Sie sind auf Seite 1von 29


Question 1.1
What is the total number of staff employed by the regulatory agency?
The proposed APRA structure envisages a staff of 446.
OSFI currently employs 350 full time staff in its regulatory functions. In addition, there are 25 in unrelated
activities (government pensions).
1998: 162 full time employees.
There are 402 permanent staff and 35 part-time staff as of 1
March 1999. However, for fiscal year 1999
(starting from April 1, 1999), permanent staff is to increase by 135.
The total number of employees of the Financial Supervisory Service is 1,238 as of March 11, 1999.
There are currently 147 employees at Kredittilsynet.
The MAS, as a central bank, had 694 staff as at 28 February 1999. Of this number 295 staff were within the
Financial Supervision Group (FSG), which is responsible for the MAS regulatory and supervisory function.
United Kingdom
The FSA currently employs 1750 permanent staff, excluding the staff involved in the Pensions Review.
Question 1.2
If available, how does this number compare with staff numbers involved in similar supervisory
12 months ago
5 years ago
Recent changes to the regulatory structure make direct comparisons difficult. However, when compared
against the total employees of the former supervisors which have combined to form APRA, staff numbers have
fallen over the last 12 months (down from around 600). Similarly, staff numbers have also fallen over the last 5
years (from a peak of 700).
12 months ago Roughly the same
5 years ago Approximately 375 full time staff at that time.
12 months ago 1997: 161 full time employees
5 years ago? 1993: 132 full time employees
With the establishment of the FSA as of 22
June 1998, 373 staff, who were previously responsible for
inspection and supervision of financial institutions in MOF, were transferred to the FSA and 30 staff were
added. For the fiscal year 1999, permanent staffs will increase by 135.
December 31, 1997 1727
December 31, 1998 1336
March 11, 1999 (after integration) 1283
December 31, 1993 117
December 31, 1997 134
December 31, 1998 139
January 31, 1999 147
Total Staff [No of FSG staff]
February 28, 1994 500 [195]
February 28, 1998 593 [246]
February 28, 1999 694 [295]
There are no comparable agencies.
United Kingdom
A direct comparison is difficult but overall staff numbers involved in similar supervisory activities are down
slightly on the numbers 12 months ago but up slightly compared to 5 years ago.
Question 1.3
In broad terms, what proportion of total staff is involved in:
front-line supervision activities (on-site and off-site, policy development licensing, enforcement);
supervisory support functions (e.g. statistics, legal, economic analysis);
corporate services (e.g. admin, human resources, finance, premises, etc)?
Front-line supervision: 332 employees
Supervisory support function: 43 employees
Corporate Services: 71 employees
Front-line supervision: Approximately 58% of OSFI staff (The Supervision Sector, the Registration
and Approvals Division, and certain functions within the Legislation and
Precedents Division).
Supervisory support function: Approximately 22% of OSFI staff (The Specialist Support Sector, the Legal
Services Division, certain functions within the Legislation and Precedents
Division, the International Liaison Division and the Communications
Corporate services: Approximately 20% of OSFI staff (Comprised of the Corporate Services
Front-line supervision: 95 full time employees (58%)
Supervisory support function: 36 full time employees (22%)
Corporate services: 31 full time employees (20%)
Front-line supervision: 80%
Supervisory support function: 10%
Corporate services: 10%
Front-line supervision activities: 933 (74%)
Supervisory support functions: 105 (8%)
Corporate services: 134 ) (18%)
Others, including labor union: 96 )
We do not divide the staff according to front-line supervision activities and supervisory support functions. The
proportion of total staff responsible for corporate services (administration, human resources, IT functions,
finance, premises, etc) is 22.4% (or 33 persons).
In 1998, the proportion on resources involved in different activities (according to a recording performed on an
annual and semi-annual basis in terms of man-weeks) were approximately the following:
On-site inspections 13.4%
Off-site inspections 14.2%
Macro-economic analysis 2.8%
International activity 4.1%
Drafting of laws and regulations 8.2%
Information, dialogue 7.6%
Supervision of compliance with laws and regulation 15.6%
Contingency plan/crisis preparedness. 2.7%
Training/development of skills 5.1%
Management and administration 26.4%
The MAS:
Financial sector supervision 42%
of which:
front-line supervision activities 36%
supervisory support functions 6%
[imputed corporate services 28%*]*allocated from corporate support
Monetary & exchange rate policy 18%
Corporate support 40%
The staff is organised as follows: Insurance sector: 12 operative supervision, 12 licensing and legal issues, 9
financial analysis. Credit market sector (including banks): 12 operative supervision, 12 licensing and legal
issues, 9 financial analysis, Securities market sector: 9 operative supervision, 11 licensing and legal matters, 6
financial analysis, administrative department (including EDP) 24 persons.
United Kingdom
Approximately 950 staff are involved in front-line supervisory activities, plus around 350 in authorisation and
enforcement. About 160 staff are engaged in legal and central policy work, as well as consumer relations,
industry training and prevention of financial crime. 285 are involved in corporate services (HR, Finance, IT,
Premises, Internal Audit)
Questions 1.4
To what extent are staff numbers constrained by factors other than the agencys overall budget?
Other than the overall budget, there are no constraints on staff numbers.
There is a budget constraint. However, additional constraints include the inability in some cases to pay market
rates (especially for specialist skills), and the availability of individuals with the appropriate skills set.
The budget is decided by Parliament as part of the Government budget.
The ordinance constraints the number of permanent staff.
No specific constraints exist other than the FSSs overall budget. However, since the crisis broke out at the end
of 1997, both the public and private sector are downsizing the unnecessary workforce to enhance efficiency
and competitiveness. As a quasi-government organisation, the FSS is setting an example and promoting
national consensus by streamlining the staff.
Staff numbers are not constrained by other factors than the overall budget. Within the overall budgetary
restrictions, the management of Kredittilsynet may decide the number of employees and the distribution of
manager, specialists, professionals and non-professionals.
Apart from the budget, the number of staff recruited is dependant on the medium term plans of the
There are no other factors than the overall budget.
