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Financial Structure in Moldova, Turkey and U.S.A: Eskișehir Osmangazi University
Financial Structure in Moldova, Turkey and U.S.A: Eskișehir Osmangazi University
Financial
structure
in
Moldova,
Turkey
and U.S.A
Financial Management Report
1
Financial Management
Irina Paduret
Abstract
The main task of building a financial structure is the distribution of responsibility and authority
between managers in managing revenues, expenditures, assets, liabilities and the company's
capital. The financial structure is the basis for the introduction of management accounting,
The Center for Financial Responsibility (CFD) is an element of the financial structure of a
company that performs business operations in accordance with its budget and has the necessary
Financial and organizational structures are closely related, but may not coincide. Each budget
period begins with the actualization of the financial structure, with the goal of correctly
distributing authority and responsibility. Often a change in the financial structure leads to
1. Describe the business processes and functions of the units: implementation, procurement,
logistics, production, accounting, personnel service, etc. to determine the items of income
responsibilities of CFOs;
As a rule, the financial structure has several levels of subordination. The first-level CFA is a
holding company as a whole. Usually it is the center of investments, the responsibility for
The second-level CFA is an independent enterprise within the holding. Usually these are profit
CFA of the third level are subdivisions of the enterprises belonging to the holding (for example,
The CFDs of the fourth level are divisions of the subdivisions of the enterprises belonging to the
holding (for example, accounting and finance department in the financial department).
Heads of the Central Federal District are responsible for the fulfillment of the assigned tasks and
must have the necessary powers and resources. Depending on the powers and responsibilities of
managers, a structural unit can be a cost center, a revenue center, a profit center, an investment
center.
The cost center is a division whose head is responsible for the fulfillment of the assigned
tasks within the allocated budget of expenses (for example, personnel service,
accounting, ACS).
The revenue center is a division whose head, within the allocated budget, is responsible
The profit center is a division whose head is responsible for profit and has the authority
The Investment Center is a division whose head has the authority of the head of the profit
center, and is also responsible for the level and efficiency of investments.
quality (reliability and uniqueness) of the planned and reporting information of the
Moldova has made some important advances since the 2008 FSAP Update. On the positive side,
inflation has been brought down to single digits, the payment system has been upgraded, and
important enhancements have been made to financial sector regulation and supervision.
However, risks to banking sector stability have become severe. Large credit concentration and
concealed connected lending, questionable cross-border exposures, and important data gaps
mean that regulatory data likely significantly understate the system’s vulnerability. Non-
powers and enforcement further exacerbate these risks and could limit the scope for an effective
policy response to shocks. Governance structures, internal oversight processes, and risk
management practices are poorly developed. In some cases, cross-border exposures are
substantial and the pattern of some (particularly cross-border) financial transactions suggest a
Although stress tests suggest the banking sector is well capitalized and liquid, important pockets
nonperforming loans (NPLs) for some banks are remarkably high, while in other cases a
reduction in NPLs may reflect regulatory arbitrage rather than a substantive reduction in risk.
Large exposures in some cases exceed regulatory norms by a wide margin. Also liquidity risk is
hard to measure, as the high reported level of liquid assets appears unreliable: some assets may
The impact of recent regional geopolitical developments on the Moldovan economy will depend
on whether the crisis spreads beyond Ukraine, trade tensions with Russia escalate, and trade
routes and gas supplies are disrupted. Financial and trade relationships with Ukraine are modest
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Financial Management
but a further slowdown in the Russian economy and/or an escalation of trade tensions with
Russia would have a significant impact, not least given some significant cross-border bank
exposures to Russia.
