Managing Islamic Deposit Insurance in a Dual Banking System: the Malaysian Experience Dato’ Mohd Razif Abd Kadir Deputy Governor 6th IADI Annual Conference 1 November 2007 1 Outline Financial Safety Net The Need for Islamic Deposit Insurance Islamic Deposit Insurance Model Issues & Challenges 2 Main Components of Financial Safety Net Need to maintain financial stability for sustainable economic growth Financial Stability Depositors’ Protection Robust & Sound Banking System FINANCIAL SAFETY NET Prudential regulation & supervision Lender-oflast resort Intervention & resolution mechanisms Deposit insurance system 3 Malaysia’s Islamic Financial System…the journey The journey: 1st Islamic bank Tabung Haji M’sian Islamic Financial Centre 1st takaful company New takaful & retakaful company Islamic window Foreign Islamic banks Islamic money market Islamic subsidiary Financial Sector Master Plan Islamic capital market Strong Growth of Islamic Banking Assets… 140 120 2000-2006: average annual growth 18.8% RM billion 100 80 60 40 20 0 1984 1986 1988 1990 1992 1994 1996 1998 2000 2002 2004 2006 Introduction of Islamic banking window … Instituted comprehensive Islamic financial system with diversity of players & wide range of products supported by robust legal, Shariah & regulatory framework, has effectively establish a viable dual banking system… ISLAMIC BANKING & Source: Bank Negara Malaysia (BNM) FINANCE IN MALAYSIA 4 Need to have Islamic deposit insurance system to maintain sustainability of Islamic financial system & overall stability of financial system… Islamic banking operating parallel with entrenched conventional banking… Depositors Implicit guarantee Government Target same customer pool Islamic Banking Implicit guarantee already in place before introduction of deposit insurance system… Conventional Banking In introducing explicit deposit insurance system, do we have a choice to exclude Islamic deposits? No! Financial safety net* as necessary condition for doing business & to maintain financial stability for economic growth - instill public confidence No compromise on financial stability – avoid systemic risk * Including deposit insurance system Islamic banking must be as competitive vis-à-vis conventional banking Need separate Islamic deposit insurance operating parallel with conventional deposit insurance – in accordance to Shariah principles 5 Mechanism for Deposit Insurance Funds DEPOSITORS Guiding Principles: DEPOSITORS Minimise Deposits MDIC funds provided for: i. Immediate payment to FINANCIAL INSTITUTIONS FINANCIAL depositors of non viable INSTITUTION’S banks; and FAILURE ii.Facilitate resolution of troubled banks Contribution (premium) duplication of functions/ regulatory requirements – least cost resolution MDIC is independent but close co-operation & coordination with BNM on regulation & supervision Costs borne by banking system – through contribution (premiums) MDIC system – Islamic deposit insurance operates side by side with conventional deposit insurance under MDIC Equitable Assessment & resolution FUND INVESTMENT • Islamic Fund • Conventional Fund BNM MDIC may seek credit from government for temporary liquidity MDIC will repay to government via adjusted premium rate GOVERNMENT CREDIT FACILITY BNM - Bank Negara Malaysia; MDIC – Malaysia Deposit Insurance Corporation 6 Rationale on insurance coverage of mudharabah deposits… As prudential measure with overall objective of promoting integrity & stability of banking system (“Maslahah” – public interest) Mudharabah deposits* – (49.2% of total deposits) If mudharabah deposits are not covered while conventional banks are covered by deposit insurance, it may expose to systemic risk MDIC will provide insurance coverage only in the event of bank failure Under normal course of banking business, depositors expose to the risk of losing their capital – consistent with concept of mudharabah Rationale Current practice, mudharabah deposits (general investment account - GIA)* are managed & behave similar to “near deposit” rather than pure investment Not fully recognised mudharabah deposits as risk absorbent for Islamic banks Deposit insurance covered by 3rd party guarantee not by bank itself MDIC will provide 3rd party insurance coverage (consistent with Shariah principles) Mudharabah deposits has lower priority of payments than Wadiah deposits In future, continuous assessment - to ascertain insurability of mudharabah deposits * Main types of mudharabah deposits - General Investment Account (GIA) & Specific Investment Account (SIA) 7 Interrelationship between BNM and MDIC Guiding Principles Transparency in presentation of the issues Accountability of each organisation for areas within their mandate Timely and clear communication In resolving conflict of interest issues, the overriding goal shall be the stability of financial system Respect & valuing the diversity of experience that both organisations would bring to the discussion table Mechanism Governor as an ex-officio member in MDIC’s Board of Directors Guide to Intervention outlines the intervention processes to be applied to member institutions by BNM and MDIC Strategic Alliance Agreement sets out areas resources & information sharing Liaison Committee to identify issues for co-ordination and resolution Regular meetings to resolve bilateral issues BNM - Bank Negara Malaysia; MDIC – Malaysia Deposit Insurance Corporation 8 Islamic Deposit Insurance Model 3. Provide insurance coverage when bank fails (3rd party guarantee) 1. Deposit money Depositors Islamic Banks 2. Contribution (premium) based on Tabarru’ Separation & equitable treatment principles Separate management of funds Funded by contribution (premium) collected from Islamic banks Pooled contribution (funds) managed separately Invest in Shariah compliant instruments Equivalent Coverage Limit Islamic deposit covered separately from conventional All coverage limit -similar to conventional Up to RM60k per depositor per member institution Covers 90% of total depositors* Separate Premium Assessment Separate deposit premium assessment system for Islamic & conventional Separate supervisory assessment for Islamic & conventional banking institutions (incl. windows) Separate Payout Separate payment in event of failure Islamic deposit insurance funds used only for Islamic banks Deficit contribution - can raise funds from government based on Shariah principles Dedicated Deposit Insurance Act covers provision on Islamic deposit insurance * Based on BNM Survey 9 Issues and Challenges Should risk premium assessment methodology be different from conventional banking? Should premium assessment on Islamic windows be separated from their parent conventional banks? Absence of guiding principles on Islamic deposit insurance Operation and establishment of Islamic deposit insurance scheme Collaboration & cooperation between Islamic Financial Service Board (IFSB) and International Association Deposit Insurers (IADI) Committee To address distinct features / structure of Islamic banking Consideration on profit sharing investment account as risk absorbent Limited avenue for investment on Islamic financial instruments Demand exceed supply Need for continuous innovation Liquidation of assets in event of bank failure Cross border liquidation of assets globalisation Priority of payments of new contracts applied to deposits (e.g. wakalah, musharakah contracts) Actual liquidation process (e.g. liquidation of assets funded by specific investment accounts) 10 THANK YOU 6th IADI Annual Conference 1 November 2007 Mission A vibrant, innovative and competitive international Islamic financial services industry in Malaysia, supported by high calibre human talents, world-class infrastructure and best international standards 11