the Central Bank of the Russian Federation within the framework of the Strategy for the Development of the Banking Sector of the Russian Federation, adopted in December 2001, and the Strategy for the Development of the Banking Sector of the Russian Federation for the period up to 2008, contributed to the consolidation of positive trends in the dynamics of the formation and development system, a significant expansion of the offer of banking services in the Russian Federation.

Measures to overcome the crisis and its consequences, carried out by the Government of the Russian Federation and the Central Bank of the Russian Federation in 2008-2009, prevented the collapse of the banking system and provided conditions for the post-crisis recovery of credit institutions.

Having overcome the crisis, the banking sector in the second half of 2010 again entered the trajectory of progressive development. Despite the fact that the consequences of the crisis will be felt for a long time, the state of the banking system is stable. Conditions are being created for further increasing the contribution of credit institutions to improving the efficiency and competitiveness of the Russian economy, including through the provision of financial resources for its modernization and innovation.

At the same time, the Government of the Russian Federation and the Central Bank of the Russian Federation, taking into account the lessons of the crisis, state the need to continue efforts to increase the stability of the banking sector and ensure the dynamic growth of the aggregate indicators of its functioning.

The achievements of modern information technologies, which form the basis for the modernization of banking activities, should be used more and more actively. The Government of the Russian Federation and the Central Bank of the Russian Federation proceed from the need to further increase the level of competition, transparency and market discipline in the banking sector. In this regard, the formation in the next few years of a more effective system of banking regulation and supervision, capable of withstanding crises, is of particular importance. The process of consolidation in the banking sector, based on the economic interests of market participants, will receive an additional impetus.

As a result, credit institutions will increasingly focus on long-term performance and more rational business conduct, building and using effective management systems, including risk management. These changes will mean a transition to an intensive model of development of the banking sector.

To achieve these goals, the Government of the Russian Federation and the Central Bank of the Russian Federation adopted the Strategy for the Development of the Banking Sector of the Russian Federation for the period up to 2015.

The Government of the Russian Federation and the Central Bank of the Russian Federation, as part of the implementation of this Strategy, intend to create the necessary legal and other conditions for the formation in the Russian Federation of a modern, highly developed and competitive banking sector that meets the interests of the Russian economy and provides a high level of banking services to the population and organizations.

Development strategy
banking sector of the Russian Federation for the period up to 2015

I. Goals and factors of development of the banking sector of the Russian Federation

The main goal of the development of the banking sector of the Russian Federation (hereinafter referred to as the banking sector) in the medium term is to actively participate in the modernization of the economy based on a significant increase in the level and quality of banking services provided to organizations and the population, and ensure its systemic sustainability. Achieving this goal is a necessary condition for the development of the Russian economy and increasing its competitiveness in the international arena through diversification and transition to an innovative path of development.

The banking sector has come a long way in 20 years of development. At the same time, from the moment of its inception in the late 1980s to the present, development has proceeded mainly within the framework of an extensive model. This model is based on the orientation of banks towards short-term performance results, which, among other things, determines an aggressive commercial policy and a high concentration of risks. The banking sector has not yet reached the required level of development of the competitive environment and market discipline, which negatively affects the availability and quality of services provided by banks. The problems of the banking sector are the low responsibility of the owners and management of banks for the quality and stability of the banking business, the reliability of information about the state of banks, as well as the hope for state support in stressful situations.

The aggressive policy of a number of banks had a negative impact on their stability, which was especially acute during the crisis and required the Government of the Russian Federation and the Central Bank of the Russian Federation (Bank of Russia) to take urgent measures to ensure the systemic stability of the banking sector, which made it possible to overcome the crisis and maintain public confidence and organizations to the banking system.

At the same time, the need for a more resolute transition to a banking sector development model characterized by the priority of qualitative performance indicators and a focus on long-term efficiency became apparent. This fully meets the long-term priorities of economic development, including those envisaged by the Concept for the Long-Term Socio-Economic Development of the Russian Federation for the period up to 2020, approved by Decree of the Government of the Russian Federation dated November 17, 2008 No. 1662-r.

1. On the implementation of the Strategy for the Development of the Banking Sector of the Russian Federation for the period up to 2008

The transformation of the model of development of the banking sector and the definition of tasks for its further development are impossible without comprehending the accumulated experience of reforms in the banking sector.

Work to change the vector of development of the Russian banking system has been carried out since the early 2000s as part of the implementation of previous strategies for the development of the banking sector of the Russian Federation. The Strategy for the Development of the Banking Sector of the Russian Federation for the period up to 2008 (hereinafter referred to as Strategy 2008) provided for the implementation of measures to increase the role of Russian credit institutions in the economic development of the country, strengthen confidence in the banking system, increase its transparency, as well as to increase the level of protection of creditors and depositors credit organizations.

In 2005-2008, favorable macroeconomic conditions developed in the Russian Federation. This circumstance and the high level of investment and consumer demand predetermined the growth of banking activity even during the period of turbulence in the world financial markets from mid-2007 to autumn 2008.

During this period, the Government of the Russian Federation and the Bank of Russia carried out the main work to implement measures to implement the 2008 Strategy.

A distinctive feature of the banking reform carried out in the Russian Federation in 2005-2008 was a combination of measures aimed at maintaining high rates of economic growth, including through the creation of favorable conditions for lending to the real sector of the Russian economy, with actions to increase the competitiveness of the banking sector in the context of foreign exchange liberalization. legislation of the Russian Federation and improving the system of banking supervision, taking into account the best international practices and recommendations of the Basel Committee on Banking Supervision.

Among the important tasks implemented in accordance with the 2008 Strategy, it should be noted, in particular, the adoption of federal laws aimed at equalizing the conditions for the access of Russian and foreign banks to the Russian banking services market, increasing the capitalization of the banking sector, protecting the rights of consumers of financial services and increasing transparency consumer lending, expansion of bank services to their customers outside the location of the credit institution.

This Strategy takes into account the results of the banking sector reform at the previous stages and has been prepared taking into account the tasks of the new stage. At the same time, the continuity of the main goals and objectives of the development of the banking sector is preserved.

2. Problems of development of the banking sector

During the implementation of the 2008 Strategy, the characteristics of the development of the banking sector have changed significantly. These changes correspond to the rather dynamic development of both individual Russian credit institutions and entire segments of the banking services market (for example, consumer lending).

In general, for the banking sector, the last 10 years have been years of rapid growth and expansion of the offer of banking services to the population and enterprises. In institutional terms, banks play a major role in the system of financial intermediation in the Russian Federation, significantly outperforming other financial market participants in terms of economic potential.

At the same time, along with a significant increase in the indicators of the development of the banking sector, there are still problems in the banking business, as a result of which the competitiveness of Russian credit institutions and the banking sector as a whole remains insufficient. This is due to various factors, both outside and inside the banking sector.

External factors include, in particular, the lack of diversification of the economy and the general lack of its investment opportunities, the limited and predominantly short-term nature of credit resources, the high level of non-core (administrative) expenses of credit institutions, including those related to checking compliance with cash discipline by customers and storing large volumes of documents in paper form. Fraud still continues to be a very common phenomenon that both banks and regulators have to deal with. In order to increase the competitiveness of the banking business, it is necessary to increase the level of protection of private property, including the formation of standard legal structures that protect the interests of creditors, and increase the efficiency of the judicial system in terms of the timing and quality of decisions made.

As internal shortcomings of the banking sector, the following can be noted:

the irresponsibility of the owners and management of some banks when making business decisions dictated by the pursuit of short-term profits to the detriment of financial stability;

unsatisfactory in a number of cases state of management, including the corporate aspect and risk management, including due to the orientation of credit institutions to serve the owners' business;

the existence of non-transparent forms of activity for the regulator and the market, unreliable accounting and reporting, leading to distortion of information about the work of credit institutions;

the involvement of individual credit institutions in illegal activities;

insufficient technological reliability of information systems of credit institutions, due, among other things, to the disorder in the field of application of information technologies in banking, including technologies for remote banking services.

The presence of unresolved problems necessitates additional efforts on the part of the Government of the Russian Federation and the Bank of Russia in order to further develop the banking sector aimed at qualitative changes in the activities of banks.

3. Transition to a predominantly intensive development model

The Government of the Russian Federation and the Bank of Russia proceed from the fact that an intensive banking sector development model is characterized, among other things, by the following features:

a high level of competition in the banking market and the financial services market in general, which is facilitated by the implementation of the principle of proportionality in regulation and the prevention of conditions for regulatory arbitrage in relation to participants in any segments of the financial market;

provision by credit institutions of various and modern banking services to the population and organizations;

the level of capitalization of the banking sector, corresponding to the tasks of development, increasing the competitiveness and efficiency of the banking business;

developed corporate governance and risk management systems, which ensure, among other things, the long-term efficiency of the banking business, balanced management decisions and timely identification of all risks, a conservative assessment of the possible consequences of their implementation and the adoption of adequate risk protection measures;

high degree of transparency and market discipline of credit institutions and other market participants;

the responsibility of managers, members of boards of directors (supervisory boards) and bank owners for the fair and balanced conduct of business, as well as for the accuracy of information published and submitted to control and supervision bodies.

The task of transitioning to a predominantly intensive banking sector development model should become a priority for the Government of the Russian Federation, the Bank of Russia and the banking community. Among the priorities of the Government of the Russian Federation and the Bank of Russia is work on the comprehensive improvement of the legal conditions for the activities of credit institutions, including the issues of reducing the unjustified administrative burden.

The implementation of this Strategy will be carried out in accordance with the plan. In turn, credit institutions will need to significantly increase their investment in advanced banking technologies and banking products, as well as in the development of modern financial instruments.

II. Tasks for Reforming the Banking Sector and Expected Outcomes of its Development

1. The main tasks of the Government of the Russian Federation and the Bank of Russia in changing the banking sector development model

Changing the banking sector development model will require the Government of the Russian Federation and the Bank of Russia to implement a set of measures aimed at:

to improve the legal environment, including the development of the legislation of the Russian Federation and the creation of other conditions that provide opportunities for rational business conduct, more effective protection of private property and the development of competition in all segments of the financial market;

on the formation of an infrastructure that meets modern requirements and is based on the use of advanced banking technologies, the development of a pledge registration system, credit history bureaus, payment and settlement systems, the institution of a central counterparty and other infrastructure institutions and conditions, including measures to create an international financial center in the Russian Federation;

to improve the quality of corporate governance and risk management in credit institutions;

to improve banking regulation and banking supervision, primarily by developing their content and bringing the legal conditions and practice of their implementation in line with international standards. Such work should be supplemented by the formation of a system of regulation and supervision (control) over the activities of all organizations providing financial services, based on the principle of proportionality of the requirements imposed on the systemic importance of organizations and the level of risks they take;

to ensure financial stability.

Solving the problems of development of the banking sector will require a significant change in the conditions for its functioning and may lead to a transformation of its structure.

2. Expected results of the development of the banking sector

As a result of the implementation of this Strategy, the Russian banking system in all major aspects (organization of activities, quality of management, state of the competitive environment, accounting and reporting, market discipline and transparency, regulation and supervision) must comply with international standards.

The expected results of the development of the banking sector are based on the provisions of the Concept of long-term socio-economic development of the Russian Federation for the period up to 2020 and take into account the need to improve the banking business model. It is assumed that by January 1, 2016 the banking sector will achieve the following aggregate indicators:

loans to non-financial organizations and individuals/GDP - 55 - 60 percent (as of January 1, 2011 - 40.8 percent).

At the same time, the Government of the Russian Federation and the Bank of Russia proceed from the fact that the qualitative characteristics of development are of paramount importance - the nature and level of banking services provided, the level of competition in the banking sector, the stability and transparency of credit institutions, which predetermine the strengthening of the role of banks in the innovation processes of the real sector of the economy and improving the efficiency of investments.

III. On the main areas of activity of the Government of the Russian Federation and the Bank of Russia to ensure the development of the banking sector

As part of the implementation of this Strategy, the efforts of the Government of the Russian Federation and the Bank of Russia will be focused primarily on creating conditions for increasing the efficiency of the banking sector's transformation of temporarily free funds into loans and investments and increasing the role of the banking sector in the process of modernizing the Russian economy.

It is envisaged to take measures aimed at:

to create conditions for the development of competition in the banking sector and in the financial market as a whole, as well as to increase the competitiveness of Russian credit institutions and the systemic stability of the banking sector;

to improve the quality and expand the possibilities for the consumption of banking services by the population and organizations, including those in remote and hard-to-reach regions;

on the introduction of modern banking and information technologies, simplification and expansion of the list of instruments for lending to small businesses;

to prevent the involvement of credit institutions in illegal activities, primarily in the legalization (laundering) of proceeds from crime and the financing of terrorism.

As part of the implementation of these measures, it is necessary to solve the issues of improving the legislation of the Russian Federation, reducing the participation of the state in the capital of large Russian credit institutions, creating a system of regulation and supervision in the financial services market provided by non-credit institutions, creating and operating modern infrastructure complexes, including an international financial center in the Russian Federation, as well as the development of the national payment system.

The implementation of measures taken by the Government of the Russian Federation and the Bank of Russia will make it possible to ensure a qualitative improvement in the conditions for banking services to the Russian economy, which will contribute to its balanced growth and sustainable development of the domestic market.