United Kingdom
There are no other constraints on staff numbers except the FSAs overall budget.
Question 2.1
What is the divisional structure of the supervisory agency?
APRA is organised into four divisions.
Diversified Institutions: Front-line monitoring of diversified or complex financial institutions,
including conglomerates and institutions with international links.
Specialised Institutions: Front-line monitoring of the more specialised or straightforward
institutions operating within traditional industry boundaries. This
division also possesses an enforcement and rehabilitation unit.
Policy, Research and Consulting: This division is responsible for prudential policy development and
legislative review, along with developmental work on supervision
methods, theoretical research and finance sector analysis. This
division also provides specialised consulting (on-site supervision
services, particularly in the area of risk management) to the
Diversified and Specialised Institutions Divisions, and manages
APRA-wide statistical collections and publications.
Corporate Services Division: This division is responsible for managing the key support activities
information technology, human resources policy, finance, internal
audit, administrative support and so on. A General Counsels Office
also provides legal advice on issues related to APRAs governance
and statutory responsibilities.
OSFI is organised into four sectors as follows:
Supervision Ongoing monitoring and examinations of all institutions.
Regulation Registration and approval; legislation and precedents; international liaison; legal
services; communications.
Specialist Support Developing supervisory and prudential practices, participating in Basle and IAIS
committee work and adapting the results for application to Canadian banks and
insurer; assessing VAR models; developing actuarial and accounting policies;
financial analysis and data base management.
Corporate Services Human resource management; training and development; systems; finance and
Organisation chart provided.
Under the Commissioner and the Deputy Commissioner, there are Commissioners Secretariat, Inspection
Department, Supervisory Department, and Securities and Exchange Surveillance Commission; 10 Divisions
are positioned under the preceding structures (Organisational chart provided).
The FSS is made of 36 departments and 6 offices (Organisational chart provided.)
Organisational chart provided. The formal organisational structure is supplemented by formal and informal
measures and structures for coordination and cooperation across sections and departments. Efficient
coordination requires a strong corporate culture.
Organisation chart provided.
Organisation chart provided.
United Kingdom
The FSA is broadly split into financial supervisory functions; authorisation, enforcement and consumer
relations; and central functions. Organisation chart provided.
Question 2.2
Is the agency structured along institutional lines (one division for banking, one for insurance etc), along
functional lines (inspections, policy etc) or on another basis?
APRA is structured along functional lines, with the distinction between types of institutions being made
according to their size and complexity.
OSFI is generally structured along functional lines.
Along institutional lines. As an integrate part of the structure there are:
Cross sectoral centres of expertise have been created for example in the fields of:
- market risk
- credit risk
- financial conglomerates
- interpretation of legislation
Each unit has inter-disciplinary staff.
Projects manned by staff from several units.
Departments are established along inspection and supervisory functional lines; and under Supervisory
Department divisions are positioned based on financial sectors.
The FSS is structured along functional division lines (examination, supervision, enforcement, consumer
protection, supervision support and administrative) and the divisions are further divided along institutional
The formal organisation chart is partly structured along institutional lines, partly along functional lines,
depending on the department. In addition, there is cooperation across sections and departments. In fact, the
structure is more a matrix organisation with cooperation across institutional lines and across functional lines.
The largest department, the Finance and Insurance Department (which includes banking) is divided into four
functional sections responsible for licensing etc., off-site supervision, on-site inspections and insurance
regulations respectively. These sections cooperate in the supervision of the financial institutions and share
information and experience on a daily basis.
The Capital Markets Department includes the Securities Market section, a small section specialising in market
transaction and insider trading issues, and a section supervising real estate agents and debt collection agencies.
The Securities Market section has overall responsibility for the securities market (including licensing, on-site
and off-site supervision of the undertakings).
The Financial Supervision Group is structured along institutional lines.
The FSA is structured along institutional lines.
United Kingdom
The FSA is largely structured along institutional lines in the financial supervision area (except for complex
groups see Question 2.5) but the FSA has brought together authorisation and enforcement for all areas into
two separate divisions.
Question 2.3
Are specialist resources (eg legal, actuarial, credit risk analysts, etc) distributed across the divisions or
concentrated in a separate division for use by others?
Specialist resources are concentrated primarily in the Policy, Research and Consulting Division. However, the
General Counsels Office, a specialist legal resource, is contained within the Corporate Services Division.
Specialist resources are concentrated in a separate Specialist Support Sector. As noted above, the Legal
Division is part of the Regulation Sector.
They are distributed across the divisions.
Certified public accountants and Commercial Code Academics have been hired from the private sector and are
positioned in the particular divisions. Additionally, in order to receive advice and instructions from
professional fields when implementing financial supervisory regulations, we have four professionals from
fields in economics, law, and auditing as advisers.
Most specialists are distributed across the divisions but there is some concentration in specific departments
such as the legal department.
In the beginning, after Kredittilsynet was formed there was a specialised legal section. However, that structure
soon proved to be unsatisfactory, and now there are legal experts in every section and department. In addition
there is Chief Legal Counsel who is responsible for major legal issues and contributed to the overall legal
quality assurance of matters handled by Kredittilsynet. Certain specialist resources are still somewhat
concentrated. Among the legal experts, there is a certain degree of specialisation; e.g. the legal experts in the
insurance section are specialised in insurance law.
In the Documentary Supervision and Analysis section (responsible for off-site supervision of the banking and
insurance market) there is a small group of macro-economists responsible for our macro-economic surveillance
We have some specialists in the prevention of money-laundering and economic crime, specialists in IT and
supervision of the undertakings IT functions. These specialists are not working in a separate staff unit but are
working in different sections, with somewhat different responsibilities, and cooperate in the performance of
their functions, thus constituting a matrix network as indicated in the previous question.
Specialist resources are concentrated in separate divisions, such as the Supervisory Legal Services Division,
Risk & Technology Department, and Life & Actuarial Division.
Specialist resources are distributed across the divisions except for accounting standards and regulation.
