商业银行内控制度建设现状【外文翻译】 .doc

商业银行内控制度建设现状【外文翻译】 外文翻译原文the situation of commercial bank internal control systemmaterial source:rationing in credit markets with imperfect informationauthor:bester screening commercial banks internal control system, is the commercial banks internal construction in preventing risks as the goal, take into account the efficiency of the original then, to realize the mutual business post balances, business process of scientific, rational, business variety of risk assessment of each the floorboard of internal rules. the current domestic banking after more than ten years of commercial construction, and has initially established a set of certain scientific and strict internal control system, initially forming a cross, post restriction, the department authorized points under internal control mechanism, to effectively guard against credit risk and market risk and operation risk played a significant positive role. banks seriously quite internal control, generally strengthened the internal control and management in the bank management of base besides art1 function sex status, can according to the peoples bank of china and the cbrc set series of internal control documents and relevant regulations request, unifies own reality, the internal control group system and method system, supervision and evaluation mechanism on the construction of a difference. if the asset to the risk classification, rating, control of bad assets of the centralized collect dispose. for new issue loans of the feasibility of the demonstration, credit audit separation, track surveillance, to the added non-performing assets the strictly investigate and prosecute, in bank accounting business operation process strictly implements incompatible business phase separation, can enough for bank internal risk status has launched a series of internal control inspection, evaluation activity etc. can say, each the banks internal all been set up a set of closely related with their own business operation, the control system, internal control management text already see rudiment of construction for banking dovish manage, played an obvious stimulative effect. but chinas banking internal control the problems of the construction of also obvious, mainly displays in: system of internal control constraint weakness, lack of mandatory. part of internal control system in departments and divisions between not only is mutual separated, some even conflict with each other. if the accounting department does not restrict deposit marketing of the capital cost, deposit structure more and more is not reasonable. the loan pricing mechanism is unreasonable, often by financial trade vicious competition in shadow ringing off the profit imization goal; loans, though a set of internal control organizational processes, but lack of policymakers restriction, etc. moreover, due to the internal control system set unreasonable, often is not accused of controlling, for management and decision-making constraint weakness, mainly by its autonomy consciousness and moral integrity to restrain, in system asher project managers on the existence of neglect of management internal control system lags behind the business development, lack of prospective. in chinas current economic is experiencing a high growth stage, the banks business internal and external environment is changing fast. if not timely, prospectively provides the system guarantee, will inevitably leads to not standardized operation, make new business risk cannot be controlled, emerging business often become new risk source. meanwhile, in the absence of system timely adjust function, some inappropriate system still need execution, lead to operator in the index under pressure to the passover, formed the system has made no universal, moreover, due to the lack of business of continuous, the system of supervision, often send hope in post-supervision and recovery, and in precautions, a chinese control to the lack of necessary rules internal control system, lack of systematic scattered formulated. commercial banks internal each management agencies and basic it is horizontal to each layer branches have their respective management institution, due to internal lack a unified inside control degree construction planning, each department formulate rules and regulations, so as to form the fragmented, separate management situation, to build became the current bank internal control system of huge, system goals are united hard, system, make some clashes content bases layer institution in the system of internal control during execution for multiple management and helpless, widespread low efficiency of management of feeling condition internal control system, lack of stylization serious maneuverability. on the one hand, the system designer unilateral pursue system degree itself perfect, often deviating from the practice, causing some internal control system in actual work hard to operate, persecuted system executives take deviant practice, and gives undesirable motivation who create crime opportunity. on the other hand, less rules again there is a blur in the concept of the operational level, involving various business links often take the original then the formulation, resulting in system of understanding and implementation of executor otherness is bigger the main cause of formation afore-mentioned problems: one is the commercial banks in china especially state-owned commercial banks, the property right is clear, corporate governance structure is not perfect. property rights system has incentive and restraint function, determine and impacting business bank of behavior targets and behavior, improve corporate governance structure is to ensure that the commercial banks internal control effectively source power. currently our commercial banks especially state-owned commercial banks, ownership and the integrity of points from, running and managing existing in the process of short-term, radically affect the commercial banks internal control long-term machine system established. although say, commercial banks has generally established internal audit organization system, but the internal audit department fails can directly to the board of directors and top management is responsible for the state-owned commercial banks, other grass-roots branches according to administrative divisions set pattern has not fully reversing, institution of too many levels and reduce the