1. State participation in the capital of credit institutions

In the medium term, it is planned to reduce the state's participation in the capital of credit institutions while maintaining state control over the activities of the open joint-stock company Sberbank of Russia, VTB Bank (open joint-stock company) and the open joint-stock company Rosselkhozbank. At the same time, in the next 3 years, it is planned to reduce the state participation in the authorized capitals of the open joint-stock company Sberbank of Russia and VTB Bank (open joint-stock company) to at least 50 percent plus one voting share. In the future, the Government of the Russian Federation and the Bank of Russia will continue to reduce the state's share in the authorized capital of these credit institutions. In the authorized capital of the open joint-stock company "Rosselkhozbank" until 2015, the state's share of participation is expected to be reduced to 75 percent.

As the conditions for the open joint-stock company "Sberbank of Russia", VTB Bank (open joint-stock company) and the open joint-stock company "Rosselkhozbank", as well as other credit institutions with government shares in the authorized capital, are formed, it is planned to take actions to attract strategic investors and place shares owned by the state in open capital markets.

The Government of the Russian Federation intends to ensure the reduction of the state's share in the authorized capital of the Postal Bank of the Russian Federation being created within 3 years after its creation not below the level of 50 percent plus one voting share with a further decrease in this share within 5 years after its creation.

The Government of the Russian Federation considers investments in shares of credit institutions that were made by companies with a predominant state share in the authorized capital (Open Joint Stock Company Russian Railways, Open Joint Stock Company Gazprom and others) as non-core assets and will ensure the implementation of measures to approve companies with state participation of medium-term programs for the alienation of such non-core assets in order to improve corporate governance and attract additional sources of financing for investment programs.

Shares of credit institutions owned by constituent entities of the Russian Federation and municipal property are property that is not required for the exercise of public powers. The Government of the Russian Federation recommends that the executive authorities of the constituent entities of the Russian Federation and local self-government bodies ensure its phased privatization in relation to the said property.

At the same time, a consistent exit from the capitals of credit institutions should not have a negative impact on the stability of the banking sector.

Taking into account the accumulated experience, the practice of attracting independent directors to participate in the management of credit institutions with government shares in the authorized capital, as well as the creation of special committees (for remuneration, risk management and internal audit, strategic planning, and others) under the boards of directors ( supervisory boards) of such credit institutions.

2. Participation of the state in the development of modern financial infrastructure

The most important element in the development of modern financial infrastructure in the Russian Federation is the work carried out by the Government of the Russian Federation and the Bank of Russia to create an international financial center in the Russian Federation.

The creation of an international financial center will contribute to a deeper integration of the banking sector and Russian credit organizations into global markets, and will ensure a comprehensive improvement of the existing system of financial market regulation.

An important place in the financial infrastructure being created should be occupied by the national payment system, which is based on modern, comprehensive and balanced legal regulation and uses modern international standards and technologies.

It is necessary to provide legal conditions for regulating the activities of organizations that are operators of payment systems, money transfer operators and operators of payment infrastructure services, as well as establish requirements for the organization and functioning of payment systems, the procedure for supervision and supervision in the national payment system.

It is necessary to legislatively define the criteria and identify significant payment systems, take into account the peculiarities of the regulation of cross-border payment systems.

The Government of the Russian Federation pays great attention to the issue of increasing the share of non-cash payments in the Russian Federation. In this regard, it is planned to continue work on the implementation of a set of measures aimed at introducing a universal electronic citizen card with an integrated special banking application.

In order to develop the market infrastructure and reduce risks when concluding transactions, it is necessary to continue work on the legal regulation of clearing activities.

As part of increasing the attractiveness of investments by central banks, it is envisaged to legislate the rules on the immunity of central banks of foreign states and their property.

The Government of the Russian Federation, together with the Bank of Russia, will determine the procedure and terms for the withdrawal of the Bank of Russia from the shareholders of the closed joint-stock company "Moscow Interbank Currency Exchange".

3. Participation of foreign capital

The result of the financial crisis was the stabilization of the indicators of participation of foreign capital in the Russian banking system. If in 2005-2008 the inflow of foreign direct investment into the banking sector was one of the significant factors in increasing the capitalization and expanding the resource base of the Russian banking system, then in 2009-2010 the influence of this factor was much less noticeable.

The presence of foreign capital in the banking sector contributes to increased competition in the Russian banking services market, which is a positive factor in its development.

In general, the application of restrictive measures in relation to the participation of foreign capital in the banking sector is possible only in order to ensure fair competition in the banking services market within the framework of international agreements reached without prejudice to the interests of banking services to the population and organizations.

The inflow of foreign investment into the banking sector will be facilitated by the legislative consolidation of transparent procedures related to the registration of representative offices of foreign banks in the territory of the Russian Federation, and by entrusting the Bank of Russia with the authority to register (accredit) them in accordance with the procedure established by it, which involves amending the federal laws "On Foreign Investments in the Russian Federation" and "On Banks and Banking Activity".

4. Development of competition and maintenance of a competitive environment in the banking business

As the consequences of the financial crisis are overcome, the banking sector will develop in the face of increased competition in the most profitable segments of the banking services market. At the same time, a certain activation of consolidation processes in the banking sector is expected with the formation of larger banking structures, including those that control a significant share of the banking services market.

The Government of the Russian Federation and the Bank of Russia will take measures aimed at maintaining equal business conditions for all credit institutions, regardless of size and form of ownership, including state-controlled credit institutions.

The suppression of abuses by credit institutions in connection with their dominant position in the banking services market remains one of the key tasks of antimonopoly regulation. The Government of the Russian Federation and the Bank of Russia will continue to prepare proposals for amending the legislation of the Russian Federation aimed at protecting the interests of consumers of financial services, taking into account international experience in antimonopoly regulation in the banking sector.

5. Territorial aspects of the provision of banking services

The territorial distribution of banking services in the Russian Federation continues to be heterogeneous. In some regions, the supply of banking services lags far behind demand, which is due, among other things, to the high costs of creating and maintaining a branch network. In addition, the promotion of banking services to the regions in some cases requires additional capitalization of credit institutions.

As a result, in the Russian Federation there are groups of the population and entrepreneurs who have significantly limited opportunities to obtain banking products and services, including attracting bank loans. This is mainly the population of rural and remote regions, low-income segments of the population and small businesses. This circumstance hinders the development of small and individual entrepreneurship in the regions of the Russian Federation and slows down the smoothing of regional disproportions, including in the standard of living of the population.

The solution to the problem of low availability of banking products and services in remote areas will be facilitated by the implementation of the project to create the Postal Bank of the Russian Federation.

The Bank of Russia will continue to work to further ensure the conditions for the development of regional networks of credit institutions, including through the abolition of territorial restrictions on the establishment of operational offices.

In order to reduce territorial disproportions in the provision of banking products and services, the Government of the Russian Federation, along with measures to expand the possibilities for their provision, will continue to create conditions for the activities of non-credit organizations in regions with an insufficient supply of banking services.

6. Measures to develop banking services for the non-financial sector of the economy and the population

One of the necessary conditions for the development of credit relations between banks and organizations in the real sector of the economy and the population is to ensure the protection of the rights of banks as creditors and encourage more responsible behavior of borrowers, including the improvement of the pledge legislation of the Russian Federation.

The Government of the Russian Federation and the Bank of Russia provide for the creation of a system for registering notifications of pledges and other encumbrances of movable property with identification features (machinery, equipment and vehicles in accordance with the All-Russian Classifier of Fixed Assets). The functions of registering notices (functions of the registration organization) will be performed by the credit bureau. At the same time, registration organizations will be required to comply with special requirements established by federal law. It also provides for the organization of state control and supervision over the activities of registration organizations.

In order to develop the system of lending by banks to small and medium-sized businesses, it is necessary to increase the efficiency of using resources allocated under state programs through state development institutions (banks), as well as to intensify the work of small and medium-sized business development funds, which, among other things, perform the functions of guarantee funds in the constituent entities of the Russian Federation . Support for small and medium-sized businesses will continue, implemented by Vnesheconombank and other development institutions through a system of partner banks, leasing and factoring companies, and microfinance organizations.

An important contribution to the formation of financial markets will be the further development of the legal conditions for asset securitization, taking into account Russian specifics and international experience, including that gained during the crisis. The syndicated lending mechanism will be further developed.

Stabilization of the resource base of the banking sector will be facilitated by amendments to the legislation of the Russian Federation, providing banks with the opportunity to conclude a bank deposit agreement with a depositor who is an individual on terms that do not provide for the right of the depositor to early demand the amount of the deposit or part thereof, or do not provide for his right to early presentation for payment of a savings (deposit) certificate.

The Government of the Russian Federation will continue to implement the mechanism for refinancing mortgage loans, including by investing pension savings managed by Vnesheconombank in mortgage-backed bonds in order to stimulate mortgage lending and make it more accessible to the general population. It is envisaged to consider other forms of attracting and using citizens' funds for the purchase or construction of residential premises.

The range of financial market instruments and bank operations on them is expected to be expanded by creating legislative opportunities for keeping accounts in precious metals.

7. Measures to reduce the administrative burden on credit institutions

Reducing the administrative burden on credit institutions remains among the priorities of the Government of the Russian Federation and the Bank of Russia. In this regard, there will be:

resolve the issue of exempting credit institutions from performing functions unusual for them to control the implementation by economic entities of the established rules for working with cash;

reduce the list of positions whose appointment requires approval by the Bank of Russia by excluding from the list of deputy heads and deputy chief accountants of branches of credit institutions;

unify the requirements for the stability of banks for the purposes of banking supervision and participation of banks in the deposit insurance system;

to continue work on optimizing the reporting of credit institutions in a number of areas, including amending the legislation of the Russian Federation on archiving in order to reduce the requirements for the volume and terms of storage of documents on paper, eliminating duplicate information from reporting forms and creating conditions for the transition to reporting information primarily on electronic media;

resolve the issue of eliminating excessive burdens in the processing by credit institutions and the Bank of Russia of personal data received from customers (counterparties) and credit institutions-correspondents, in the course of banking operations and activities preceding the conclusion of agreements with customers (counterparties) and credit institutions-correspondents, and also when processing personal data by the Bank of Russia for the purpose of exercising control and supervisory functions.

8. Issues of development and implementation of modern banking technologies in the Russian Federation

Modern banking is impossible without the use of advanced information technologies that improve the quality of services provided and expand their list. As practice shows, the introduction of new banking technologies by credit institutions provides a significant increase in the efficiency of their activities.

Prospects for the development of the banking sector are largely related to the improvement of the methods of banking activities based on the application of advances in the field of informatization.

In recent years, there has been a process of intensive technological modernization of banking activities associated with the introduction of banking automated systems and remote banking services technologies in credit institutions, which can significantly expand the client base of credit institutions and the offer of banking services.

To realize the benefits of information technology, it is necessary to increase the operational compatibility of the payment infrastructure (processing centers, ATMs, terminals) and centralize clearing and settlement services based on unified rules and standards.

The Government of the Russian Federation and the Bank of Russia will ensure the formation of a regulatory framework, as well as general conditions for the use of the latest information technologies in banking, including remote banking technologies, automation of cash transactions, electronic means of payment and electronic processing of payment information based on the development of competition and introduction of innovations in the field of high-tech banking products with appropriate state regulation and control.

The introduction of new technologies and new banking products will allow credit institutions to significantly increase the speed and quality of banking operations, simplify settlements for the population, provide more opportunities for obtaining cash from bank accounts and protect the property interests of citizens from counterfeiting, create conditions for promoting banking products and services to remote regions with a low level of development of banking services, as well as in territories where there are no credit institutions, their branches or internal structural divisions.

At the same time, the development of advanced technologies puts on the agenda the issues of ensuring the reliability of the functioning of banking automated systems and their information security. An important area in the activities of credit institutions should be to ensure the protection of information, identify risks of a technical and technological nature, as well as the risks of using a credit institution in activities aimed at the legalization (laundering) of proceeds from crime and the financing of terrorism.

In order to improve the reliability of banking activities in the context of the growing use of modern banking technologies, the issue of legislatively assigning to the Bank of Russia the functions of determining the minimum requirements for managing risks of credit institutions in this area is becoming relevant.

The Government of the Russian Federation and the Bank of Russia will support the efforts of the banking community aimed at regulating high-tech banking activities. In particular, the Bank of Russia intends to continue participating in the adaptation of international and the development of national standards in the field of rational use of advanced technologies in banking, as well as in creating conditions for compliance with such standards.

At the same time, credit institutions and banking associations are encouraged to continue their work aimed at regulating high-tech banking activities, developing and implementing relevant industry standards and ensuring the conditions for their compliance.

9. On improving the quality and expanding the list of banking and other financial services in the Russian Federation

The development of intra-industry and inter-industry competition in the financial market, including competition for clients, will help improve the quality and expand the list of banking services in the Russian Federation.

Under these conditions, credit institutions will have to pay special attention to providing customers with a range of modern banking products and services and reducing unjustified cost, administrative, procedural, technical and technological costs (costs) of customers when they consume them.

A reasonable minimization of the package of documents for obtaining a loan and a reduction in the time for consideration by credit institutions of relevant applications, combined with measures to modernize technologies for interacting with a client using modern remote access systems, will significantly change the situation in the field of interaction between credit institutions and a group of clients representing small businesses and individual entrepreneurship .

Based on the experience of applying the Federal Law "On Credit Histories", in order to improve the quality of lending services, it is advisable to implement measures to improve the work of credit history bureaus and the Central catalog of credit histories.

The work carried out by the Government of the Russian Federation and the Bank of Russia to improve the legislation of the Russian Federation on consumer lending, credit cooperation and microfinance will contribute to improving the quality and expanding the list of banking and other financial services.