United Kingdom
In general specialist resources are distributed across the divisions, except for specialist legal resources which
are currently concentrated in the General Counsels division but are working closely with and are physically
located near their relevant institutional division.
Question 2.4
Is the specialist resource model working well, in terms of:
Access by those areas needing such resources; and
Ability to retain specialist staff
The new APRA structure will not commence until July 1999, but has been designed to promote accountability,
access and staff retention.
The Specialist Support Sector has only recently been established. Responsibilities include certain existing
functions within OSFI, plus some new function which are not yet fully staffed. Thus far, the Specialist Support
Sector, to the extent that it has been established, is meeting OSFIs expectations.
Accountability yes
Access by those areas needing such resources; and yes
Ability to retain specialists staff yes
Each division is receiving instructions and advice from specialists and implementing financial regulations
accordingly. We have not had much difficulties in retaining professional staff.
Since the establishment of the FSS, a number of attorneys, actuaries and risk management specialists have
been newly positioned in the relevant departments. Until now, the model is working well.
We are quite satisfied with our model for distributing specialists across the departments and sections. There are
both advantages and disadvantages in grouping specialists within one division, and we believe that we have
found a system that works well within Kredittilsynet. We are currently conducting a review of the organisation,
analysing the development of the organisation to determine inter alia if there is need for changes.
On balance, the current structure is satisfactory. However, it requires regular interchange of views across
institutional lines.
The specialist resource model is working well in terms of accountability and access to those areas needing such
resources however there is always a problem in retaining specialist staff according to the competition from the
financial industry.
United Kingdom
The current structure appears to be working well. The General Counsels different structure is partly driven by
the specialist legal resource requirements during the passage of the legislation. Accountability of the specialists
is to the director in their respective division. Consistency is potentially the only problem with a distribution of
specialist resources across division but the contrasting benefit is the fact that the specialists are close to the
line-side work. So far the organisational structure does not appear to have had a negative impact on the FSAs
ability to retain specialist staff.
Question 2.5
Are conglomerates and/or complex groups handled by a separate division or as parts of institutional
Conglomerates and/or complex groups are supervised within the Diversified Institutions division.
OSFI has two conglomerate groups within the Supervision Sector one for deposit taking conglomerates, and
another for insurance conglomerates. The supervisory team assigned to each conglomerate is responsible for
all federal institutions in the conglomerate.
They are handled by the institutional units who have a duty to coordinate as appropriate.
Supervision of financial conglomerates is part of the responsibilities of supervisory division which oversee the
main business field of financial conglomerates.
They are handled as parts of institutional divisions but a separate department is established to coordinate
various policies for the supervision of conglomerates and complex groups.
Conglomerates and complex groups are not handled by a separate division. With regard to the banking and
insurance sectors, off-site supervision and on-site inspections are the responsibility of different sections.
However the supervision of complex groups or conglomerates is performed in cooperation between the various
sections and departments. One member of the staff would have the main overall responsibility for the whole
conglomerate, while there would be different main supervisors for the different parts of the conglomerate (e.g.
the insurance part would be overseen by one insurance expert, while the banking part would be overseen by a
banking expert). However, these experts cooperate and communicate with each other regarding the
undertakings that are part of the same group, thus forming a team responsible for each conglomerate.
Conglomerates and/or complex groups are handled as part of institutional divisions. In practice, there would be
a lead division in charge of supervising complex groups. For example, Banking Department (BD) acts as the
lead regulator in the supervision of banking groups and besides receiving consolidated financial information
(including that of non-bank subsidiaries) on banking groups, BD would also consult the other institutional
divisions (e.g. Securities and Futures Department) responsible for supervising the non-banking subsidiaries
within the banking groups.
Conglomerates are handled as parts of institutional divisions.
United Kingdom
The FSA has a Complex Groups Division which regulates the 54 largest and most complex global institutions
which range across various industry sectors (in particular at present the ones combining banking and securities
business). The Complex Groups Division is working on enhanced lead supervision and will start experiments
in group supervision.
Question 2.6
How is the integration of off-site and on-site supervision managed?
Off-site supervision is concentrated primarily within the Diversified and Specialised Institutions divisions. On-
site supervision is co-ordinated by relationship managers within these divisions, however, the resources (and
expertise) of the Policy, Research and Consulting division are drawn upon when on-site work is undertaken.
Off-site supervision involves a continuous monitoring process based on established uniform analysis,
combined with analysis specific to an institutions risk profile. OSFI uses a risk-based approach involving the
identification of key risks as part of the monitoring/off-site review process. Key risks identified then become
the focus of on-site reviews. OSFIs approach to supervision, in addition to being risk based, is highly reliance
based. Extensive reliance is placed on internal audit, external audit, risk management and compliance.
Off-site and on-site supervision is done by the same staff.
The FSA endeavours to shorten the intervals of on-site inspections and thus to check the financial and business
conditions of financial institutions in timely and accurate manners. There is a parallel move to strengthen the
off-site monitoring to complement inspection through installing computer system.
Off-site supervision is made as part of the preliminary process of on-site supervision. Findings of the off-site
supervision process are examined at the on-site supervision.
With regard to the banking and insurance sectors, off-site and on-site are the responsibility of different
sections. However the staff of the different sections communicate and cooperate with regard to the supervision
of the undertakings. The off-site section has developed a formal early-warning system based on the US Fed.s
Camel system, which serves along with other indicators as a basis for selecting institutions for on-site
supervision. The warning signs are thus picked up by the off-site section, which would then discuss the matter
with the on-site inspectors. A person from the off-site section or other sections would sometimes accompany
the inspectors at on-site inspections (this applies particularly to the actuaries with regard to inspections of
insurance companies).
With regard to the supervision of insurance undertakings, there are regular meetings between the different
functional sections and the insurance section.
With regard to the supervision of investment firms, the whole section deals with every aspect, from licensing
to off-site supervision and on-site inspection. The staff in that section cooperate with staff members from other
departments and sections with regard to the supervision of complex groups or conglomerates.
Different institutional divisions have different approaches to the management of integration of on-site and off-
site supervision.