sensitivity of internal control, increased group woven operation risk. second, it is commercial banks internal control system construction lack of systematic, comprehensive, prospective study fundamentally, our country banking industry is still in extensive development, not according to commercial bank itself the organizational system, business operation system and risk control situation and other factors on systematic, comprehensive and prospective studies, thus making set the consistent with their own development regularity of the internal control system of the construction plan. the daily management work is often a business to send exhibition, there a problem, just go considering internal control system of research and formulate, or some business development process appeared in fact risk to sum up experience, research risk control measures, the end can not specimen. third, the commercial banks internal control means relatively lags behind, the technology content is relatively inferior, the reaction speed is relatively slow the banks internal control and management is a dynamic control process, covering the whole process of bank business, the purpose is to have effect of guard against operational risks occur, promote the business development. some banks internal control content simply to formulate system, carry out inspection, treatment peccancy, as technological application level is relatively backward, the internal control system failed to establish a set of scientific and efficient, standardized computer risk control system, internal control means still with manual exercises is given priority to, from large portfolio of artificial screening and control, inevitably will appear omissions, not only the management cost is high, and low efficiency of the management. internal control system construction is still a passive cope with the situation. second, our country commercial bank inside control construction of the emphases and difficulties commercial banks internal control of the construction of key should be: the establishment of a modern enterprise system, perfect the corporate governance structure, from the construction of internal control systems of system and mechanism continuity source such as sexual problems on to try to solve. commercial banks share-holding system the aim is not only to realize joint-stock enterprise form, more important is the realization mechanism and system transformation, into for sufficient capital, strict internal controls, safe operations, good service, benefit is remarkable modern banking enterprise. from single a property to multiple property . diversified ownership will make the property right of state-owned banks, and is more obvious and because property is the source of the socialization and shares the mobilization, the assets of state-owned banks configuration will be more efficient, facilitate state-owned banks rapidly expand capital, business contacts and risk prevention. from legal person to level multistage method people . first class corporative increased the chances of government intervention, causing credit constraints softened. in multi-stage legal person system, the state-owned commercial bank head office is no longer administrative institutions, but level operation entity, is first class corporative, can with shareholder bank top-down jiguanshi, administrative management mode, implement the commercial bank multistage operation, since bear wind the risk of goals. from administration to corporate governance. the state-owned commercial banks hangzhengshi internal institutions asher buy and administrative regionalization branches set must to reform, reorganization and implementation in share-holding system multistage method people after the internal management system and operational mechanism, must be fetching company governance structure, thoroughly remove plan economic system hangzhengshi personnel arrangement system, try to overcome the influence of subsequent state-owned commercial banks various agent short-term tendency towards utilitarianism commercial banks internal control system construction of difficulty is to establish the operation and orderly, fast reaction, adjusted timely, inside let integrity and evaluation rational internal control organization, implementation and evaluation system. commercial banks should press decision-making system, execution system, supervision and feedback system on the principle of mutual containment of internal control organization structure settings. decision-making person cannot breach or transcend decision-making procedures: executives should be at its responsibility and authority in exercising their functions and powers, internal supervision department tasseled shall establish various business risk assessment, internal control evaluation and examination of condition of any violation behavior of punishment system. but this is only theoretical conception, when these theoretical conception real practice, often can touch to many practical problems, there exist some difficulty 译文商业银行内控制度建设现状资料来源:信息不对称与信贷市场 作者:贝斯塔.斯克里宁 商业银行内控制度,是商业银行内部构建的以防范风险为目标,兼顾效率原则,实现业务岗位的相互制衡、业务流程的科学合理、业务品种的风险评估的各种内部规章的总称。当前国内银行业经过十多年的商业化建设,已初步建立起一套具有一定科学性和严密性的内控制度,初步形成了部门交叉、岗位制约、授权分责的内控机制,对有效防范信用风险、市场风险和操作风险起到了明显的促进作用。各银行都比较重视内部控制,普遍强化了内控管理在银行经营管理中的基础性地位,能够按照人民银行、银监会制定的系列有关内部控制的文件、规章的要求,结合本行的实际,在内部控制的组织体系、方法制度、监督评价等机制的建设上有所作为。如对资产的风险分类、评级、控制,对不良资产的集中清收、处置。对新发放贷款的可行性的论证、审贷分离、跟踪监督,对新增不良资产的责任人的严肃查处;在银行会计业务操作过程中严格实行不相容业务相分离,能够针对银行内部风险状况开展一系列内部控制检查、评价活动等等。可以说,各银行内部都陆续建立起一套与自身业务紧密相关的操作、控制制度,内控管理文化建设已见雏形,为银行业的稳健经营起到了明显促进作用。但我国银行业内控建设中存在的问题也显而易见,主要表现在: 内控制度约束乏力,缺乏强制性。部分内控制度在部门和部门之间不仅是相互割裂的,有些甚至相互抵触。如会计部门不能制约存款营销的资金成本,存款结构越来越不合理;贷款定价机制不合理,往往受到金融同业恶性竞争的影响而偏离了利润最大化目标;贷款发放虽有一套内部控制的组织流程,但缺乏对决策者的制约,等等。另外,由于内控制度设置不合理,往往是“控下不控上”,对管理层、决策层的约束乏力,主要靠其自律意识和道德操守来约束,在制度设计上存在对管理者疏于管理的问题。 内控制度滞后于业务发展,缺乏前瞻性。当前我国经济正处于高速成长期,银行经营的内外环境亦快速变化。如果不能及时、前瞻性地提供制度保障,就必然会导致不规范操作,使新兴业务的风险无法得到控制,新兴业务往往成为新的风险源。同时,由于缺乏制度的适时调整功能,一些不适宜的制度仍然需要执行,导致经营者在指标的压力下,不得不逾越制度,形成了普遍的有令不行、有禁不止的现象。另外,由于缺乏对业务经营的连续、系统的监督、往往寄希望于事后监督与补救,而在事前防范、事中控制等方面缺乏必要的规章。 内控制度分散制定,缺乏系统性。商业银行内部各管理机构基本都是横向的,每一层分支机构都设有各自的管理机构,由于内部缺乏一个统一的内控制度建设规划,各个部门自行制定规章,从而形成各自为政、分头管理的局面,造成了现行银行内控制度数量庞大,制度目标难以统一,制度内容时有冲突,使基层机构在内控制度执行时因多头管理而不知所措,普遍存在管理效率低下的情况。 内控制度程式化严重,缺乏可操作性。一方面,制度设计者片面追求制度本身的“完美”,往往偏离实际,导致一些内控制度在实际工作中很难操作,逼迫制度执行者采取越轨的作法,并给不良动机者创造作案机会。另一方面,不少制度规定又存在模糊化的概念,在涉及操作层面的各个业务环节时往往采取原则性的提法,导致制度执行者理解和执行上的差异性较大。形成上述问题的主要原因:一是我国商业银行尤其是国有商业银行,产权不明晰,法人治理结构不完善。产权制