An important factor in the development of fair competition and improving the quality of services is the development of market discipline, including the expansion of the publication by banks of objective information about their activities. The Government of the Russian Federation and the Bank of Russia will take measures aimed at consistently increasing the transparency of credit institutions. The Bank of Russia will continue the practice of posting in the media and on its website on the Internet materials explaining to the public the issues of providing banking services.

10. Issues of creating an international financial center in the Russian Federation and strengthening the role of the ruble in international settlements

The Government of the Russian Federation and the Bank of Russia are working to implement the measures provided for by the action plan for the creation of an international financial center in the Russian Federation, approved by Order of the Government of the Russian Federation No. 911-r dated July 11, 2009. The implementation of these measures will also contribute to the achievement of the objectives of this Strategy.

The creation of an international financial center in the Russian Federation will allow for a deeper integration of the banking sector and Russian credit institutions into global markets, as well as ensure a comprehensive improvement of the existing system of financial market regulation.

At present, changes in the monetary policy of developed countries and an increase in the volatility of the exchange rates of major world currencies have created additional prerequisites for the formation of new currency blocs and bilateral settlement mechanisms based on the use of local monetary units in international financial settlements, as well as for the emergence of new international financial centers, including in the Russian Federation. At the same time, there is a real opportunity to significantly increase the share of the Russian ruble in international settlements, which, in turn, makes it possible to switch to using the ruble as a regional reserve currency and reduce currency risks for Russia and partner countries.

In order to create attractive conditions for international settlements using the ruble, the Government of the Russian Federation and the Bank of Russia should consider introducing changes to the currency, tax and customs legislation of the Russian Federation.

11. Issues of protecting the rights of consumers of banking services

In the system of the modern banking services market, despite a number of positive trends contributing to its progressive development, there are certain problems that negatively affect the quality of banking services and the level of retail consumers' confidence in credit institutions. To solve these problems, it is necessary to improve the legislation of the Russian Federation, including the adoption of federal laws aimed at regulating relations in the field of consumer lending, protecting the rights of consumers of financial services and improving the procedure for collecting debts from debtors - individuals. To ensure additional protection of the rights of debtors of credit institutions, it is also necessary to legally regulate the procedure for collecting overdue debts (collection activities).

In order to simplify the procedure for resolving conflict situations between credit institutions and their clients, it is advisable to take measures aimed at developing and improving out-of-court dispute resolution procedures.

In addition to improving the effectiveness of protecting the rights of consumers of banking services, it is necessary to develop their financial literacy, including the formation of a responsible attitude to personal finances, as well as to expand their knowledge and skills in using banking services. In this regard, the Government of the Russian Federation and the Bank of Russia, with the participation of the banking community, will make additional efforts to implement the activities of the project "Assistance in improving the level of financial literacy of the population and the development of financial education in the Russian Federation."

12. Issues of increasing the capitalization of the banking sector

An important condition for the development of the banking sector and increasing the stability of credit institutions is to increase the amount of their own funds (capital), improve its quality and ensure a sufficient level of capital coverage of the risks assumed by credit institutions. In this regard, measures aimed at increasing the capital base of credit institutions are of key importance for the implementation of the objectives of this Strategy.

From January 1, 2012, the amount of own funds (capital) for all banks must be at least 180 million rubles.

For the purpose of further capitalization of banks, the Government of the Russian Federation and the Bank of Russia will take measures to introduce amendments to the legislation of the Russian Federation, providing for the establishment of a minimum amount of the authorized capital of a newly created bank from January 1, 2012 and a minimum amount of own funds (capital) of banks created before that time from January 1, 2015 in the amount of 300 million rubles.

13. Development of financial services for small businesses and the population

In recent years, small business and individual entrepreneurship have been actively developing in the Russian Federation. At the same time, small businesses are experiencing a shortage of credit and financial services. For small businesses and individual entrepreneurs, citizens who have personal subsidiary plots, bank loans are inaccessible due to the lack of reliable collateral and, therefore, the complicated procedure for obtaining and the high cost of servicing.

As international experience shows, in addition to the development of banking services and the state's acceptance of part of the risks associated with lending to small businesses by banks, one of the ways to solve the problem of a shortage of credit and financial services can be the development of a system of non-credit organizations, primarily credit cooperatives and microfinance organizations, as well as pawnshops. .

The main task of the Government of the Russian Federation in this area is to ensure regulation and control over the activities of the relevant non-credit organizations. It is envisaged that in the future the function of supervision and verification of the activities of non-credit organizations on the ground will be withdrawn from the sphere of state regulation and transferred to self-regulatory organizations in the field of credit cooperation and microfinance, while maintaining the obligation to conduct selective and scheduled inspections jointly with the state regulator.

In the short term, the main task of the Government of the Russian Federation is to improve the system of regulation and control over credit cooperatives and microfinance organizations, as well as pawnshops.

14. On the organization of the circulation of cash

An important activity of credit institutions is the organization of cash circulation. To date, the Russian Federation has developed a traditional model for organizing cash circulation, which is characterized by a high degree of participation of the issuing center in the management of cash flows.

The Bank of Russia plans to more actively involve credit institutions in organizing cash circulation by delegating some of its functions to them. Decentralization of cash flows will make it possible to increase the efficiency of meeting the needs of business entities in cash, ensure the smooth functioning of cash circulation, especially in regions where there are no institutions of the Bank of Russia.

Given the rather high cost of cash transactions, one can expect a redistribution of the functions of credit institutions related to the conduct of cash transactions, in the direction of specialization of some credit institutions in working with cash and cooperation with other credit institutions on a contractual basis in order to provide them with processing, storage and transportation of banknotes and coins. The availability of qualified personnel and the necessary material and technical base for specialized credit organizations will ensure, on the one hand, the high quality of services provided at their moderate cost, and on the other hand, maintaining the purity of cash circulation.

A promising solution to improve the efficiency of providing the economy with cash is to provide a part of the Bank of Russia's cash for storage with credit institutions with the possibility of its spending under the control of the Bank of Russia and replenishment by credit institutions. Due to this, the operating expenses of credit institutions for the transportation of cash are reduced and the uninterrupted reinforcement of the operating cash desks of credit institutions with banknotes and coins is ensured. In addition, reducing the number of transports of large amounts of cash will increase their safety.

It is also planned to stop issuing and gradually withdraw from circulation 1- and 5-kopeck coins while maintaining them as a calculation tool.

It is planned to continue work on the legal regulation of the organization of circulation of cash and increase the transparency of settlements.

15. Operation of the deposit insurance system

Considering that the development of the Russian deposit insurance system should be based on the consistent improvement of its main parameters, it is planned to continue studying the best international experience recommended for use and summarized in the Fundamental Principles for Effective Deposit Insurance Systems, which were approved by the Basel Committee on Banking Supervision together with the International Association deposit insurers. The Government of the Russian Federation and the Bank of Russia, with the participation of the State Corporation Deposit Insurance Agency (hereinafter referred to as the Deposit Insurance Agency), will consider the possibilities of using this experience, taking into account the peculiarities of Russian practice.

In order to maintain the amount of insurance compensation at a level corresponding to the social and economic conditions in the country, as well as the financial capabilities of the deposit insurance system, it is planned to constantly monitor the adequacy of the insurance protection provided to depositors and, if necessary, adjust the level of insurance compensation and the level of insurance premiums.

It is also expected to consider other issues of the Deposit Insurance Agency's activities, taking into account the work being done by the Government of the Russian Federation to form a unified regulatory legal framework for the activities of all state corporations.

As part of the work to improve the deposit insurance system, consideration will be continued of the feasibility and possibility of expanding the range of entities covered by the protection provided by the deposit insurance system for individuals, at the expense of individual entrepreneurs operating without forming a legal entity.

At the same time, it is necessary to strengthen the legislative protection of the funds of the deposit insurance fund from dishonest actions of banks and clients on the artificial formation of obligations subject to insurance compensation.

16. Countering the legalization (laundering) of proceeds from crime and the financing of terrorism

The Government of the Russian Federation and the Bank of Russia intend to continue work to fulfill the tasks and functions defined by the Federal Law "On countering the legalization (laundering) of proceeds from crime and the financing of terrorism", as well as to improve the efficiency of the banking system in the field of countering the legalization (laundering ) proceeds of crime and financing of terrorism.

In this case, the Bank of Russia will take part:

in improving approaches to determining the list of transactions subject to mandatory control, as well as mechanisms for a risk-based approach in identifying customers, customer representatives and beneficiaries;

in work to expand the grounds on which credit institutions have the right to refuse to conclude a bank account (deposit) agreement and execute a client's order to conduct a transaction, as well as to provide credit institutions with the right to refuse to execute a bank account (deposit) agreement;

in clarifying the powers of supervisory authorities to monitor compliance by organizations that carry out transactions with funds or other property with certain requirements of the legislation of the Russian Federation in the field of combating the legalization (laundering) of proceeds from crime and the financing of terrorism.

17. Interaction with the banking community and international cooperation

In recent years, the interaction between the Government of the Russian Federation and the Bank of Russia with the banking community on the functioning of the banking sector has been significantly strengthened. The Government of the Russian Federation and the Bank of Russia will have to take new steps to develop constructive contacts with the banking community, primarily through banking associations, and continue the practice of involving them in improving the regulatory legal framework for banking activities.

At the same time, taking into account international experience, banking associations may be recommended to be more active in aggregating proposals from the banking community addressed to the Government of the Russian Federation and the Bank of Russia aimed at improving the efficiency of the banking business and bringing it in line with modern international standards and approaches. At the same time, there is a need to strengthen the role of banking associations in informing market participants about decisions made by the Government of the Russian Federation and the Bank of Russia in the field of banking.

Cooperation between the Government of the Russian Federation and the Bank of Russia with international organizations is actively developing. In 2011-2015, work will continue in the G20, the Financial Stability Council, the Basel Committee on Banking Supervision and their working bodies.

The Government of the Russian Federation and the Bank of Russia will continue to cooperate with the International Monetary Fund and the World Bank on the development of the banking sector, banking regulation and banking supervision. The Bank of Russia will continue to develop cooperation with the banking regulatory and supervisory authorities of other countries on issues of cross-border supervision of credit institutions, banking groups and bank holding companies.

18. Development of instruments for regulating the liquidity of the banking sector

In order to achieve the maximum availability of refinancing (lending) instruments for all financially stable domestic credit institutions, the Bank of Russia plans to optimize refinancing (lending) mechanisms and switch to a single mechanism for refinancing (lending) by the Bank of Russia of credit institutions, which will allow any financially stable Russian credit institution to organization to receive a loan from the Bank of Russia, secured by assets included in a single pool of collateral.

In addition, the Bank of Russia will continue its policy of expanding the list of assets that can be used as collateral for its loans.

The Bank of Russia plans to improve the regulatory and contractual framework governing REPO transactions in the Russian market, including the mechanisms for the Bank of Russia to conduct REPO transactions with credit institutions as part of the refinancing system. It is planned to arrange for the Bank of Russia to conduct REPO operations against a single pool of collateral, which will allow credit institutions to more effectively manage their securities portfolio when receiving refinancing from the Bank of Russia. The Bank of Russia will also take an active part in the implementation of collateral management services for REPO transactions (trilateral REPO) for financial market participants.

The Bank of Russia will continue to carry out deposit operations and operations to place bonds of the Bank of Russia to absorb excess liquidity in the banking sector. In order to ensure equal access of Russian credit institutions to deposit operations, the Bank of Russia will improve the procedure and conditions for conducting deposit operations, in particular, the Bank of Russia intends to consider the possibility of expanding the composition of credit institutions participating in Bank of Russia deposit operations, granting a certain period, as well as the use by credit institutions for the purpose of fulfilling obligations under deposit transactions, along with correspondent accounts opened with the Bank of Russia, of their correspondent sub-accounts with the Bank of Russia and bank accounts opened with authorized settlement centers of the organized securities market (at the choice of credit institutions) .

In the coming years, the Bank of Russia plans to use the required reserve ratios (reserve requirements) as a direct instrument for regulating the liquidity of the banking sector of the Russian Federation. At the same time, the Bank of Russia does not exclude the possibility of a further increase in the required reserve averaging ratio in order to maintain the liquidity of credit institutions when they meet the required reserve requirements.

Decisions regarding changes in the level of required reserve ratios and their differentiation will be made by the Bank of Russia based on the current macroeconomic situation and the state of liquidity in the banking sector. At the same time, the actions of the Bank of Russia in this area will be aimed not only at solving current problems, but also at ensuring economic stability in the medium term, which includes stabilizing the dynamics of external debt, restoring sustainable economic growth and limiting inflation rates.

IV. Main directions for improving banking regulation and supervision in the Russian Federation

The Government of the Russian Federation and the Bank of Russia proceed from the fact that the system of banking regulation and supervision over the activities of credit institutions in the Russian Federation should become more efficient in the coming years, and will direct efforts to bring it into line with international standards in this area.

It is planned to continue work on clarifying the powers of the Bank of Russia in accordance with international requirements for banking regulation and banking supervision, including the ability to assess the stability of credit institutions on an individual and consolidated basis and the powers to apply supervisory response measures.

Special attention will be paid to the identification and assessment of risks, including risks of a systemic nature, on a substantive basis and intensity of supervision based on risk-based approaches.

1. Weaknesses in banking regulation and banking supervision

The problems that emerged in the activity of the banking sector during the crisis testify to the shortcomings of banking regulation and banking supervision. The main disadvantage is the implementation of largely formal approaches in the implementation of banking supervision functions.