The Banking Department has recently adopted a cluster structure, where each cluster comprises both on-site
and off-site officers who are accountable for the supervision of a given portfolio of institutions. In SFD and ID,
where the cluster approach is not adopted, off-site review officers would assist in off-site inspection planning
and regular meetings are held to work out certain issues relating to the institution concerned. Off-site officers
may also be required to participate in the inspection.
Off-site supervision is provided by the units for financial analysis which are obliged to provide the units for
operative supervision with relevant data.
United Kingdom
Off-site and on-site supervision is managed within the same division, largely by the same line-side supervisor
responsible for a particular institution. However, there are specialist teams particularly with regard to traded
markets risk assessment systems and particular credit risk expertise which support the line-side in their on-side
supervision in particular.
Question 2.7
Is policy developed within a separate policy division or within the on-line supervisory divisions?
Policy is developed primarily within the Policy, Research and Consulting division. However, consultation is
also sought from the other divisions within APRA with regards to new policy initiatives.
Legislation-based policy is generally developed within the Legislation and Precedents Division of the
Regulation Sector; however, there is extensive consultation with other sectors within OSFI. Prudential policy
(capital adequacy, etc) is developed in the Capital Division of the Specialist Support Sector.
Policy is mostly developed within the on-line supervisory divisions.
Fundamentally, MOF is in charge of ordinance amendments and from the point of view of supervisory
execution, amendments of related ordinance is discussed between the on-line supervisory division of the FSA
and MOF.
On-site supervision divisions develop policies but the Supervision Coordination Office incorporates and
coordinates individual policies initiated by the divisions.
The general regulatory policy guidelines are the responsibility of the Ministry of Finance. Kredittilsynet gives
its views through its strategic plans and through the annual reports. Policy with regard to the day-to-day
supervision of the financial institutions is the responsibility of the senior management and the board of
directors of Kredittilsynet. Whenever new types of cases arise, where there may be a need for making a policy
decision, the section responsible for the case in question (e.g. the licensing section with regard to new types of
mergers or structures) would then suggest a policy with regard to this type of case. The case would then be
discussed at a board meeting, and the board would be ultimately responsible for Kredittilsynets decision in the
matter. Certain matters would be handled by Kredittilsynet, others would be sent to the Ministry of Finance for
final approval, in accordance with guidelines given by the Ministry of Finance.
Within the Financial Supervision Group, the Supervisory Policy Division, in consultation with the front-line
supervisory departments where necessary, formulates and develops policy with regard to the regulation and
supervision of banks, merchant banks and finance companies in Singapore, as well as policy that cuts across
institutional lines. The front line supervisory departments also develop policy responses where they are more
directly related to problems or crises faced by the institutions under their supervision.
In addition, the Securities Regulation Development division within the Securities and Futures Department
examines regulatory issues specifically related to the capital markets in Singapore.
There is no separate policy division except for the Secretariat for policy and coordination. This secretariat has
not the task to form all policies for FSA.
United Kingdom
Policy is developed in a separate team within the relevant line-side supervisory division. However, there is a
central policy division which focuses on bringing the wider policy issues together (such as design of the
supervisory rulebook overall). There are various fora in which exchange of information between the policy
groups in the individual divisions take place.
Question 2.8
Is the agency housed in a single location, or does it have a number of offices? Where there are a number
of offices, how are responsibilities split between the head office and the other sites? What are the main
benefits and problems from having a number of separate offices?
APRAs main office is located in Sydney (possessing 248 staff). It also has offices in several other capitals
including Canberra (102 staff), Melbourne (55 staff), Brisbane (23 staff), Adelaide (9 staff) and Perth (9 staff).
The Diversified Institutions Division and (most of the) Policy, Research and Consulting Division are located in
the head office in Sydney. The Specialised Institutions Division includes the State offices which supervise
institutions operating largely in their region.
OSFIs main office in Ottawa but with the examinations activities largely based in Toronto and supported by
regional offices in Montreal and Vancouver, The Regulation and Corporate Services Sectors are primarily in
Ottawa. The main benefit is that Supervision staff are generally close to the institutions they supervise, and
Regulation staff are in close proximity to key government departments and agencies that they regularly deal
with. The challenge of having multiple offices is the need for frequent travel by senior staff, local recruitment,
and/or relocation of staff, and communication issues.
The Danish Financial Supervisory Authority is housed in a single location.
The office is divided into two separate buildings, but since they are within close proximity, it is as if they are
situated in one area. There are no other offices. For the inspection and supervision of regional financial
institutions, the head of each Local Finance Bureau of MOF has been delegated the partial responsibility from
the FSA, and for the delegated operations, the Commissioner of the FSA directly give instructions to the head
of each Local Finance Bureau.
It is in a single location.
Kredittilsynet is housed in a single location. We have seen that as a precondition for efficient coordination of
supervisory functions and cooperation between the staff responsible for the different areas under supervision.
Kredittilsynet recently took over responsibility for the supervision of accountants and the relevant staff were
physically relocated to Kredittilsynets offices. We believe that it is easier to achieve a strong corporate culture
in common premises, and thereby achieve more efficient and effective supervision. Important factors include,
among others, a common cantina, a common library, and common staff meetings. Proximity of offices also
facilitates informal communication and cooperation, and staff members may easily get information and advice
from other colleagues and experts, e.g. over lunch or in the hallways.
All MAS departments and divisions are located in a single location.
The FSA is housed in one single location. There are no regional or local offices.
United Kingdom
The FSA is housed in a single location, except for a very small unit based in Edinburgh. Between November
1998 and January 1999, the different groups of staff have come together in a single building.
Question 2.9
Is the agency responsible for its own Corporate Services function (covering human resources, personnel,
financial administration, and IT) and budget?
Yes. These functions are performed within the Corporate Services Division.
Yes, all corporate service needs are provided internally.
The FSA is accountable for its operations, though the final responsibility lies with the Cabinet since the FSA is
a government organisation.
