한국의 거시건전성정책체계 설계: 2 - 단계 최소접근법 (Designing the Institutional Framework for Macroprudential Policy in Korea: A Two - Step Minimalist Approach)

서지정보

· 발행기관 : 한국금융학회
· 수록지 정보 : 금융연구 / 30권 / 4호 / 63 ~ 118페이지
· 저자명 : 김홍범

초록

이 글은 우리나라의 현실에 적합한 거시건전성정책체계의 설계를 목적으로 한다. 제Ⅱ장에서는일국의 거시건전성정책을 전담하기에 적합한 당국, 또는 적어도 동 정책에서 주된 역할을 맡기에적합한 당국이 다름 아닌 중앙은행이라는 관련 문헌의 표준적 결론을 조명한다. 또한, 거시건전성정책의 주체가 중앙은행인지 여부를 포함한 몇몇 특징적 측면에서 서로 차별화되는 여러이론 모형에 대해서도 살펴본다. 이와 같은 일반적 논의를 토대로, 제Ⅲ장은 우리나라의 구체적현실을 십분 고려한 2-단계 최소접근법에 따라 법정 2자 협의체(가칭 ‘거시건전성정책협의회’)를한국의 거시건전성정책체계 모형(안)으로 제시한다. 동 협의회는 거시건전성정책의 두 핵심당국으로 널리 간주되는 중앙은행(한국은행)과 금융감독당국(금융위원회․금융감독원)으로구성된다(최소 접근). 이는 정책당국 사이에 “수직적 기관 위계(vertical institutional hierarchy)”가지배하는 우리 사회의 유교문화적 전통을 감안하여 정부(기획재정부)를 배제함으로써, 한국은행과감독당국 간 “기능적 협력과 수평적 견제”를 촉진하기 위한 것이다. 또한, 동 협의체는 준비단계를거쳐 완성 단계로 진입하는 점진적 접근을 따른다(2-단계 접근). 한국은행이 “대응의지” 및“대응역량”을 배양할 수 있으려면, 그리고 두 정책당국이 상호 협력 및 조정의 경험을 통해 선의의경쟁 속에 각기 나름의 성과를 축적할 수 있으려면 준비 단계가 반드시 필요하기 때문이다.
제Ⅳ장은 결론으로 2자 협의체 모형의 잠재적 강점 및 한계를 논의한다.

영어초록

The formal institutional framework for macroprudential policy is yet to be created in Korea. Although Korea has been operating for years a couple of informal channels for discussion of major themes in its macroeconomy and finance including macroprudential policy issues relating to systemic risk and financial stability, recent evidence shows that they cannot be relied upon at all to serve the role of the macroprudential policy authorities. This stands in stark contrast to the fact that many countries each have already been formally operating their own institutional arrangements for macroprudential policy, on the heels of the global financial crisis.
This paper aims at designing the Korean institutional framework for macroprudential policy that should meet the basic requirements for the effective conduct of macroprudential policy and, at the same time, be adequately attuned to the institutional realities in Korea. In order to do so, Section II provides a literature review, which leads us to the finding that central banks are generally expected either to be charged with macroprudential policy as the competent authority or to play at least an important role therein. The emphasis given to the role of central banks reflects the general understanding that the effective conduct of macroprudential policy requires “a strong institutional framework” that should be built on both the “willingness to act” and the “ability to act.” Further, several typologies of stylized theoretic models found in the literature are briefly reviewed and discussed.
On the basis of this literature review and in full consideration of institutional realities in Korea, Section III of the paper comes up with a two-step minimalist approach in its exploration of an appropriate model that should suit Korea properly and effectively. As a result, the paper finds one in the two-party council, tentatively titled the Macroprudential Policy Council (MaPC), in which participate the Bank of Korea (BOK) as the cental bank on one hand, and both the Financial Services Commission (FSC) and the Financial Supervisory Service (FSS) as the prudential regulator on the other.
Note that in line with the paper’s minimalist approach MaPC consists of the two core authorities including BOK and FSC/FSS, with the Ministry of Finance and Strategy (MOSF) excluded. This feature is embedded in the model in view of the deep-rooted Confucianist cultural tradition in Korea where “the vertical institutional hierarchy” has long been entrenched. As long as the macroprudential policy framework is mandated to deal with the prevention side of crisis only, the two parties will suffice. In addition, this minimalist approach will contribute to mitigating effectively such inherent tendencies as “group-think” to which multi-agency councils are deemed vulnerable. The two-party council may well have considerable significance in the sense that it can be interpreted to be a natural arrangement resulting from the process of institutional evolution, as was evidenced in case of the Council for Cooperation on Macroprudential Policy that existed, though briefly, in Sweden for a couple of years back in 2012 and 2013.
Note also that in line with the paper’s two-step approach MaPC is designed to take its first step to the beginning stage which allows each participant to buy enough time to get adjusted and prepared before taking its second step to move on to the completion stage. This feature importantly reflects the fact that BOK currently leaves much to be improved in terms of its willingness and ability to act, whereas FSC, along with the FSS, needs to learn how to cooperate and coordinate with BOK in macroprudential policy.
In the first stage, BOK is left with few policy tools of its own to be used distinctively for the macroprudential policy purposes, while FSC/FSS, in their capacity of microprudential policy authorities, own and control most macroprudential tools. In the second stage, however, a few cyclical macroprudential tools could be assigned to BOK, which is generally expected to hold comparative advantage in analyzing and dealing with, if anything, the cyclical dimension of systemic risk.
What is particularly unique about MaPC lies in a couple of specific rules that govern its modus operandi. The Council is supposed to apply either the ‘consultation’ rule or the ‘positive endorsement’ rule, depending on whether a proposed item on the agenda one party submits to MaPC for discussion is to request, via consultation, the other to act, or to seek positive endorsement from the other so as to carry out one’s own plan to act. Once it is either consulted or positively endorsed as the case may be, the submission will have become a recommendation issued in public by the Council with its addressee being obliged to ‘comply or explain’. Considering that most policy tools are in the hands of the financial supervisory authorities, these specific rules governing MaPC are contrived mainly for the purpose of ensuring BOK to exert checks and balances effectively upon FSC/FSS. Finally provided in Section IV are conclusive remarks on potential merits and limits of the institutional framework which this paper has proposed.

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