One of the reasons for this shortcoming is the limited legal capacity of the Bank of Russia to implement meaningful approaches to assessing the risks of credit institutions. To a significant extent, the legislation of the Russian Federation does not meet international standards in terms of the ability to exercise supervision on a consolidated basis and determine (in order to limit the concentration of risks) criteria for the relationship of borrowers to each other and the relationship of borrowers to a bank. Also, the list of supervisory response measures available to the Bank of Russia to shortcomings in the activities of credit institutions, banking groups and banking holding companies does not comply with international approaches to effective supervision.

In this regard, the Government of the Russian Federation and the Bank of Russia consider it necessary to strengthen the legal basis for the implementation by the Bank of Russia of banking supervision tasks. It is planned to introduce amendments to the legislation of the Russian Federation aimed at establishing the powers of the Bank of Russia to implement substantive regulation and supervision, supervision on a consolidated basis, to determine the composition of supervisory response measures and procedures for their application in accordance with international standards.

2. Requirements for corporate governance and risk management systems in credit institutions

The Government of the Russian Federation and the Bank of Russia proceed from the need to clarify the functions and competence of the board of directors (supervisory board) and executive bodies of a credit institution (within the framework of the Federal Law "On Banks and Banking Activities"), fixing the requirement to ensure that members of the executive bodies and of the board of directors (supervisory board) of their functions, including in relation to the organization of risk management systems, as well as on ensuring objectivity when the board of directors makes decisions on strategically important issues for the credit institution.

The problem of bringing the criteria for the business reputation of the heads and members of the board of directors (supervisory board) of credit institutions into line with international practice, as well as establishing the responsibility of the heads and members of the board of directors (supervisory board) involved in violations by the credit institution of the banking legislation of the Russian Federation and ( or) regulations of the Bank of Russia, which by their actions (inaction) contributed to a serious deterioration in the financial position of a credit institution, bringing it to bankruptcy and (or) revocation of a banking license.

To implement these approaches, it will be necessary to introduce amendments to legislative acts, which, among other things, provide for the empowerment of the Bank of Russia to make relevant demands.

3. Consolidated supervision, improvement of regulation of banking groups and banking holdings

Particular attention should be paid to the development of supervision over the activities of credit institutions on a consolidated basis. Increasing the effectiveness of consolidated supervision will be facilitated by increasing the degree of awareness of the banking supervisory authority, as well as financial market participants, about the organizational structure of banking groups and bank holding companies, about the risks they take and their ability to manage these risks. An essential element in building an effective consolidated risk management system in banking groups and banking holdings is the ability to transfer the necessary information by the participants of these associations to their parent organizations. In this regard, the Government of the Russian Federation and the Bank of Russia have prepared proposals to introduce appropriate amendments to the legislation of the Russian Federation.

An important prerequisite for improving supervision on a consolidated basis is the development of cooperation between the Bank of Russia and federal executive authorities authorized to supervise financial institutions that are part of banking groups and bank holding companies, as well as with foreign banking supervision authorities. The Government of the Russian Federation and the Bank of Russia are working to create conditions for more effective interaction between regulators.

4. Measures to improve the regulation and supervision of financial risks

The Bank of Russia will continue to work in the field of banking regulation and banking supervision aimed at improving the quality of banking capital and assets, limiting the level of risks, including the degree of their concentration, and increasing the cooperativeness and transparency of credit institutions.

The financial crisis has revealed the areas of activity of Russian banks that are most vulnerable in terms of their exposure to risk, including operations related to lending to the business of the owner (owners) of the bank, as well as operations with financial instruments, the prices of which are subject to increased volatility, and operations with borrowers whose activities are not transparent.

The crisis has demonstrated that aggressive policies lead to unmanageable risks. In this regard, the Bank of Russia will pay increased attention to balancing the policies of credit institutions, using, if necessary, systemic and (or) individual supervisory measures aimed at limiting unjustified activity.

One of the lessons of the crisis is that the increase in the concentration of risks is an independent factor that significantly reduces the stability of banks on an individual and systemic basis. In this regard, the Bank of Russia will have to implement measures to limit the concentration of financial risks in the activities of credit institutions.

The crisis also revealed that the quality of assets and the cost of collateral accepted by credit institutions are often overstated. In this regard, the Bank of Russia will work to create more conservative regulatory conditions for assessing the quality of collateral by credit institutions.

An important lesson of the crisis was that the increased level of risks taken by banks due to shortcomings in their business policies, as a rule, is accompanied by deliberate actions aimed at hiding the true state of affairs, manipulation of accounting and reporting data, as well as non-cooperative behavior of management and bank owners in relationships with the supervisory authority. In this regard, the lack of transparency in the activities of banks, including the opacity (lack of obvious economic sense) of ongoing operations and transactions, the opacity of counterparties and sources of income, is a significant sign of increased risks taken by the bank.

The Bank of Russia will take measures aimed at a more conservative assessment of risks in case of any manifestations of non-transparency in the activities of banks. The Bank of Russia will also develop comprehensive approaches to assessing the risks assumed by banks and the quality of their management.

5. Implementation in the Russian Federation of international approaches to financial regulation

The Government of the Russian Federation and the Bank of Russia will continue to work on implementing the Fundamental Principles for Effective Banking Supervision of the Basel Committee on Banking Supervision and on introducing into the practice of banking regulation and supervision the provisions of the document of the Basel Committee on Banking Supervision "International Convergence of Capital Measurement and Capital Standards: New Approaches", adopted in 2004, as well as the areas of financial regulation reform approved by the G20, including those included in the package of documents of the Basel Committee on Banking Supervision adopted in 2010. Directions and terms of implementation in the Russian Federation of international approaches to financial regulation are given in Appendix No. 1.

As part of improving the methodology for calculating capital adequacy, work will continue on the phased implementation of the provisions of the document of the Basel Committee on Banking Supervision "International Convergence of Capital Measurement and Capital Standards: New Approaches", which are an internationally recognized benchmark in the field of assessing the adequacy of own funds (capital) of banks, taking into account all significant risks and compliance with market discipline (disclosure) requirements.

As part of the fulfillment by the Russian Federation of the obligations assumed at the highest level to implement the decisions of the G20, the implementation of the proposals of the Financial Stability Board and the Basel Committee on Banking Supervision approved by the international community will be ensured. Work will be carried out in the following areas:

increased requirements for quality and capital adequacy;

increased liquidity requirements;

development of approaches to identify and assess systemic risks, analyze the systemic stability of the banking sector, use the information received for the purposes of individual and consolidated banking supervision and banking regulation, including macroprudential and countercyclical aspects;

development of reporting standards;

reforming the system of payments and remuneration;

cross-border aspects of financial recovery and bankruptcy of systemically important credit institutions.

The implementation of these areas will be carried out taking into account the specifics of the Russian economy and the characteristics of the banking sector.

6. Licensing. Procedure for investing capital

The Government of the Russian Federation and the Bank of Russia will consider improving the system for admitting capital to the banking services market and controlling the Bank of Russia over large acquisitions (more than 10 percent) of shares (stakes) in credit institutions. Particular attention will be paid to the compliance by investors with the requirements of the legislation of the Russian Federation. The Government of the Russian Federation and the Bank of Russia envisage the formation of a system of enforcement measures against investors who have made acquisitions in violation of the laws of the Russian Federation.

Work will continue to consolidate provisions in the legislation of the Russian Federation aimed at raising the requirements for the heads of credit institutions and their branches, at strengthening control by the Bank of Russia over the compliance of heads with the established requirements, as well as work to prevent the admission to participation in the capital of banks of persons with unsatisfactory financial position and business reputation, including the authority to control major acquisitions of shares (stakes) in credit institutions. It is required to carry out work on the legislative consolidation of the Bank of Russia's powers to process personal data and maintain databases.

In order to simplify the procedures for the placement of shares of credit institutions among a wide range of investors, measures will be taken to ensure favorable conditions for the public offering of shares, as well as to simplify the procedure for registering the issue of securities.

It is envisaged to prepare proposals for improving the legislation of the Russian Federation, which regulates the procedures for reorganization of credit institutions, aimed at eliminating obstacles in realizing the possibility of merging and taking over credit institutions of various organizational and legal forms.

At the current stage of development of the banking sector, it is planned to maintain the existing conditions for investing foreign capital, which presuppose an equal procedure for participation in the authorized capital of resident credit institutions with residents without providing the opportunity to open branches of foreign banks.

7. Transparency of credit institutions

An important tool for achieving systemic stability in the banking sector is to increase the transparency of the activities of Russian credit institutions and strengthen market discipline. This is one of the essential conditions for increasing confidence in the banking sector and increasing its investment attractiveness.

In order to increase the transparency of the banking system, the Government of the Russian Federation and the Bank of Russia will continue to improve the requirements for disclosure by credit institutions, banking groups and banking holding companies of information about their activities. The implementation of this task involves bringing these requirements closer to internationally recognized approaches, including the recommendations of the Basel Committee on Banking Supervision. In particular, it is planned to introduce amendments to the legislation of the Russian Federation that establish requirements for the disclosure by credit institutions, banking groups and bank holding companies of information on the amount of own funds (capital), as well as on the risks taken, procedures for their assessment and management.

In recent years, the situation with the transparency of the ownership structure of credit institutions has improved. Due to changes in the regulation of relations in the field of insurance of deposits of individuals in banks of the Russian Federation, information on the ownership structure of banks participating in the deposit insurance system has become available not only to the Bank of Russia as a supervisory authority, but also to citizens - consumers of banking services.

Further increase in the transparency of the ownership structure of credit institutions will also be facilitated by the development of the legal framework for the institute of affiliated persons of credit institutions. In particular, it is necessary to provide for a requirement for all affiliates of credit institutions to provide information about themselves and responsibility for failure to comply with this requirement. The establishment of these requirements is also necessary in order to prevent conflicts of interest when credit institutions carry out related party transactions.

It is also necessary to determine the mechanisms for ensuring control over the transparency of the ownership structure in the course of public offerings by credit institutions of shares outside the Russian Federation. The Government of the Russian Federation and the Bank of Russia, with the participation of the expert community, intend to study international experience in this area and prepare appropriate proposals.

It is necessary to legally regulate the obligation of shareholders and persons who indirectly (through third parties) have a significant influence on decisions made by the management bodies of a credit institution, including third parties, to provide the credit institution with information for disclosing the ownership structure, including if the credit institution's shares are from a nominal holder.

Measures to expand the obligation of credit institutions to disclose to an unlimited circle of persons information characterizing the professional qualifications and business experience of managers will serve to improve market discipline.

According to the Government of the Russian Federation and the Bank of Russia, the development by the banking community of sectoral transparency criteria, requirements and industry standards for the disclosure of information by credit institutions should become one of the important activities of Russian banking associations. For its part, the Bank of Russia, within the established competence, intends to participate in this work.

Ensuring the transparency of the activities of credit institutions and improving the system of financial reporting by public companies in accordance with International Financial Reporting Standards is one of the essential conditions for improving the efficiency of the banking services market and increasing confidence in the banking sector. In this regard, as part of the implementation of the provisions of the Federal Law "On Consolidated Financial Statements", starting from 2012, it is envisaged that all credit, insurance organizations, as well as other organizations whose securities are admitted to trading on stock exchanges and (or) other organizers of trading in the securities market, consolidated financial statements only in accordance with the specified standards.

8. Remote supervision

The Bank of Russia will continue to put into practice internationally recognized approaches to organizing remote banking supervision in the Russian Federation. Further development will be the use in remote supervision of the activities of credit institutions, banking groups and banking holding companies of meaningful approaches to the analysis of the situation in credit institutions, based on modern methods of analysis and assessment of risks significant for credit institutions, their level of concentration and quality of management.

In the process of organizing off-site supervision, the Bank of Russia will pay special attention to:

that credit institutions have modern corporate governance and risk management systems adequate to the nature and scope of their activities, which make it possible to identify, assess, monitor, control and limit all significant risks in a timely manner and determine the overall adequacy of own funds (capital) taking into account the risk profile of the credit institution;

the presence of proper control by the board of directors (supervisory board) and top managers over the activities of the credit institution, the quality of strategic and operational decisions made, the balanced conduct and stability of the business, the reliability of information published and provided to the control and supervision authorities;

assessment of the degree of transparency of the activities of credit institutions, including an assessment of the transparency of the ownership structure.

Work will continue to develop the methodology and practice of supervision, allowing to identify the emergence of problems in credit institutions at an early stage in order to take appropriate preventive and corrective measures and determine the regime for further supervision. Within the framework of supervisory work, approaches to the analysis of the reliability of enterprises in the non-financial sector of the economy will be improved in order to assess credit risks assumed by credit institutions.

As part of the implementation of risk-based approaches, the Bank of Russia will continue to use a differentiated regime for supervision of credit institutions, depending on their systemic significance, degree of transparency, business complexity, and compliance with regulatory standards. At the same time, the Government of the Russian Federation and the Bank of Russia proceed from the need to strengthen supervision, first of all, of systemically important banks. With this in mind, the Bank of Russia intends to implement a more efficient distribution of supervisory resources.

It is planned to form mechanisms for exercising additional control by the central office of the Bank of Russia over the situation in systemically important credit institutions, as well as its direct participation in supervisory activities. The Bank of Russia will also take measures to develop the institution of bank curators.

The listed approaches to the organization of banking supervision will be carried out in conjunction with the measures taken in all areas of supervisory activities (inspection, licensing, work with problem banks).

Taking into account the experience of authorized representatives of the Bank of Russia in credit institutions that received state support during the crisis, the Government of the Russian Federation and the Bank of Russia proceed from the expediency of using this institution in the future when exercising supervision in banks of systemic importance.