Kredittilsynet is responsible for its own corporate services functions. These are all located in the administration
department, under the management of a Deputy Director General. IT is a separate group within that
MAS has its own corporate services function such as the Human Resource and Corporate Services Department,
Information Technology Department and Finance Department.
The FSA has the total responsibility for these matters.
United Kingdom
The FSA is responsible for its own corporate service functions, which all fall within the management and
budget of the FSA. None of the corporate services functions are currently contracted out to other organisations
or agencies.
Question 2.10
To what extent does the agency use outsourcing of corporate and other activities?
Most activities are sourced internally, with only certain internal audit, IT and recruitment functions being out-
To a limited extent, generally relating to the use of consultants for various studies, projects, audits and software
IT management is done under a facility management contract with an outside service provider.
The driving of vehicles for official use is partly out-sourced.
Not applicable
In general, Kredittilsynet undertakes most of its functions by using internal resources. Certain IT-functions and
the management of certain projects have been out-sourced from time to time (e.g. organisational projects, or
special investigation committees).
There is minimal use of outsourcing in the Human Resource and Corporate Services Department. One area
where we do outsource periodically is the use of recruitment agencies for referral of candidates.
For the moment there is no outsourced activities.
United Kingdom
The FSA has had support for some smaller, very specific projects from other institutions (such as consultancy
firms) where this was regarded as beneficial or necessary due to resource shortages but no major function has
been outsourced.
Question 3.1
Does the supervisory agency have a clearly stated mission statement and/or statement of values?
APRA has a clearly defined vision, mission, values and principles. APRAs vision is: Our Vision for APRA is
to be a world-class integrated prudential supervisor recognised for its leadership, professionalism and
APRAs mission statement is: APRA is committed to establishing and enforcing prudential standards and
practices designed to ensure that, under all reasonable circumstances, financial promises made by institutions
we supervise are met within a stable, efficient and competitive financial system.
The statement of values adopted by APRA is: APRA will pursue the highest standards of individual and
corporate integrity and be flexible, decisive, open and accountable.
The broad principles that characterise APRAs supervisory approach are: (i) management and Boards of
supervised institutions are primarily responsible for financial soundness; (ii) forward looking; (iii) primarily
risk-based; (iv) consultative; (v) consistent; and (vi) in line with international best practice.
Yes, OSFI has a corporate mission statement and statement of values.
OSFIs Mission statement reads, We are the primary regulator of federal financial institutions and pension
plans. Our mission is to safeguard policyholders, depositors and pension plan members from undue loss. We
advance and administer a regulatory framework that contributes to public confidence in a competitive financial
system. We also provide actuarial service and advice to the Government of Canada. We are committed to
providing a professional, high quality and cost-effective service.
OSFIs values are Commitment, Teamwork, Professionalism and Integrity.
Yes. The current mission statement was decided in September 1998.
The FRC Establishment Law states the FRC and the FSA must take necessary measures for financial failure
to stabilise and to reconstruct Japanese financial system. And also the FRC and the FSA must supervise
financial institutions to ensure appropriateness and soundness of their businesses for the purpose of protecting
depositors, insurance holders and investors and ensuring smooth circulation of securities.
The mission statement of the Financial Supervisory Commission is outlined in Section 1 of the Act. The
mission statement of the Financial Supervisory Service, which is same as that of the FSC, is also stated in the
article 2 of its article of incorporation.
- The Financial Supervisory Commission and the Financial Supervisory Service are established to
contribute to the development of the national economy by establishing an affirmative regularity in the
credit system and fair financial practices as well as protecting the rights of depositors and investors.
Yes, Every 3-4 year or so, Kredittilsynet develops a strategic document with goals and purposes of the
supervisory authority.
In 1998 Kredittilsynet considered and adopted a new strategy at the end of a process in which staff, managers
and the board of directors were all actively involved. The plan confronts the challenges associated with the
rapid development of national and international financial markets, and the tasks that Kredittilsynets
organisation has to come to terms with in order to meet these challenges.
According to the Strategy, Kredittilsynets mission is to promote:
Satisfactory levels of capital strength, risk awareness, management and control at financial institutions
under it supervision;
The exposure of circumstances that threaten the stability of the financial system and maintain
preparedness for dealing with problems in the financial sector
Compliance with laws and regulations, a high ethical standard and orderly conditions among players in the
financial market
A regulatory framework that fosters smoothly functioning markets both for supervised institutions and
their users.
The supervisory philosophy of Kredittilsynet is based upon the basic criterion that the main responsibility for
the individual institution and its activities rests upon the institutions board of directors and the management,
who shall ensure that the financial conditions are satisfactory, that laws and regulations are complied with, and
that the activities are conducted in a prudent manner.
Kredittilsynet is an independent competent authority that performs its functions in accordance with guidelines
drawn up by the Storing, the Government and the Ministry of Finance as overarching bodies. In order to
achieve its objectives, Kredittilsynet must maintain a broad-based and substantial competence and utilise its
resources effectively.
FSA has a clearly stated mission statement set by the Government.
United Kingdom
The FSAs vision is to be a world leading financial services regulator, respected for its effectiveness, integrity
and expertise both at home and abroad.
As for its values, the FSA aims to be:
- forward-looking and adaptable;
- firm and fair;
- open and responsive; and
- rewarding and fun.
Question 3.2
What steps has the agency taken to promote and foster the establishment of its corporate culture?
Staff have been involved in the establishment of APRAs corporate culture through various consultative groups
and sessions. A Staff Consultative Group has been set to air the views of the staff regarding all human resource
initiatives, including the implementation of APRAs Human Resources Policy Manual. Regular updates by the
CEO and various meetings held with all staff have been used to promote APRAs corporate culture.
OSFI involves staff in the development of all major human resource initiatives. Both unions and the Employee
Advisory Group (EAG) are consulted and the EAG has frequent access to the Executive Committee. OSFI also
holds regular meetings with all staff which are open forums with senior management.
The Mission of the Danish Financial Supervisory Authority stresses the value of one single corporate culture.
