三大视角深度解析海内外中央银行差异

Report Summary 1. Report Industry Investment Rating No industry investment rating is provided in the report. 2. Core Viewpoints - The differences in central bank systems between domestic and overseas are systematic in deposit reserve systems, accounting system frameworks, and financial regulatory mechanisms, reflecting different economic structures, financial market development stages, and policy goals [3][75]. - These differences are rational choices based on each country's economic development stage, financial market structure, legal system tradition, and policy goal priorities. Developed countries tend to adopt market - led institutional arrangements, while emerging market countries focus more on policy execution, risk prevention, and system stability [75]. - In the future, with the further integration of global financial markets and enhanced macro - policy coordination, central banks may learn from each other's experiences while maintaining their own characteristics to optimize monetary policy frameworks and financial regulatory systems [75]. 3. Summary According to the Catalog 3.1海内外存款准备金制度的异同 - Historical and Current Significance of Deposit Reserve System - Historically, it was a fundamental tool for quantitative regulation, controlling inflation and preventing bank runs by limiting banks' lending capacity [8]. - Currently, it serves as a tool for structural regulation and liquidity management, with functions such as adjusting liquidity, supporting key areas, performing counter - cyclical regulation, and guiding market expectations [8]. - Overseas Deposit Reserve System Status - Countries with 0% Reserve Requirement: The US, UK, Australia, and Canada have a 0% legal deposit reserve requirement. Their monetary policy has shifted from quantitative to price - based, with the marginal role of legal reserves significantly reduced [9][13]. - Japan and South Korea: They still maintain the legal deposit reserve system, with rates ranging from 0% - 1.3% in Japan and 0% - 7% in South Korea. They keep it as a "base" and operational support for payment and settlement stability and special - period adjustments [19]. - Domestic Deposit Reserve System Status - "Implicit Lower Limit" of 5%: It reflects the central bank's "psychological bottom line" in the quantitative monetary policy framework. The reserve system has shifted from a "strong constraint" to a "weak constraint" on bank leverage [23]. - Significance: It provides a macro - level buffer for the indirect - financing - based financial system, offers policy space for counter - cyclical adjustment, and is suitable for the current monetary policy operation framework [23]. - Potential Directions: The system is likely to be retained. A more feasible short - term path is to unify standards before discussing breaking the "implicit lower limit." Introducing inventory cash as a reserve alternative could release liquidity [26]. 3.2海内外央行会计制度的异同 - Differences in Central Bank Balance Sheet Items - Asset Side: China's central bank's assets are mainly foreign exchange assets and claims on financial institutions, while those of the US, EU, and Japan are more concentrated in bond holdings, due to different money - issuing mechanisms [28]. - Liability Side: China includes currency issuance and financial institution deposits in the "Reserve Money" item, and currently has no "reverse repurchase agreement" item. Its main way of base - money injection is through adjusting the deposit reserve ratio [41]. - Differences in Accounting Element Measurement Attributes - China: It mainly uses historical cost for asset measurement, which helps maintain financial market stability and reduces workload [52]. - Overseas: Central banks use various methods such as amortized cost, historical cost, and fair value. The reasons include differences in policy goals, fiscal relationships, profit - distribution mechanisms, and legal systems [57]. 3.3海内外金融监管体系中宏观审慎与微观审慎的差异 - US Financial Regulatory System - Macro - Prudence: The Financial Stability Oversight Council (FSOC) is the core coordinating body, with the Fed providing stress - test data and other agencies providing relevant risk data [65]. - Micro - Prudence: Different agencies are responsible for the micro - prudential supervision of different financial sub - sectors, such as the OCC for national banks and the Fed for bank - holding companies [65]. - China's Financial Regulatory System - Macro - Prudence: Under the overall coordination of the Central Financial Commission, the People's Bank of China is the core executive department, responsible for most capital - market macro - prudential management outside the on - exchange market, and the China Securities Regulatory Commission is responsible for on - exchange market supervision [68]. - Micro - Prudence: Different agencies are responsible for the micro - prudential supervision of different financial sectors, such as the People's Bank of China for specific areas and the National Financial Regulatory Administration for most non - securities financial institutions [68]. - Similarities and Differences between China and the US - Similarities: Both countries have established higher - level committees for overall management, involve central banks in macro - prudence, and have commonalities in micro - prudential regulatory goals and indicators [73]. - Differences: China emphasizes centralized and unified management, with administrative coordination and window guidance in macro - prudence, while the US has a multi - agency, market - oriented, and legalized regulatory system [73]. 3.4结语 The differences in central bank systems between domestic and overseas are profound and diverse, which are rational choices based on different national conditions. In the future, international cooperation in the fields of digital economy, cross - border capital flow, and systemic risk prevention will be crucial for the construction of a more resilient and inclusive global financial system [75].