As part of the development of remote supervision, work will continue:

on the organization of supervisory boards for the activities of banking groups and banking holding companies, the parent organizations of which are Russian banks, including with the involvement of foreign supervisory authorities, if these groups include non-residents;

on developing the participation of the Bank of Russia in the work of supervisory boards for cross-border credit institutions;

on the creation of a legislative basis for interaction between the Bank of Russia and audit organizations conducting mandatory audits of the accounting (financial) statements of credit institutions.

9. Inspection

The inspection activity of the Bank of Russia will be focused on obtaining objective information about the financial condition (economic position) of credit institutions, determining the profile of risks and the main areas of their concentration, as well as identifying operations aimed at hiding the real quality of assets and formal compliance with regulatory requirements.

When planning and organizing inspections, special attention will be paid to banks of federal or regional significance and, as a result, having a significant impact on the systemic stability of the banking sector.

The study of transactions that generate the main risks will be carried out with a fairly high degree of detail, including with regard to assessing the activities of participants in these transactions, the legality of conducting, the correctness and timeliness of their reflection in the accounting and reporting of credit institutions.

In order to obtain more complete and reliable information about customers, borrowers and bank owners, including on issues of confirming the reliability of financial statements of borrowers and founders (participants) of credit institutions, the interaction of the Bank of Russia with tax, customs and law enforcement agencies will be improved.

In order to improve the quality of inspections based on the principle of unification, the improvement of practical approaches and procedures at all stages of inspection activities will continue.

It is envisaged to carry out a phased centralization of the inspection activities of the Bank of Russia, aimed at increasing the effectiveness of inspections and the efficiency of interaction between remote and contact supervision units, as well as specifying their areas of responsibility and more efficient maneuvering of inspection resources.

To ensure the continuity of the supervisory process, operational management of inspection activities will be carried out on an ongoing basis, one of the main elements of which is monitoring the organization and conduct of inspections.

With respect to credit institutions included in banking groups and banking holdings, it is planned to monitor and coordinate simultaneous inspections. This approach will allow supervisory divisions of the Bank of Russia to promptly obtain reliable (objective) and up-to-date information that will allow them to assess the level of risk on a consolidated basis, as well as the risks associated with the participation of credit institutions in banking groups and banking holding companies.

The introduction of elements of internal control aimed at improving the quality and effectiveness of inspection activities will continue.

10. Prevention of insolvency (bankruptcy) of credit organizations

Taking into account the positive experience in the implementation of procedures for the financial rehabilitation of credit institutions, the Deposit Insurance Agency should retain the relevant powers on an ongoing basis.

The practice of applying by the Bank of Russia and the Deposit Insurance Agency measures to prevent the bankruptcy of credit institutions makes it expedient to further improve the bankruptcy prevention mechanism. The most relevant is the expansion of incentives for private investors to participate in the prevention of bankruptcy of banks by providing the Bank of Russia with the opportunity to establish a special regime for the application of enforcement measures to credit institutions that implement financial recovery plans without attracting state funds, as well as clarifying the legal framework for the mechanisms for transferring property and liabilities of banks . In addition, it is necessary to establish the responsibility of persons having the right to give instructions binding on the bank or the ability to otherwise determine its actions (controlling persons), if the need to apply bankruptcy prevention measures arose as a result of guilty actions (omissions) of these persons.

As part of the G20 initiatives, the Bank of Russia will continue to monitor the development of risk mitigation and emergency financing plans by systemically important banks in order to ensure the continuity of their activities in a crisis, in accordance with the Principles of Interstate Cooperation on Crisis Management of the Financial Stability Board.

In order to improve the efficiency of the functioning of provisional administrations appointed by the Bank of Russia to credit institutions after the revocation of a license, it is advisable to introduce legislative changes, including by expanding the scope of participation of employees of the Deposit Insurance Agency in the work of provisional administrations, granting them the right of access to information constituting banking secrecy, and also by legislatively fixing the possibility for provisional administrations to conclude agreements with the Deposit Insurance Agency on the gratuitous performance of certain functions.

It is necessary to establish a mechanism for restricting by court decisions the rights to manage credit institutions of owners who, by their actions, contributed to the emergence of a threat to the interests of creditors and depositors in credit institutions.

The Bank of Russia, with the participation of banking associations and the involvement of the expert community, will continue to analyze international experience in the field of preventing the insolvency (bankruptcy) of credit institutions, as well as to study the possibilities of its application in Russian practice.

11. Control over the liquidation of credit institutions and protection of the rights of creditors

In order to protect the rights of creditors, the Government of the Russian Federation and the Bank of Russia will consider the need to prepare amendments to the legislation of the Russian Federation providing for a simplified procedure for the transition from the procedure for the compulsory liquidation of a credit institution to the procedure for its bankruptcy, including in terms of establishing creditors' claims.

In order to reduce risks for creditors, it is necessary to establish the duties of the head of a credit institution to ensure the safety of the electronic databases of the credit institution and create backup copies of them, as well as liability for failure to fulfill these duties.

The Government of the Russian Federation and the Bank of Russia also proceed from the fact that in order to protect the rights of creditors of credit institutions, it is necessary to establish liability, including criminal liability, for the head, as well as the person responsible for compiling and (or) submitting accounting and other statements, for entering into accounting , other accounting and reporting documents reflecting the economic activities of the credit institution, significant changes that distort their actual content, false information, as well as for the provision of incomplete or knowingly false information in order to conceal information about the actual financial position of the credit institution.

The Government of the Russian Federation and the Bank of Russia intend to consider other issues of improving the mechanism for bankruptcy and liquidation of credit institutions, including the use of a positively proven scheme for transferring household deposits to financially stable banks at the stage of liquidation of banks, as well as legislative issues to ensure the participation of employees of the Deposit Insurance Agency in the work temporary administrations.

V. Final provisions

In order to implement this Strategy, the Government of the Russian Federation and the Bank of Russia intend to implement the action plan, which is given in Appendix No. 2, which provides for measures to change the regulatory legal framework for banking activities in the Russian Federation, as well as to carry out a number of other measures aimed at developing and further improving relations in the banking sector.

In turn, the Government of the Russian Federation and the Bank of Russia count on support from the legislature, the banking and the entire business community in the implementation of the tasks stipulated by this Strategy.

Application No. 1

Russian Federation for the period up to 2015

Directions and terms of implementation in the Russian Federation of international approaches to financial regulation

The stage-by-stage work on the implementation of the provisions of the document of the Basel Committee on Banking Supervision "International Convergence of Capital Measurement and Capital Standards: New Approaches" (hereinafter - Basel II), consisting of 3 complementary components, is due to its concept, which provides for the possibility for the supervisory authority to choose different approaches to calculation of the values of financial and non-financial risks in order to determine the adequacy ratio of own funds (capital) of banks. Basel II assumes that such a choice depends on the level and dynamics of the development of the banking system and financial markets in which banks operate, as well as the state of the banking legislation of the state implementing Basel II.

The Bank of Russia currently uses the simplest approach to assessing credit risk - the simplified standardized approach of the 1st component "Minimum capital requirements" of Basel II.

Preliminary work is underway to prepare for the introduction of the approach set out in the 1st component of Basel II, which is based on independent intra-bank assessments of credit risk parameters (hereinafter referred to as the approach based on internal ratings). At the same time, minimum requirements are being developed for internal procedures for assessing the adequacy of own funds (capital) by credit institutions within the framework of the 2nd component "Supervisory Evaluation Process" of Basel II.

The assessment of the level of readiness of the Russian banking system for the introduction of an approach based on internal ratings and the implementation of the provisions of the 2nd component of Basel II was carried out as part of the cooperation program with the European Central Bank.

In order to implement Basel II, including the approach based on internal ratings, as well as its 2nd component, the Government of the Russian Federation and the Bank of Russia will work to introduce appropriate changes to the legislation of the Russian Federation.

At the same time, it is assumed that the circle of banks implementing the approach based on internal ratings will be very limited. This is due, among other things, to the high requirements for such banks in terms of the state of databases and intra-bank risk management systems.

Tentatively, the introduction of the 2nd component of Basel II can begin no earlier than 2014, and the approach based on internal ratings - after 2015.

As part of the implementation of new international requirements for the quality and adequacy of capital, maintaining the required level of liquidity, provided for by the documents of the Basel Committee on Banking Supervision adopted in 2010 (hereinafter referred to as Basel III), it is assumed:

revising the structure of regulatory capital by highlighting its key component - core capital (the total indicator of equity capital and retained earnings);

in addition to the minimum requirements for the adequacy of basic capital, the establishment of requirements for the formation of capital buffers (additional elements of capital, which are allowances for the minimum regulatory requirements for basic capital), in particular, a conservation buffer and a countercyclical buffer, which are a source of covering banks' losses in a crisis;

introduction, in addition to the capital adequacy ratio, calculated taking into account the level of risks assumed by banks, the "leverage" indicator, defined as the ratio of the amount of capital to the total amount of assets and off-balance sheet positions without taking into account the level of risk on them;

introduction of 2 liquidity ratios, determined taking into account the possibility of negative conditions both in the bank's activities and in the financial markets as a whole, - an indicator of short-term liquidity, defined as the ratio of liquid assets to net cash outflow in the next 30 days in the event of a general market tense situation with liquidity (stress situation), and the indicator of net stable funding, defined as the ratio of available stable sources of funding to the required funding (based on the liquidity characteristics of assets and off-balance sheet positions of the bank and its operations) for one year.

The implementation of the new Basel III regulatory standards in the area of capital and liquidity is expected to start in 2011 (the observation period for a number of standards) and be completed in 2018. Thus, the new regulatory standards will be fully effective from January 1, 2019.

At the same time, internationally agreed implementation stages are envisaged, which, among other things, include:

in terms of capital requirements - a phased introduction of requirements for the adequacy of basic capital and fixed capital (2013 - 2015);

in terms of the capital conservation buffer - a phased introduction of the requirement for the formation of the specified buffer (2016 - 2018);

in terms of the "leverage" indicator - the monitoring period (2011 - 2012), the period of parallel calculation of the indicator, during which the "leverage" indicator and its components will be compared with the capital requirements calculated taking into account the level of risks (2013 - 2017). As part of the parallel calculation of the indicator, information on its value and components is expected to be disclosed from January 1, 2015. The introduction of the leverage indicator as a mandatory one is planned from January 1, 2018;

in terms of liquidity standards:

indicator of short-term liquidity - the period of observation of the level of the indicator (2011 - 2014). The introduction of the indicator of short-term liquidity as a mandatory one is planned from January 1, 2015;

indicator of net stable funding - the period of observation of the level of the indicator (2012 - 2017). The introduction of the indicator of net stable funding as a mandatory one is planned from January 1, 2018.

Application No. 2
to the Banking Sector Development Strategy
for the period up to 2015

Action plan
for the implementation of the Strategy for the Development of the Banking Sector of the Russian Federation for the period up to 2015