The FRC Establishment Law states the FRC and the FSA must take necessary measures for financial failure
to stabilise and to reconstruct Japanese financial system. And also the FRC and the FSA must supervise
financial institutions to ensure appropriateness and soundness of their businesses for the purpose of protecting
depositors, insurance holders and investors and ensuring smooth circulation of securities.
Since the consolidation, numerous informal social gatherings within departments have been made and
employee development programs have been in place to develop a new corporate culture.
In order to promote and foster the establishment of corporate culture, the management of Kredittilsynet ensures
the participation of the employees in all processes related to the organisation and management of
Kredittilsynet. All employees are involve in preparing the annual plans for Kredittilsynet, and reporting the
activities and mid-year and at the end of the year. Internal information is emphasised and all employees receive
a copy of the minutes from the weekly senior management meetings. There is a high degree of openness with
regard to internal organisational matters in addition to professional matters (e.g. employment terms etc)
Projects involving the participation of persons across sections and departments help build a team spirit and
corporate culture.
Regular information meetings are held 4-6 times a year for all staff members.
The staff responsible for certain cases would also participate in the board meeting where the case is being
presented and discussed. At section level, there are training courses and seminars outside the premises where a
balance between profession discussions and social activities is emphasised. In addition, there are certain social
activities organised by and for the staff.
MAS has been engaged in a corporate visioning exercise since the middle of last year. Through an extended
process of off-site retreats, focus group discussions, and dialogue sessions, staff from different departments
and across different levels of seniority gathered to share their views and give their feedback on what MAS
vision and values should be. The process, though not complete, has helped foster a sense of common identity
and a consensus on the kind of corporate culture that staff would like to see.
According to the statement set by the Government the FSA has formulated a written policy statement in
accordance with the overall statement.
United Kingdom
Co-location in a modern and open-plan office building has enhanced the realisation of a common corporate
culture. Openness and transparency/accountability through its relationship with stakeholders and staff has
helped to build a corporate culture. Management and staff training has focused on promoting the visions and
values as outlined in the statement and on bringing people closer together, enhancing their understanding of
other areas within the FSA.
Question 3.3
Does the agency have the flexibility (financially and/or in terms of political autonomy) to establish its
own culture and to institute employment terms and conditions of employment consistent with the
desired culture?
APRA has maintained a certain degree of flexibility in establishing its own culture and sets of employment
terms and conditions. Since APRA is an authority, as opposed to being an agency, it is not bound by the
standard terms and conditions of the public sector. As such, APRAs new integrated set of employment terms
and conditions are unique, being different from those conditions found in the public sector, private sector and
in those supervisory bodies who combined to create APRA. A flexible remuneration framework has been
developed which is performance based.
To some extent yes. While OSFIs status is technically outside of the regular public service there are some
limitations placed on OSFI' autonomy in these areas by its enabling legislation, the unions, central
government agencies and parliament.
Recently, the Danish Financial Supervisory Authority has been given a certain amount of flexibility to use
incentives as part of human resources management.
In accordance with the National Public Service Law Article 28, the salary, work time and other working
standards must be corrected in order for basic benefits to be at the same level as the private sector.
Kredittilsynet has substantial flexibility with regard to developing its own corporate culture, but rather limited
flexibility with regard to employment terms. Kredittilsynet is bound by the general rules applying to
employment conditions for government employees (state and municipal). Certain exceptions have been granted
to Kredittilsynet to offer better employment terms or flexible terms where it has been considered crucial in
order to attract or keep well-qualified experts. As mentioned previously, within the overall budgetary
restrictions, the management of Kredittilsynet has a certain amount of freedom with regard to the size and the
distribution of manager, specialists, professionals and non-professionals. During the last years, Kredittilsynet
has been emphasising quality rather than quantity in its recruitment policy.
Generally, MAS has the autonomy to set its own remuneration policy and terms and conditions of
employment. However, as we are a statutory board, we are required to comply with certain terms such as
medical benefit, car benefit etc. so as to be in line with the policy of the civil service.
FSA has the flexibility, within the frames of the legislation for civil servants, to decide on employment terms
and conditions.
United Kingdom
The FSA has instituted its own employment terms and conditions which, in some cases, were quite different
from the former constituent organisations terms and conditions. These FSA terms and conditions are
consistent with the desired culture and are flexible in offering employees the opportunity to select their own
benefits package tailored to their own individual circumstances through a flexible benefits plan.
Question 3.4
How do the terms and conditions of employment currently offered by the agency compare with those
available to staff in the private sector?
As specified in question 3, APRAs set of employment terms and conditions are unique. While the
remuneration packages are typically lower than those in the private sector, they are still at a level which
exceeds the standard public sector levels.
A recent comparison with the financial services industry showed that there are significant gaps in the
compensation levels of some OSFI staff compared to other regulatory bodies and the financial sector. We are
working on strategies to respond to this issue. In terms of other working conditions such as hours of work,
flexible work arrangements and benefit programs, OSFI compares fairly well with the market.
Wages are on the Government scale. They are lower than those of the private sector. In special cases it is
possible to pay wages higher than those on the Government scale. Jobs in supervision are attractive because
they are more all round jobs than those in the private sector.
See question 3.3
Similar levels as domestic financial institutions average payment and benefits.
Salaries offered at Kredittilsynet are somewhat lower than in the private sector. However we endeavour to
attract well qualified people by other means, e.g. by offering flexible employment terms (flexible work hours
training and educational, the flexibility to work part time if there is no conflict of interest, for example
teaching) In addition we have experienced that employees who have left Kredittilsynet in order to work in
the private sector have come back after a few years. The reason is often that the work is more challenging and
that they feel that they can accomplish something useful, they have more independence and responsibilities.
The market appreciates the experience gained by working at the supervisory authority. (Sometimes the work
pressure/load in the private sector is not compensated by enough salary, whereby the supervisory authority
would pay overtime whenever this is needed).
Our system of flexible working hours has proven attractive to professionals with young children (both male
and female). Presently 50% of the staff are women. Rules pertaining to the granting of leave of absence are
better than in the private sector. Employees are granted leave of absence for educational purposes, in order to
gain experience from the private sector or other entities within the public sector, for parent leave, etc. The
leave of absence may also be spent abroad.
