The solution to the problem of off-balance sheet deposits was sent back for revision

Information on the progress of work on amendments, aimed at combating so-called off-balance sheet deposits, is contained in the report on the activities of the National Council for financial market (NSFR, a report is available), the representatives of which participated in the relevant thematic meeting in the Federation Council at the end of last week. “The meeting discussed the issue of introduction of mechanism of receipt by investors of information confirming the existence of obligations to banks for refund on the basis of the contract of Bank account (Deposit) by sending the request by using information-telecommunication network Internet. The designed mechanism provides for the creation of a unified accounting system of deposits, which does not imply the inclusion of personal data, including surname, name and patronymic, as well as the formation of a special unique ID of the contribution”, the report says.

It also States that the meeting was attended by representatives of the Central Bank, the Ministry of Finance, the DIA, the members of the Federation Council, representatives of the banking community and experts. Details of the proposed mechanism and the results of the meeting in the report are not disclosed. The working title of the amendments to the draft Federal law “On amendments to certain legislative acts of the Russian Federation” in terms of ensuring the rights of investors to receive reliable information about the deposits.”

According to several sources familiar with the meeting, the essence of the proposal is to unify the approaches of banks to identify the Bank Deposit agreement, identifying each such contract room on a single system and by putting this number in a single external database that would accommodate and uniquely identify a particular Deposit in the same way as is done with the identification of contracts of insurance. Now the number is assigned to the Deposit agreement each Bank according to its rules, not to mention the absence of a common external database of the accounting of your deposits, which is not always allows you to check contributions and uniquely identify it in the case of the fraudulent actions of unscrupulous bankers. The idea of the amendment belongs to a member of the Federation Council Committee on budget and financial markets Nikolay Zhuravlev. He confirmed that a meeting on this issue took place, but declined detailed comments to its proposal, citing the fact that the document is still at a too early stage of discussion and that the meeting was “working”.

The problem of off-balance sheet deposits is that in situation of difficulties the Bank or just the original malice of bankers made by the client the Deposit is not reflected in the Bank database (which, in particular, facilitates the bankers, those assets or allows you to hide in the presence of constraints on the inputs from controller real volume of deposits). As a result, the accounting of your deposits is conducted informally, in a so-called notebook in the official reporting of the deposits is not detected after the revocation of the Bank licence creates difficulties for the investors in getting their money — both in terms of the procedures for their return (requires additional documentation) and the terms of payment of insurance compensation under contributions the Agency on insurance of contributions (which increase substantially). First off-balance sheet deposits were identified in the Mosoblbank a few years ago in the course of his rehabilitation. Subsequently, the similar situation repeatedly to light after the revocation of licenses and other credit institutions.

Controversial decision

The intention of the Bank of Russia to deal with off-balance sheet deposits disclosed a long time, regularly and repeatedly, but the information that we discuss specific options and details of these discussions have only become available recently.

However, as point sources , despite the absence of formal objection on the proposed draft amendments made during the meeting, the proposed solution is perceived stakeholder agencies is not clear and raises more questions than answers. “Formally, the meeting agreed to calculate the cost of the project, the timing of its implementation, to consider alternative options and then return for further discussion,” — said one of the interlocutors .

“The actual sale price, who will pay and terms — key issues — says one of the sources . Given that the remake will have all the system identify the deposits in banks, not to mention the creation of the database itself, which is expensive and not as easy as it seems, the protection of the contained data, its updating and maintenance, talking about really substantial cost”. To rate them he really found it difficult. “As for the timing, according to preliminary estimates, this years, he continues. — During this time, you can clean up the banking system completely or come up with another, more optimal way of solving the problem off-balance sheet deposits.” Too expensive and most likely unnecessary at the time of implementation of the “toy” turns out, he concluded.

Another important question — the question of Bank secrecy. According to sources , one of the previous meetings of the special concern over this issue was expressed by the head of the Central Bank Elvira Nabiullina. “In theory, replacing full name of contributor unique contract number solves this problem, but what if the contract is a customer of the Bank, say, lost? So, the database should be kept and personal information,” says another source .

“We are talking about the fact that even in the presence of IDs in the database will still be stored in the key registers of depositors of individual banks. And as soon as the information leaves the credit institution somewhere else, the risk of leakage of Bank secrecy increases. And she was recently becoming more and more ephemeral concept,” explained one of the participants of the meeting.

The opinion of the market

Officially, the banking market participants admit that the mechanism of suppression of off-balance sheet deposits needed, but doubts the meeting participants relative to this particular proposed mechanism share. “Tool for fight against off-balance sheet deposits needed. However, while the efficiency of the proposed mechanism raises a number of questions, in particular, who will be the Registrar and as may be implemented wholly, the continuity of this system, because any failure can cause unnecessary anxiety of depositors,” — said Vice-President of Association of regional banks “Russia” Alina Vetrova.

“Despite the positive motivation of this proposal have a lot of questions for its implementation, in particular regarding the costs of implementation of this idea, emerging risks for the protection of Bank secrecy, and technological complexity. When large injections are required from the state and from market participants. And not the fact that the government is ready to spend the money to implement this project. The Bank of Russia actively clean the market from unscrupulous credit companies. And perhaps to the time of the creation of a single register the need for it will be extremely small. By the way, the problem of fictitious deposits on the scale is not the key compared to assets”, — said the Deputy Chairman of Alfa-Bank Vladimir Senin.

In a press-service of the Central Bank said that the Bank of Russia considers “not reflection in the financial statements of the banks obligations to depositors as a financial crime.” “The main direction of the fight against crimes in the banking sector is seen in the improvement of the criminal legislation and law enforcement practice. At the same time, the Bank of Russia is ready to examine any proposal aimed at protecting from unscrupulous behavior of banks”, — said the representative of the Central Bank. The project of creation of uniform system of the account of deposits nominated by the initiative group of experts, is in its initial stage of development, he added. “At this stage it looks technically complex and costly. Thus its implementation is highly problematic and is unable to solve the problem of so-called off-balance sheet deposits”, — said the representative of the regulator.