		Implementation form	Implementation period	Responsible executors
I. Improving the competitiveness of the banking sector. Development of financial infrastructure. Reducing the costs of banking
1.	Development of the legislation of the Russian Federation on the national payment system	draft federal laws	adopted by the State Duma of the Federal Assembly of the Russian Federation in the 1st reading	Ministry of Finance of Russia Ministry of Economic Development of Russia FFMS of Russia with the participation of interested federal executive authorities and the Bank of Russia
2.	Implementation of measures aimed at the introduction of a universal electronic card of a citizen	normative legal acts	in accordance with the plan of measures necessary for the implementation of the Federal Law "On the organization of the provision of state and municipal services", approved by the order of the Government of the Russian Federation of September 2, 2010 No. 1433-r	Ministry of Economic Development of Russia with the participation of interested federal executive bodies, the Bank of Russia, state authorities of the constituent entities of the Russian Federation, the federal authorized organization
3.	Ensuring the immunity of central banks of foreign states and their property	draft federal law	year 2012
4.	Establishment of a ban on opening branches of foreign banks	draft federal law	in accordance with the terms of the entry of the Russian Federation into the World Trade Organization	Ministry of Finance of Russia Ministry of Economic Development of Russia Ministry of Foreign Affairs of Russia with the participation of the Bank of Russia
5.	Fixing transparent procedures related to the registration (accreditation) of representative offices of foreign banks in the territory of the Russian Federation and entrusting the Bank of Russia with the authority to register (accredit) them in accordance with the procedure established by it	draft federal law	year 2013	Ministry of Justice of Russia Ministry of Finance of Russia Ministry of Economic Development of Russia Ministry of Foreign Affairs of Russia FAS Russia with the participation of the Bank of Russia
6.	Improving the pledge legislation of the Russian Federation in terms of creating a system for registering notices of pledge	draft federal law	2011
7.	Providing banks with the opportunity to conclude a bank deposit agreement with a depositor who is an individual on terms that do not provide for the depositor's right to early demand of the deposit amount or part thereof or do not provide for his right to early presentation of a savings (deposit) certificate for payment	draft federal law	2011	Ministry of Finance of Russia FFMS of Russia Ministry of Economic Development of Russia with the participation of the Bank of Russia
8.	Introduction to the legislation of the Russian Federation of the concept of "metal account", including for individuals	draft federal law	2011	Ministry of Finance of Russia Ministry of Economic Development of Russia FFMS of Russia with participation of the Bank of Russia
9.	Improving the legal regulation of the activities of the bureau of credit histories and the Central catalog of credit histories	draft federal law	year 2012	Ministry of Finance of Russia Ministry of Economic Development of Russia FFMS of Russia with participation of the Bank of Russia
10.	Setting minimum standards for the provision of financial services	draft federal law	2011	Ministry of Finance of Russia Ministry of Economic Development of Russia Ministry of Health and Social Development of Russia FFMS of Russia FAS Russia with participation of the Bank of Russia
11.	Improving the regulation of issues of responsibility of an official of a credit institution for failure to fulfill obligations to control the implementation by economic entities of the procedure for conducting cash transactions	draft federal law	year 2012
II. Improving the quality of banking services
12.	Improving the legislation of the Russian Federation on consumer lending	draft federal law	2011	Ministry of Finance of Russia Ministry of Economic Development of Russia with the participation of the Bank of Russia
13.	Improving the legislation of the Russian Federation aimed at protecting the rights of borrowers from possible abuses by entities involved in debt collection	draft federal law	year 2012	Ministry of Economic Development of Russia Ministry of Finance of Russia FAS Russia with participation of the Bank of Russia
14.	Introducing amendments to the Code of Administrative Offenses of the Russian Federation in terms of unifying the approach to establishing administrative impact for violating the rights of consumers of financial services	draft federal law	2011	Ministry of Health and Social Development of Russia Ministry of Finance of Russia Ministry of Economic Development of Russia FAS Russia with the participation of the Bank of Russia
III. Improving banking regulation and supervision
15.	Improving approaches to determining the list of transactions subject to mandatory control, improving the mechanisms of a risk-based approach in identifying clients, client representatives, beneficiaries, expanding the grounds on which credit institutions have the right to refuse to conclude a bank account (deposit) agreement and execute a client’s order to conduct a transaction , as well as granting credit institutions the right to refuse to execute a bank account (deposit) agreement and clarifying the powers of supervisory authorities to control compliance by organizations engaged in transactions with funds or other property with certain requirements of the legislation of the Russian Federation in the field of combating the legalization (laundering) of income, proceeds of crime and financing of terrorism	draft federal laws	year 2012	Rosfinmonitoring Ministry of Finance of Russia Ministry of Economic Development of Russia FFMS of Russia with participation of the Bank of Russia
16.	Improving the legislation of the Russian Federation in terms of specifying the requirements for managers and founders (participants) of a credit institution, granting the Bank of Russia the authority to monitor the compliance of these persons with the established requirements, collect information about their business reputation, maintain relevant databases, process and maintain personal data, as well as reducing the circle of heads of branches of credit institutions requiring approval from the Bank of Russia	draft federal law	2011	Ministry of Finance of Russia Ministry of Economic Development of Russia with the participation of the Bank of Russia
17.	Improving the legislation of the Russian Federation in terms of expanding the powers of the Bank of Russia to apply enforcement measures against credit institutions for identified shortcomings in their corporate governance systems, the application of enforcement measures to managers and owners of credit institutions, including measures recommended by the Basel Committee on Banking Supervision	draft federal law	year 2012	Ministry of Finance of Russia Ministry of Economic Development of Russia FFMS of Russia with participation of the Bank of Russia
18.	Providing legal conditions for the organization of consolidated banking supervision and disclosure by credit institutions, banking groups and banking holding companies of information about their activities in accordance with international experience in this area, including supervision of risks arising from the relationship of credit institutions with their related persons	draft federal law	submitted to the State Duma of the Federal Assembly of the Russian Federation	Ministry of Finance of Russia Ministry of Economic Development of Russia FFMS of Russia with participation of the Bank of Russia
19.	Ensuring unified supervisory requirements for assessing the stability of credit institutions and requirements for participation in the deposit insurance system based on international principles of supervision and application of enforcement measures	draft federal law	year 2012	Ministry of Finance of Russia Ministry of Economic Development of Russia with the participation of the Bank of Russia
20.	Creation of a legislative basis for the implementation of the recommendations of the Basel Committee on Banking Supervision, including granting the Bank of Russia the right to establish for credit institutions the rules for managing risks and capital, the use of intra-bank risk assessment methods, as well as establishing the responsibility of members of the executive bodies and the board of directors (supervisory board) for the activities of credit institutions , including in the field of risk management	draft federal law	year 2012	Ministry of Finance of Russia Ministry of Economic Development of Russia FFMS of Russia with participation of the Bank of Russia
21.	Introducing amendments to the legislation of the Russian Federation in terms of simplifying the procedure for issuing securities by credit institutions, as well as ensuring control over large purchasers of shares (stakes) in a credit institution by the Bank of Russia in accordance with international experience	draft federal law	2011	Ministry of Finance of Russia Ministry of Economic Development of Russia FFMS of Russia with participation of the Bank of Russia
22.	Improvement of procedures for reorganization of credit institutions	draft federal law	year 2012
23.	Establish requirements for affiliated persons of credit institutions to provide information about themselves and the procedure for disclosing information about these persons	draft federal law	year 2013	Ministry of Economic Development of Russia Ministry of Finance of Russia FFMS of Russia with participation of the Bank of Russia
24.	Establishment in the legislation of the Russian Federation of norms providing for the obligation of shareholders and persons indirectly (through third parties) exerting a significant influence on decisions taken by the management bodies of a credit institution, including third parties, to provide the credit institution with information for disclosing the structure of ownership, including in the event of if the shares of a credit institution are held by a nominal holder	draft federal law	year 2012	Ministry of Finance of Russia Ministry of Economic Development of Russia FFMS of Russia with participation of the Bank of Russia
25.	Creation of legal conditions for interaction between the Bank of Russia and audit organizations	draft federal law	2011	Ministry of Finance of Russia Ministry of Economic Development of Russia FFMS of Russia with participation of the Bank of Russia
26.	Amendments to federal laws in terms of assigning to the state corporation "Deposit Insurance Agency" on a permanent basis the functions of financial rehabilitation of banks and clarifying the mechanisms for their implementation, improving the procedures for preventing bankruptcy and liquidating credit institutions, increasing the responsibility of bank managers for illegal actions in bankruptcy, as well as the establishment of legislative norms aimed at protecting the funds of the mandatory deposit insurance fund from dishonest actions	draft federal law	2011	Ministry of Economic Development of Russia Ministry of Finance of Russia with the participation of the Bank of Russia
27.	Establishment of criminal liability for the introduction of significant changes in accounting, other accounting and reporting documents reflecting the economic activities of a credit institution, false information that distorts their actual content, as well as the submission of incomplete or deliberately false information in order to conceal information about the actual financial position of a credit institution	draft federal law	year 2012	Ministry of Economic Development of Russia Ministry of Finance of Russia Ministry of Internal Affairs of Russia with the participation of the Bank of Russia
28.	Establishing the possibility of appointing Bank of Russia employees as authorized representatives to credit institutions that are significant for the banking system and the economy of the Russian Federation	draft federal law	2011	Ministry of Finance of Russia Ministry of Economic Development of Russia with the participation of the Bank of Russia
29.	Improving the legislation of the Russian Federation in terms of increasing the minimum amount of the authorized capital and equity (capital) of banks	draft federal law	2011	Ministry of Finance of Russia Ministry of Economic Development of Russia with the participation of the Bank of Russia
30.	Improving the legislation of the Russian Federation in terms of establishing the obligation of credit institutions to disclose to an unlimited circle of persons information on the professional qualifications and business experience of managers	draft federal law	year 2012	Ministry of Finance of Russia Ministry of Economic Development of Russia with the participation of the Bank of Russia

Statement of the Government of the Russian Federation and the Central Bank of April 5, 2011 “On the Strategy for the Development of the Banking Sector of the Russian Federation for the period up to 2015”

The text of the statement is posted on the website of the Ministry of Finance of the Russian Federation on the Internet (http://www.minfin.ru)

Document overview

It has been determined how the Russian banking sector will develop for the period up to 2015.

In the medium term, it is proposed to reduce the participation of the state in the capital (while maintaining control over the activities) of Sberbank, VTB and Rosselkhozbank.

It is planned to legislatively determine the conditions for the functioning of the national payment system. The procedure and terms for the withdrawal of the CBR from the number of shareholders of CJSC MICEX will be fixed.

It is planned to establish the minimum amount of the authorized capital of newly created banks from January 1, 2012 and the minimum amount of own funds operating from January 1, 2015 in the amount of 300 million rubles.

It is planned to stop issuing and gradually withdraw from circulation 1- and 5-kopeck coins while maintaining them as a calculation tool. In addition, it is planned to delegate some of the CBR's powers to organize the circulation of cash to banks.

It is possible that the circle of subjects covered by the protection provided by the deposit insurance system will be expanded at the expense of individual entrepreneurs.

It is envisaged to improve the system of admission of capital to the banking services market and the Central Bank's control over major acquisitions of shares (stakes) in credit institutions. It is planned to increase the requirements for the heads of credit institutions. It is planned to simplify the registration procedures for the issue of securities.

It is planned to increase the transparency of credit institutions, in particular, by establishing a requirement to disclose information on the amount of own funds, as well as on the risks taken, the procedures for their assessment and management.

In order to implement international approaches to financial regulation, the terms for the introduction of new regulatory standards "Basel II" and "Basel III" are also determined.

It is assumed that by the beginning of 2016 the banking sector will achieve the following indicators: assets to GDP - more than 90% against 76% as of January 1, 2011, capital to GDP - 14-15% against 10.6% as of January 1, 2011 ., loans to non-financial organizations and individuals to GDP - 55-60% against 40.8% at the beginning of 2011.

FINANCE, CREDIT, INSURANCE

UDC 336.01 A. V. Kanaev

CONCEPTUAL ISSUES OF THE DEVELOPMENT STRATEGY OF THE RUSSIAN BANKING SYSTEM

First decade of the 21st century marked by the increased interest of government financial bodies, official departments and the business community, initially in the strategic aspects of reforming the banking system (until 2005), and then, as it strengthens, in finding ways and means for further development. The determining factor was the transition of the Russian economy to the stage of economic growth, which affected all socio-economic processes and determined Russia's return to the "league" of the world's leading countries. These circumstances led to the intensification of scientific research on the development of the conceptual foundations of banking strategic management, and also accelerated the preparation and publication of practical policy documents that determine the goals, directions and mechanisms for implementing the strategy for the development of the Russian banking system1.

1 Such documents include: “Strategy for the Development of the Banking Sector of the Russian Federation” (2001) and “Strategy for the Development of the Banking Sector of the Russian Federation for the Period up to 2008” (2005), “The Strategy for the Development of the Banking Sector of the Russian Federation for the Period until 2015” (2011); developments of the Association of Russian Banks "Strategy for increasing the competitiveness of the national banking system of the Russian Federation" (2005) and the program "National banking system 2010-2020" (2006); report of the First Deputy Chairman of the Bank of Russia A. A. Kozlov "Scenarios for the development of the Russian banking system for 2001-2015" (2001), as well as a series of strategic reports, scenarios and analytical materials: "The banking system of Russia in the context of the global economic crisis" (report at a meeting of the Academic Council of the Institute of Economics of the Russian Academy of Sciences, 2009), "Proposals for the development strategy of the banking sector for 2010-2012 ." (Association of Regional Banks of Russia together with the rating agency "Expert RA", 2009), "Banks in the post-crisis economy: Russia and international practice" (Association of Regional Banks of Russia and the consulting group "Banks. Finance. Investments", 2010), "Strategy of financial ensuring and innovative growth of the economy

Alexander Vladimirovich KANAEV - Doctor of Economics in Economics, Professor, Department of Credit Theory and Financial Management, Faculty of Economics, St. Petersburg State University In 1978, he graduated from the Faculty of Economics, Leningrad State University. In 1987, he defended his Ph. In 1978-1992 worked in various research and higher educational institutions, in 1993-2001. - in a number of commercial banks in St. Petersburg. He completed an internship in foreign banks in Hungary, Great Britain and Germany. Since 2001, he has been working at St. Petersburg State University. Research interests - theory of credit, monetary policy, banking in Russia and abroad, management of commercial banks. Author of more than 30 publications.

An analysis of the content of these documents allows us to conclude that significant progress has been made in the field of strategic banking management over the past decade. To date, practical experience has been accumulated in solving a number of strategic tasks as part of the implementation of official strategies for the development of the banking system (2001 and 2005) and a theoretical and methodological basis has been formed for solving the most pressing problems in this area. At the same time, a number of conceptual issues relating to the fundamental theoretical and practical aspects of the development and implementation of the strategy remain the subject of extensive discussion and require further development. The present article is devoted to the search and formulation of such key questions that form "intellectual forks". At the same time, the author of the article shares the attitude of the English researcher Richard Koch, who wrote: “Novelty in strategic thinking seems to be much less important than the synthesis of what is already known, with a clear understanding of the conditions of application and compromises between different approaches...” .

Strategies and concepts

Since the mid-80s of the 20th century, the initially purely military strategic ideas began to penetrate deeply into management theory and practice. This influence affected the formation of a new scientific direction, called the theory of strategic management (management). At the same time, the relative "youth" of this discipline is manifested in the difficulties that accompany the implementation of its basic provisions and principles in the management practice of companies, banks and government agencies. Some of them are purely theoretical in nature and are determined by the complexity and versatility of this managerial phenomenon, which is reflected in the existence of numerous and often opposite interpretations of strategy and strategic management. There are problems that are terminological in nature, associated both with the frequent substitution of the concepts of "strategy" and "concept", and with the variety of their definitions.