MAS aims to pay a competitive remuneration package vis--vis those in the financial sector. Our pay package
is pegged at 75
percentile, with the best being paid at the 90
percentile, of market.
In general wages in the private financial sector are much higher than is FSA. Other terms and conditions are
United Kingdom
The terms and conditions of employment currently offered by the FSA aim to be equivalent to terms and
conditions in comparable finance organisation sector (generally aiming to be equivalent to the second quartile
conditions, excluding investment bank bonuses).
Question 3.5
What has been the main source of supervisory staff:
Other supervisory agencies
Other government departments; or
Private sector recruitment?
The majority of APRAs current staff comprise the former staff of the regulatory bodies combined to create
APRA. These included the former Insurance and Superannuation Commission, Bank Supervision Department
of the Reserve Bank of Australia, Australian Financial Institutions Commission and the various state
supervisory commissions. The make-up of the staff from these former institutions comprised both private
sector recruitments, along with university graduates.
By far the major source of supervisory staff has been the private sector and particularly the financial services
Mostly private sector recruitment and new graduates
The FSA, by necessity, has to secure staffs with experience in financial supervision; therefore, a large number
of staff who were engaged in inspection and supervisory operations at the Ministry of Finance have been
transferred with the establishment of the agency. At the same time, the FSA recruited staff from 13 ministries
as well as public accountants and commercial law experts from the private sector. A number of people who
have practical business experience in the private financial sectors have been hired as part-time staff after the
establishment of the agency.
Staff from four existing supervisory agencies: 1250
Private sector recruitment: 18
When Kredittilsynet was established in 1986, the insurance supervision and the banking supervision (which
already included the supervision of the securities market) were emerged and Kredittilsynet hired the staff from
these supervisory authorities. The same happened on 1 January 1999, upon taking over the supervision of
accountants, the staff of this previous supervisory agency was transferred to Kredittilsynet. Otherwise there is
no recruitment from other supervisory agencies, since Kredittilsynet is the only financial supervisor in Norway.
The current employees of Kredittilsynet have been recruited from:
The public sector: 43.3%
The private sector: 41.4%
Schools/Universities: 15.3%
MAS recruits its staff principally from fresh university graduates. A significant number of mid-career recruits
from the private sector have also been hired, especially in the last year. There has also been a small number of
staff seconded from either the public or private sectors.
A mixture of the named sources.
United Kingdom
The current staff resources have been largely taken over from the constituent parts of the old regulatory system
(a number of whom were recruited directly from the private sector), enhanced by private sector recruitment. In
future, then aim is to recruit from a range of different sources, balancing the need for an understanding of the
market with specialist policy making skills. In practice it is likely that most recruitment will in the future be
from the private sector.
Question 3.6
Does the agency make use of internal secondments from the private sector to provide specialist
To date, this has not occurred within APRA.
Yes, this is done from time to time.
Yes, but not to a large extent. Mostly auditors.
We have four advisers (part-time) such as an economist, accountant and lawyer in order to receive instructions
and advice from the professional field when implementing financial supervisory regulation. Also, at the time of
the establishment of the FSA, we recruited staff from private sectors such as certified public accountants and
commercial law experts, and for part-time staff, we have recruited a number of staff with experiences in
private financial sector.
Kredittilsynet does not make use of secondments from the private sector. Due to the potential conflict of
interest our ethical guidelines do not allow us to employ a person for a fixed term before returning to a specific
financial institution.
However, Kredittilsynet may hire experts from the private sector with specialised skills. Over 40% of the staff
have experience from the private sector.
Yes. However most private sector entrants have been recruited by MAS rather than seconded by their
United Kingdom
Yes, the FSA does make use of internal secondments from the private sector, although the supply of good-
quality secondees is unfortunately rather limited. Currently around 40 of the 1750 staff are on secondment.
Question 3.7
Does the supervisory agency aim to develop staff with expertise in particular areas, or to ensure staff are
well-versed in all areas of the agencies activities (ie does it look for specialists or generalists)?
APRA seeks to develop both staff with specialist skills, particularly in the Policy, Research and Consulting
division, as well provide staff with well-rounded supervisory skills. Cross-skilling will be provided by both a
formal training program and regular rotation of staff through different areas.
Both. OSFI aims to make its supervisory staff generalists and encourages cross training in different areas. The
university recruitment programs provides new employees with training in all sectors of OSFI. OSFI also
searches for specialists to provide greater technical expertise in some functions.
The Danish Financial Supervisory Authority aim to develop staff who are generalists with a special knowledge
of the financial sector and a few specialists (actuaries).
The FSA aims to foster specialists and generalists at the same time.
The FSS aims to develop specialists.
It is a challenge for a supervisory authority to achieve the optimal balance between generalists and specialists.
In certain areas, we have specialist staff. However, there is a danger for the supervisory authority of becoming
vulnerable if a small number of persons have highly specialised skills. Kredittilsynet tries to ensure that at least
more than one person have the same specialised skills. (There are some staff members specialised in capital
adequacy/credit risk analysis, actuarial functions and macro-economic surveillance).
We aim for a balance of specialists and generalists. The MAS has relied principally on specialists in the past. It
has been placing greater emphasis since 1998 on developing generalist instincts and skills, and on rotation of
staff across specialist functions.
Even here the FSA tries to have a mixture of specialists and generalists.
United Kingdom
The FSA aims to strike a balance in which both specialists and generalists will find a career in the FSA. The
FSA will continue to recruit staff with a view to training them to become rounded regulators (e.g. graduate
recruitment) but will also offer careers to specialists, although in reality ,many of the specialist might well
come to the FSA from the private sector for shorter periods of time, returning to the industry.
Question 3.8
Given the often unique nature of supervisory tasks, what training programs have been established to
develop the supervisory skills of staff? Are these largely in-house programs, or external training.