At the same time, we should note a number of fruitful, in our opinion, attempts to establish a clear subordination of these fundamental concepts and give their meaningful economic and managerial characteristics. Indeed, in the “State Strategy for the Economic Security of the Russian Federation” (approved by Decree of the President of the Russian Federation of April 29, 1996 No. 608), it was noted that this document develops and specifies the relevant provisions of the National Security Concept of the Russian Federation. The latter is a "system of views on ensuring the security of the individual, society and state in the Russian Federation."

(state, development forecast)" (edited by Ya. M. Mirkin, 2010), "Structural modernization of the financial system of Russia" (Institute of Contemporary Development and the Bank of Moscow, 2010), "Banking system of Russia 2011: trends and priorities of post-crisis development" (Association of Regional Banks of Russia and consulting group "Banks. Finance. Investments", 2011), "The challenge of the decade: the quality and availability of banking services" (Association of Russian Banks, 2011), strategic scenarios for the balanced development of the Russian banking system, developed by the team of the Center for Macroeconomic Analysis and Short-Term Forecasting (CMASF) and employees of the State University-Higher School of Economics in 2010-2011. Currently, strategic studies are being conducted by members of the expert group "Development of the financial and banking sector" as part of the preparation of proposals for improving the Strategy 2020.

states from external and internal threats in all spheres of life. This Concept formulates the most important directions of the state policy of the Russian Federation” . These documents emphasize that the implementation of the state strategy should be carried out through a system of specific measures implemented on the basis of qualitative indicators and quantitative indicators - macroeconomic, demographic, foreign economic, environmental, technological, etc.

Obviously, by the mid-1990s, the foundations of the methodology of strategic planning in the field of national security had been laid. It turned out to be in demand at the height of the crisis, which was reflected in the “National Security Strategy of the Russian Federation until 2020” published in 2009 (approved by Decree of the President of the Russian Federation of May 12, 2009 No. 537). According to paragraph 3 of this document, the adopted strategy is an officially recognized system of strategic priorities, goals and measures in the field of domestic and foreign policy that determine the state of national security and the level of sustainable development of the state in the long term. The conceptual provisions in the field of ensuring national security are based on the fundamental interconnection and interdependence of the Strategy 2020 and the "Concept for the long-term socio-economic development of the Russian Federation for the period up to 2020" (approved by order of the Government of the Russian Federation of November 17, 2008 No. 1662-r). Paragraph 4 notes that Strategy 2020 is the basic document for planning the development of the system for ensuring the national security of the Russian Federation, which sets out the procedure for actions and measures to ensure national security.

A similar methodology is contained in the “Transport Strategy of the Russian Federation for the period up to 2030” (approved by Decree of the Government of the Russian Federation of November 22, 2008 No. 2009 No. 1715-r). The latter defines the goals and objectives of the long-term development of the country's energy sector for the coming period, priorities and guidelines, as well as the mechanisms of the state energy policy at certain stages of its implementation, ensuring the achievement of the goals set. "Energy strategy." forms new guidelines for the development of the energy sector as part of the transition of the Russian economy to an innovative development path, provided for by the Concept 2020.

Thus, we can conclude that modern official strategic developments relating to the development of the most significant infrastructure sectors and sensitive functional areas of state policy reflect the most important principles of organizing strategic management and planning formulated by economic science. They clearly fix the relationship and interdependence (subordination) of management processes: state policy - the concept of development - strategy - a system of measures, mechanisms and plans.

As for the development strategy of the Russian banking system, the situation here is completely different. None of the three adopted versions of the official strategy (2001, 2005 and 2011) corresponds in form and content to the “format” of strategic developments. The main claim to the adopted documents is the lack of clearly defined goals, objectives, a system of priorities and adequate target

indicators, resource provision, as well as criteria for solving problems, the timing and stages of the implementation of strategic measures and initiatives. In addition, we can talk about the lack of continuity in the formation of a common ideology for the development of the sector, its strategic vision. For example, in 2005 the Government of the Russian Federation and the Bank of Russia proceeded from the fact that one of the priorities of the state economic policy is the formation of a competitive Russian banking sector capable of developing on its own basis. Such development should have made it possible already at the next stage (2009-2015) to define as a priority the effective positioning of the Russian banking sector in the international financial markets. In the 2011 strategy, everything is much more modest - the main goal of the sector's development in the medium term is to actively participate in the modernization of the economy based on a significant increase in the level and quality of banking services provided to organizations and the population, and ensure its systemic sustainability.

The noted shortcomings of strategic developments, the inconsistency and non-realism of their goals, in our opinion, indicate the need for a radical change in the very process of organizing strategic management in the industry. To this end, despite the ongoing disagreements between representatives of banking associations, government agencies, analysts and experts regarding the scenarios for the development of Russian banks, serious work will have to be started to develop a common view on the content of the concept of the banking sector development strategy. It is important to determine the vision of the future of Russian banks, their prospective image and formulate strategic priorities for the development of the sector. Then there will be hard work to build the entire "strategic composition" up to specific plans and programs, as well as to create an effective system for managing the implementation of the strategy.

The platform for developing a banking strategy should be the concept of Russia's national strategy - "a set of key ideas, views, principles that give a holistic view of possible scenarios for the development of society" . The unity and complementarity of these concepts are determined by the fact that both of them are a set of fundamental views on goals, priorities, the formation of resources, methods of action and the organizational mechanisms that ensure them.

Another option for moving through a real-life "fork" that determines the choice of the nature and directions of the intellectual efforts of the country's monetary authorities, expert and business communities, leads to the formation of a tradition of declarative messages (directives), which is fraught with a transition to a strategic "drift" mode with its costs and risks. . And this is a very likely choice, since a number of authoritative experts are sincerely convinced that “it is wrong to demand a specific and clear action plan from the strategy, since such documents are intended to express political will and a vector of development direction” (quoted from:).

Strategic goals and objectives

The above position of the banking ombudsman P. A. Medvedev is shared not only by many experts, but also by the heads of state financial structures. At the same time, most of them are adherents of active

economic policy formulated in the "Concept of long-term socio-economic development of the Russian Federation for the period up to 2020". Recall that it sets the goal of achieving a level of economic and social development corresponding to Russia's status as a leading world power in the 21st century, occupying leading positions in global economic competition and reliably ensuring national security and the exercise of the constitutional rights of citizens: in 2015-2020. Russia should enter the top five countries in terms of gross domestic product (purchasing power parity).

A good example of the complementarity2 of attitudes is the strategic vision of the development of the transport industry: “In the transition to an intensive, innovative, socially oriented type of development, the country seeks to become one of the leaders in the global economy, which requires making adequate strategic decisions on the development of the transport complex in the long term. At a new stage, the transport strategy should determine the active position of the state in creating conditions for socio-economic development, primarily in order to improve the quality of transport services, reduce the total costs of society dependent on transport, increase the competitiveness of the domestic transport system, strengthen innovative, social and environmental orientation development of the transport industry".

Formally, the goals of the country's long-term development correspond to the task of transition in 2015 to a predominantly intensive banking sector development model, formulated in the latest version of the banking system strategy. This model is characterized by the priority of qualitative indicators and the orientation of banks' activities towards long-term efficiency. However, this attitude cannot be recognized as adequate for the goal of achieving the country's global leadership. And the point is not that in practice the extensive business model has already exhausted its potential. Something else is important. At the time of overcoming the crisis (2009), the ratio of bank assets to GDP in Russia was 75.4%, Belarus - 78.3, Slovakia - 83, Poland - 85, Bulgaria and Lithuania - 103 each, the Czech Republic - 110, Estonia - 238, Germany - 351, Great Britain - 616%. The ratio of bank capital to GDP in Slovakia was 6.6%, Poland - 6.7, Czech Republic - 7.3, Belarus - 10.8, Russia - 11.8, Italy - 14.4, Sweden - 18.5, Spain - 23.9%. The above data clearly show that Russian banks will have to build up their potential for more than a year, using the entire arsenal of extensive and intensive sources of growth.

The probable reason for the inadequacy of the strategic intentions of the developers of banking strategies, in our opinion, is the underestimation of the factors that determine the main priorities for the development of the industry.

Challenges and threats. In the theory of strategic management, concretization of strategic intentions in the form of goals and objectives involves an analysis of the internal and external environment, known as SWOT analysis. In practice, in recent years, another variant of identifying strategic

2 By complementarity of goals (tasks), we mean the presence of complementarity and mutual correspondence between them, which provides additional effects from their achievement (solution). For example, investment projects are interconnected by complementarity relations if the adoption of a new project contributes to an increase in income from one or more other projects.

factors influencing strategy development - analysis of internal and external challenges. So, in the "Energy Strategy." It is explicitly stated: "The need for an adequate response to the most important internal and external challenges of long-term development, combined with the existing problems in the energy sector, forms the goals and objectives of this Strategy" .

The Concept 2020 formulates the main directions of the country's long-term socio-economic development, taking into account long-term systemic challenges. They reflect both global trends and internal development barriers:

Strengthening global competition, covering not only the traditional markets for goods, capital, technology and labor, but also the systems of national governance, innovation support, and human development;

The emergence of a new wave of technological changes that enhance the role of innovation in socio-economic development and reduce the influence of many traditional factors of growth;

Increasing role of human capital as the main factor of economic development;

Exhaustion of the potential of the raw material export model of economic development based on the forced increase in fuel and raw material exports.

With regard to the national banking system, the list of internal barriers must be substantially supplemented by threats to its long-term sustainable development. In a broad sense, a threat is not only potential negative (from the standpoint of national interests) impacts, but also existing processes and factors that undermine the stability of the economy and are capable of causing some damage to it at a certain point in time. More briefly, threats can be defined as a set of conditions, factors and processes (actions) that have or may have a destabilizing effect on the functioning and development of the banking system, hinder or may hinder the realization of national interests in this area.

Threats to the sustainable development of the banking system are complex. The latter reflects the interdependence of negative macroeconomic factors and specific difficulties in the development of the banking system proper. The existence of the latter is due to:

The previous state and spontaneous adaptation of the Russian economy to the financial policy of macroeconomic stabilization and monetary restrictions (restrictions) of the mid-1990s;

The underdevelopment of the national banking system, caused by the initial deformations of its formation and subsequent post-crisis reform (instability, weak connection with the real sector, dependence on the commodity sector, etc.);

The impact of external financial crises and shocks.

It is important to note that the long-term persistence of internal threats without an effective economic policy makes the domestic banking system more vulnerable to external threats. The influence of the latter also lies in the fact that many internal threats are hidden (latent) in nature and can only manifest themselves

under the influence of external crisis impulses (shocks). Indeed, the events associated with the development of the recent financial crisis made it possible to clearly identify a number of weaknesses in the national banking system and strategic (large-scale and long-term) threats to its sustainable development, the consideration of which is a necessary condition for developing a banking strategy. Let's briefly consider their nature.

Dysfunctionality of the banking system. The main problem in the development of the Russian banking system is the discrepancy between its ability to transform savings into investments and the significant scale of domestic savings, as well as the high and expanding needs of the Russian economy for investments. The result was a growing shortage of long-term financial resources, which does not allow Russian banks to provide a long-term loan offer at a level adequate to the needs of the economy. The share of bank loans in the structure of sources of financing for capital investments of enterprises is unsatisfactorily small - in the "fat" year 2008 it reached a historical maximum and amounted to only 11.8% (including foreign loans - 3.0%), while in the USA - 40 %, in the EU on average - 42-45%, in Japan - 65% (data as of the end of 2005). The share of loans in the structure of all financial investments of organizations (excluding small businesses) is slightly more - 15% (including foreign - 9.7%).

At the same time, 48% of loans were issued for a period of up to 1 year, 28% - from one year to three years, 24.2% - over 3 years, less than 10% - over 5 years. In Europe, the opposite is true: 51.6% of loans are issued for a period of more than 5 years. The current situation is a natural result of the predominance of short-term and ultra-short-term funds in the liabilities of Russian banks. Funds for up to one year make up more than 60% of balances on accounts and deposits in Russian banks, for up to three years - 95%. The future shortfall of banks' long-term liabilities required to offer long-term credit is estimated at 5% of GDP by 2012.

Another important manifestation of the dysfunctionality of the banking system is its general inadequacy to the size of the real sector of the national economy and the level of concentration of capital. Suffice it to say that in 2009 Russia ranked 12th in terms of GDP in the world, but ranked only 20th in terms of the ratio of assets of its banking system to GDP. For comparison: 10th in terms of GDP, Canada ranks 12th in the world banking ranking. Another important fact is that the assets of Russian banks in 2009 (924 billion euros) were more than one and a half times (1.56) less than the assets of Austrian banks and almost three times (2.92) less than the assets of Canadian banks.

Dispersion of bank capital. The dysfunctionality of the banking system is largely determined by the dispersion of banking capital. This problem is related to the high dispersion of bank capital, which does not allow Russian banks to accumulate resources to finance large projects. Thus, the average value of the assets of a Russian bank (excluding Sberbank) is $0.1 billion versus $4 billion in South Korea, $5 billion in the UK and $45 billion in Japan.

In general, the inadequate level of concentration of the system is determined by two factors: the relatively small size of the market leaders (except for Sberbank and VTB) and the presence of a vast “field” of banks with assets of less than 5 million euros (40% of all banks as of 01.01.2011). Banks ranked lower in the rating of the national system

200th (total number of banks - 1012), together they are the owners of 5% of assets, 5% of loans to organizations and 8% of the capital of the system.

This dispersal of capital makes the national banking sector practically uncompetitive in financing major transactions involving Russian companies. Therefore, large Russian enterprises, primarily those of the fuel and energy complex, are forced to carry out a significant share of the borrowings necessary to finance their current activities and investments abroad.

Fragmentation of the financial system and its dependence on foreign markets. Another serious strategic threat to the development of the Russian system is the continued fragmentation of the domestic financial system, which contributes to the process of institutionalization of the spontaneous two-loop model of financing the economy. The latter includes: a) the national financial sector - the accumulation of short-term resources serving the current turnover, financing investments in working capital; b) foreign financial sector - accumulation of long-term savings, financing of investments in fixed assets and transactions with capital assets.

The reasons for the formation of such a model were low interest rates on international credit markets, an increase in the credit ratings of Russia and the largest domestic companies, the strengthening of the ruble, as well as the continuing disproportionate development of the banking and non-financial sectors of the Russian economy. At present, loans to the Russian non-financial sector, provided by Russian and foreign banks, correlate approximately as 61 to 39 - respectively 463, 4 and 291.3 billion dollars. At the same time, at the beginning of 2011, external loans of the banks themselves reached 144.8 billion dollars. A similar situation arose in the interbank market, where the share of loans attracted from non-resident banks in the total volume of interbank loans increased from about 70% at the beginning of 2005 to 80% by the beginning of 2008. The crisis corrected the state of affairs in the credit foreign exchange markets , but did not remove the problem of dependence on foreign loans. In a way, she even got worse.

Thus, according to a study conducted by Deutsche Bank, the level of external debt of Russian companies and banks is comparable to Turkey, but twice as high as that of India and Brazil, and almost 5 times higher than that of China. In the second half of 2010, corporate external debt increased by 6.6% to $436.2 billion: banks - by 18.6% to $144.8 billion, companies - by 1.5% to $291.3 billion. about 30% (134 billion) were occupied by state-owned banks and corporations. About 20% of all corporate debt in Russia is held by Gazprom, Rosneft and VTB. The five largest Russian debtors included Russian Railways OJSC and Rosselkhozbank.

Strategic dead end. Thanks to external financing, domestic enterprises and banks will be able to mobilize long-term resources for the modernization of the economy. However, the strengthening of the economic role of the two-loop model in the context of further liberalization of the services market and the openness of the Russian financial system, as foreign competitors emerge from the crisis, will inevitably be accompanied by increased external competitive pressure and, as a result, stagnation of the national banking sector and an increase in the dependence of the Russian economy on the situation of external financial markets. . Position-

The situation is exacerbated by the low starting parameters for the development of domestic banks.

Indeed, the analysis of the integral indicators contained in the report "Global Competitiveness in 2010-2011" shows that in terms of the main factors characterizing the operation of the financial system (financial market development), Russia is in 125th place out of 139 countries. So, in terms of the level of business processes (business sophistication), it got only 101st place, in terms of the availability of financial services in the market (availability of financial services) - 109th, in terms of soundness of banks (soundness of banks) - 129th, in availability of financial services (affordability of financial services) - 92nd and ease of access to loans - 107th place. In 2010, according to The Financial Development Index, Russia was ranked 40th out of 57 countries in the overall rating (in 2009 it had the same 40th position). Other BRIC countries took the following places: China - 22 (26th), Brazil - 32 (34th), India - 37 (38th) (for comparison: Canada - 6th, Austria - 19th, Czech Republic - 33rd, Poland - 35th, Slovakia - 36th).

From the analysis carried out, the following conclusions can be drawn:

1) the level of development of the domestic banking system is inadequate to the level of concentration of domestic capital and does not correspond to the economic potential and geopolitical position of Russia in the world. In many respects, the domestic banking system lags behind the banking systems of a number of countries in Eastern Europe and the CIS, which not only makes it difficult to solve the problems of the country's socio-economic development, but also creates a threat to the country's economic security. Obviously, in modern conditions, the question of the further development of the banking system has gone beyond the scope of the industry and has acquired the character of a geopolitical problem;

2) the nature and sources of the pre-crisis development of the Russian economy, the availability of financial and innovative potentials, as well as the determination and political will of the country's leadership retain the ability to form a sovereign banking and financial system capable of independently transforming national savings into investments and providing conditions for sustainable long-term economic growth for innovative basis;

3) for a qualitative change in this area, it is necessary to abandon the currently implemented strategy of inertial development and move to an alternative option by developing new strategic decisions aimed primarily at creating a competitive Russian banking sector capable of developing on its own basis. Therefore, all variants of the proposed scenarios for the development of the Russian banking system should be developed as scenarios for overcoming the strategic "dead end" formed by established and steadily functioning institutions of inertial development;

4) first of all, we have to go through an important intellectual "fork" related to the choice of development goals, its priorities and target indicators. Achieving consensus in this area will significantly accelerate the development and implementation of truly effective strategic decisions.

While formulating the goals and objectives of the strategy, we should not forget about the most important feature of strategy as a managerial phenomenon. Strategy in any field of activity retains its ancestral connection with the military field, which is characterized by a clash of antagonistic, purposeful, provided with the necessary

resources and long-term volitional aspirations and actions of opponents (opponents). This relationship is reflected in the definition of the subject of the theory of strategic management (management), the specifics of its conceptual system - the study of the nature of the competitive advantage of the company, the means by which it can be achieved and maintained.

Such an understanding of the competitive nature of the strategy makes it possible to determine the goal of the upcoming movement along the trajectory of innovative and socially oriented development in relation to the banking system as Russia's entry into the top 20 countries in terms of the integral indicator of the development of the financial sector and into the 50 most competitive countries in the world in terms of the level of development of the financial system. It is this goal that is complementary to the priorities and guidelines of the Concept 2020 and reflects the interests of the country's economic security.

Financial authorities and banking stakeholders

The effectiveness of strategic management is largely determined by the active participation in the development of companies of their stakeholders, called stakeholders. This central position of the theory of strategic management is applicable both to an individual bank and to the national banking system as a whole. In the latter case, the circle of stakeholders expands significantly both in terms of the number and composition of participants. These include: clients (borrowers and lenders), regulators and government agencies, regional authorities and the banking community, and the general business community. According to the modern interpretation (often called investment), stakeholders are “individuals or clientele who contribute, intentionally or unintentionally, to the activities of the corporation and its economic potential (wealth-creating capacity) and therefore are potential beneficiaries of the corporation and / or accept bear its risks."

It is important to note that the vast majority of representatives of higher education and academic science, banking analysts and independent experts are borrowers or creditors of domestic banks, i.e. their real investors, and should be able to participate in one way or another in monitoring the activities of the banking system. Financial authorities, and above all banking regulators, are also stakeholder-investors, since they make specific non-capital-intensive investments in the formation of mechanisms for prudential regulation and supervision and may be exposed to serious reputational risk in case of poor performance of their functions.

Different categories of stakeholders differ in the level of their influence on the development of companies and banks. The latter, according to the model proposed by A. Mendelow, is associated with two factors - the power and interest of the stakeholder. The power of a stakeholder is determined by his ability to influence the organization, and his interest - the desire to influence the organization. It seems to us that for a stakeholder-investor, the interest will be directly proportional to the risk of his investments, which determines the desire to control their use. Hence the desire to strengthen positions of power even with a stable amount of investment.

In other words, the influence formula should look like this:

stakeholder influence = power x interest (risk).

Based on this formula, four basic lines of behavior can be distinguished that depend on the “power-interest” ratio and form a matrix (power-interest matrix): 1) the “weak-low” ratio is characterized by a low effort line; 2) for "strong-high" - key players (key players); 3) for "weak-high" - the position of the information player (keep informed); 4) for "strong-low" - a neutral position (keep satisfied).

With regard to Russian conditions, the proposed model allows:

Find out the reason for the inertial approach of the country's financial authorities to the development and implementation of the strategy. These bodies act within the limits of their powers and therefore seek primarily to minimize the risks in the field of fiscal relations and inflation, and not to take on additional investment risks. Therefore, there is nothing surprising in their desire to increase their influence solely by strengthening their positions of power in government. Such a position, in terms of Mendelow's model, can rather be designated as neutral;

Explain the natural formation of coalitions of less influential stakeholders by creating banking associations for consolidated interaction with government agencies and financial authorities. This desire also explains the difficulty of creating a single "trade union" of bankers, in which the opinions of the least influential members can be ignored. This category of people is not satisfied with the position of “staying in the know”, which was given to them by the creators of the strategic developments of recent years.

From the foregoing, a fairly obvious conclusion follows that in order to “launch” the mechanism of state strategic management, it is necessary to go through another “fork” - to develop coordinated approaches:

To involve the widest range of stakeholders in the strategic processes. The expert community, representatives of Rospotrebnadzor, domestic and foreign scientists are called upon to play an important role. It is necessary to create "platforms" for discussing, taking into account and coordinating their opinions and interests in the formation and implementation of the strategy;

To increase the investment activity of the most influential stakeholders. For them, the strategy should not become an interdepartmental document designed to coordinate efforts to develop regulatory legal acts, but a concrete action plan to achieve the goals of the banking system development. In this regard, the Ministry of Finance's participation in the creation, together with IFC and Vnesheconombank, of a capitalization fund for small Russian banks with a volume of more than $1 billion should be noted as a positive development. However, the Ministry's contribution of $50 million cannot be called adequate. It would be more logical to significantly increase this contribution at the expense of income from the sale of state-owned stakes in Sberbank of Russia and VTB. Thus, the accelerated capitalization of the national banking system and the growth of its competitiveness will be achieved at the expense of the system itself and without prejudice to the country's budget;

To the organization of state strategic planning and management in the banking sector of the economy. This activity is connected with the active position of the Ministry of Economic Development and can be implemented in two interconnected ways.

other areas: a) harmonization of measures and mechanisms for implementing the banking strategy with the goals and instruments of energy, transport and other innovative strategies that ensure the implementation of the directions of the Concept 2020; b) a broad discussion by all interested parties of the draft Federal Law “On State Strategic Planning” developed by the Ministry (October 2009). This doctrinal document should be the object of the most thorough conceptual analysis, since it is it that is called upon to become the basis for the development and implementation of truly strategically important decisions.

The importance of such an analysis is due both to the place of planning with the general “strategic composition” described above, and to the understanding that “any content is defined only as a moment of the whole, outside of which it is an unreasonable assumption, or subjective certainty” .

Literature

1. Koch R Strategy. How to create and use an effective strategy. 2nd ed. St. Petersburg: Peter, 2003.

2. Kanaev A. V. Strategic management of a commercial bank: conceptual framework. St. Petersburg: Publishing house of St. Petersburg State University, 2006.

3. The concept of national security of the Russian Federation: Approved by Decree of the President of the Russian Federation of December 17, 1997 No. 1300. URL: http://www.kodeks.ru (date of access: 06/14/2011).

4. Sorokin D. On the development strategy of Russia // Questions of Economics. 2010. No. 8. S. 28-40.

5. Abalkin L. From economic theory to the concept of long-term strategy // Questions of Economics. 2010. no. 6. S. 4-9.

6. Shokhina E. Development as a formality // Expert. 2011. No. 7. S. 50-52.

7. Transport strategy of the Russian Federation for the period up to 2030: Approved by the order of the Government of the Russian Federation dated November 22, 2008 No. 1734-r. URL: http://www. kodeks.ru (date of access: 06/14/2011).

8. Alymov Yu. M. On the development strategy of the banking sector of the Belarusian economy for 2011-2015 // Bank Bulletin. 2011. No. 5. S. 5-11.

9. Energy Strategy of Russia for the period up to 2030: Approved by Decree of the Government of the Russian Federation dated November 13, 2009 No. 1715-r. URL: http://www.kodeks.ru (date of access: 06/14/2011).

10. The concept of long-term socio-economic development of the Russian Federation until 2020: Approved by the order of the Government of the Russian Federation dated November 17, 2008 No. 1662-r. URL: http://www.kodeks.ru (date of access: 06/14/2011).

11. Investments in Russia. 2009: Stat. Sat. M., 2009.

12. Glazyev S. We have macroeconomics of the absurd // National Banking Journal. 2006. No. 6(29). URL: http://www.nbj.ru/publs/banki-i-biznes/2006/06/07/archive-publ-9472/index.html (date of access: 06/14/2011)

13. Solntsev O. Breaking the inertial trend // Expert. 2008. No. 16. S. 68-71.

14. Solntsev O. Financial sector: development prospects and policy of national competitiveness // Banking in Moscow. 2005. No. 11; No. 12. URL: http://www.forecast.ru/_ARCHIVE/Analytics/BDM/BDM.pdf (date of access: 06/14/2011).

15. Russia's quasi-sovereign debt. Deutsche Bank Research. January 27, 2011 URL: http://www. dbresearch.com/PR0D/DBR_INTERNET_EN-PR0D/PR0D0000000000269066.pdf (accessed 14.06.2011).

16. The Global Competitiveness Report 2010-2011. World Economic Forum Geneva. 2011. P. 286-288. URL: http://www3.weforum.org/docs/WEF_GlobalCompetitivenessReport_2010-11.pdf (accessed 14.06.2011).

17. The Financial Development Report 2010. World Economic Forum USA Inc. 2010. P. 11. URL: http://www3.weforum.org/docs/WEF_FinancialDevelopmentReport_2010.pdf (accessed 14.06.2011).

18. Post J. E., Preston L. E., Sachs S. Redefining the Corporation. Stakeholder Management and Organization Wealth. Stanford University Press, 2002.

19. Mendelow A. L. Proceedings of the Second International Conference on Information Systems. Cambridge, 1991.

20. Hegel G. F. Encyclopedia of Philosophical Sciences: in 3 volumes. T. 1. Science of Logic. M.: Thought, 1975.

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