APRA is in the process of developing a training strategy and program. A Reference Group has been set up to
provide ideas and advice for APRAs learning and development strategy. Various in-house training sessions
have been organised, which use both internal resources as well as industry experts. External programs such as
training sessions organised by various industry bodies are also used by APRA to train its staff. APRA
encourages staff to engage in various postgraduate courses run by tertiary institutions, and is investigating the
viability of running (in combination with a tertiary institution) a post-graduate course in prudential supervision.
The use of secondments to both domestic and international institutions is also encouraged as a means to
enhance the knowledge and skills of APRAs staff.
OSFI has undertaken to train staff using both in-house and external resources. For example, OSFI has entered
into a joint venture with the international training unit of the Federal Reserve Board in Washington to give
courses to OSFI staff. As well, OSFI has hired a consulting firm to develop and deliver leading edge technical
training in asset liability management, modelling and risk assessment, asset and liability management
strategies and liquidity management. Finally. OSFI staff have developed and delivered in-house courses on
various subjects related to the supervisory process.
In house training programs, learning by doing as well as external training is used.
The FSA is strengthening the training program for staff in order to secure the expertise and high level of ethics,
since the implementation of fair and transparent financial supervision based on clear rule is a prerequisite to
raison detre of the FSA. In general, training programs are designed and carried out according to staffs
experiences, and they consist of not only theory such as accounting, but also practical training on inspection
techniques such as checking soundness of assets of financial institutions and their market risks. Most of this
training is based on the internal program designed by the FSA, but when needed, the FSA also use external
training programs. The recent example is the implementation of Intensive Training on derivative transactions
based on external programs, from the risk management point of view.
To develop supervisory skills among the staff, the FSS has arranged various programs, including development
of insurance specialists, securities specialists and bank specialists. These programs are being offered by a
combination of in-house and outside training institutions.
Kredittilsynet has both in-house training programs and supports external training. There is a high degree of
flexibility with regard to choice of training programs. These programs may be tailor-made to one or several
persons, or one or several persons may attend external programs or courses. We also participate in staff
exchange programs with the other Nordic supervisory authorities. As mentioned previously, employees may be
granted leave of absence for further professional studies, for trainee periods elsewhere (including at the
European Commission in Brussels). Several staff members have also been working for shorter or longer
periods of time in a supervised financial institution in order to gain experience in particular areas that would be
valuable for their functions at the supervisory authority.
Supervisory staff are sent for both overseas and local training courses to equip them with functional skills.
External training and internal programs are provided. In addition, we have in place a regular program for
external attachments, both locally and overseas. These include attachments or study visits to central banks and
supervisory authorities to provide exposure to international financial regulatory issues as well as to operational
aspects of banking and other financial institutions.
The training programs for inspectors are largely in-house programs.
United Kingdom
The FSA is in the process of establishing a training strategy for its staff. At the moment training is partly based
on the individual training programs offered in the constituent organisations, focusing mainly on technical
training. These are largely in-house programs but might include attendance at specific training sessions run by
the industry. In addition, the FSA runs management training and other more general training programs, devised
largely specifically for the FSA but carried out with external help.
Question 3.9
Where the supervisory agency has been formed by joining together a number of industry-based
supervisors, how has the problem of differences in culture and in terms and conditions been addressed?
The problems of differences in culture and in terms and conditions have been addressed in several ways. A
completely new set of terms and conditions have been introduced, and a new organisational structure has also
been designed which integrates into a single areas many of the activities previously performed separately by
the different supervisory agencies. For example the Specialised Institutions Division brings together in one
Division, institutions which were supervised by three former supervisors (the ISC, AFIC and RBA). Several
in-house training courses have also been organised to facilitate the integration of both staff and ideas.
OSFI was formed in 1987 through the amalgamation of the Inspector General of banks and the Department of
Insurance. Both of these were government agencies that had mostly similar organisational cultures, but
somewhat different operational procedures. These differences have gradually disappeared over the life of OSFI
through the use of methodology reviews plus reorganisation and the infusion of new staff.
With respect to terms and conditions, they were identical.
The problem has been addressed in a number of ways:
Cross sectoral centres of expertise has been created for example in the fields of:
- Market risk
- Credit risk
- Financial conglomerates
- Interpretation of legislation
Each unit has inter-disciplinary staff.
Projects manned by staff from several units
Relocation of staff between the units.
The FSA was not established as a composite of several supervisory agencies, but was established by
transferring supervisory-related Departments from MOF which had overseen all financial sectors as a single
Before the integration, a rational integration model was developed in consultation with a consulting firm, and
the model was fully discussed between interested parties until they reached a consensus.
- After integration, to establish an organisational culture and sense of unity among supervisory
personnel, various employee morale programs are being practised.
Kredittilsynet has been reorganised several times since it was formed in 1986. These reorganisations have
partly been initiated in an attempt to solve cultural problems. When Kredittilsynet was formed in 1986, it was
thought that it would be crucial to fully integrate the insurance supervision with the banking and finance
supervision. The integration was perhaps exaggerated, and did not take into account the specificity of
insurance technical matters. Particularly with regard to actuarial issues, it became apparent that there was a
need to create a better team-culture by uniting the actuaries and experts in insurance legislation in one section.
Thus a separate insurance section within the finance and insurance department was established in 1993. The
responsibility for on-site inspections and off-site supervision remains within these functional sections.
Similarly, separate international department had been created in a major reorganisation in May 1991. Soon it
became apparent that all aspects of financial supervision were becoming more and more international, and it
was not natural to separate the international issues in a small department. Every section and department was
becoming involved in international issues. Instead of an international department there is now an International
Coordinator in the staff of the Director General who coordinates the international activities across sections and
N/A. The MAS has been a consolidated supervisor of financial institutions and markets since the 1970s.
This problem has not occurred in FSA.
United Kingdom
The FSA brought together nine constituent bodies (see attached). A completely new set of terms and
conditions has been introduced. A new structure has been devised and staff has been moved to a new, single-
site location. The FSA has thus aimed to create a new identity and culture which is new to staff from all
constituent bodies (i.e. where no one organisations culture dominates) but fits in with the new visions and
values in creating a single regulatory authority.