Against this background, the independence and effectiveness of the regulatory bodies needs to be
challenges, including Constitutional Court (CC) rulings that have allowed the suspension of
supervisory actions. Moreover, National Bank of Moldova (NBM, banking supervision) and the
National Commission for Financial Markets (NCFM, nonbank supervision) board members and
staff do not have sufficient protection against lawsuits, even while discharging their duties in
good faith. While the authorities are generally supportive of reform, progress in obtaining
parliamentary approval has been slow and the authorities have been unable to address fraudulent
raider attacks on banks, to limit large bank exposures, or to address serious weaknesses in the
privately-run securities registries. And in the meanwhile, there have not been sufficiently
The crisis management framework is weak, and cooperation between regulatory authorities
requires improvement. A National Committee for Financial Stability (NCFS) was set up in 2010
to bring together key stakeholders in financial sector stability, though its remit is focused on
crisis management. However, while the NCFS proved useful in addressing problems which arose
in 2012, it could do more in the areas of contingency planning, testing of processes and powers,
and coordination between the member agencies. There are also significant gaps and deficiencies
in the statutory powers required for cost-effective bank crisis resolution. If systemic pressures
were to emerge, it would be critical for the NCFS to ensure a focus on managing the situation in
There is room also to strengthen the financial safety net. The Deposit Guarantee Fund (DGF) is
reasonably funded for the current level of coverage, which includes foreign exchange deposits,
although depositor protection is the lowest in Europe at MDL 6,000 (about USD 445). But the
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Financial Management
DGF lacks the capacity for rapid payout in anything other than very small cases, and there are no
established funding lines available, which could impede the ability to make rapid payouts. The
DGF also needs better access to sufficient and timely data for more rapid and accurate payouts.
In addition, there are some small financial entities supervised by the NCFM that accept deposits
The two securities settlement systems are in need of updating, though plans to take this forward
are not finalized. The corporate securities registry system displays governance and infrastructural
weaknesses, which are not expected to be addressed in the near term. Settlement of government
and central bank securities, and of equities, is delivery versus payment (DVP) in central bank
money. But the settlement systems are old and ill-suited to any expansion of trade. Registration
of equities is split between 11 private registries, which run manual systems—in some cases with
no reliable data back-up—and are vulnerable to fraud and abuse of data. The recently adopted
law on capital markets does not provide a forceful or timely framework for addressing these
shortcomings.
The insurance sector is small and almost entirely restricted to motor insurance. There have been
few new entrants to the market for some years, and anticompetitive practices deter entry and
growth. The NCFM is keen to move to risk-based supervision. This is a worthwhile goal, but
Weaknesses in the insolvency and creditor/debtor regime create uncertainty and may deter some
stakeholders from engaging in financial transactions. There is no rescue culture for distressed
enterprises, and the system incentivizes administrators to liquidate rather than reorganize.
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Financial Management
its trading partners and reliant on remittances and donor support. Remittances from
Moldovan workers abroad are around 24 percent of GDP (on a declining trend), and
donor support to the budget is equivalent to 10 percent of total spending (Figure 1).
Inflation is within the NBM’s target range of 5 percent ±1.5 percent. With nominal
exchange rate depreciation (9 percent since end-2012), the MDL has depreciated by 1
percent in real terms. In per capita GDP terms, Moldova is the poorest country in Europe.
2. The financial system is dominated by the banking sector, which in turn appears to be
controlled by a small number of individuals. There are 14 commercial banks (four are
compared with neighboring peers. Five of the six largest banks reportedly form two de
facto groups, and have a combined 60-70 percent share of the banking system, giving rise
to a “too big to fail” problem. Similarly, the owners of these groups also reportedly
etc. Funding is primarily from retail deposits, while credit appears to be mainly to
commerce and industry (Figure 2).1 FX assets and liabilities account for around 45
percent of balance sheet totals. Since end-2011, cross-border financial linkages have
increased sharply and have become more complex. (Figure 3). During this period, foreign
percent of GDP.
3. Nonbank financial institutions and markets are still small and underdeveloped. The
insurance sector is small at 3.5 percent of total financial sector assets and is growing only
in line with GDP. Microfinance institutions and some small deposit-taking credit
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Financial Management
associations—regulated by the NCFM—are increasing in number but their reach and size
is not growing.
4. The capital market is small: the Moldova Stock Exchange, controlled by the banks, is
illiquid. Turnover in 2013 represented less than 1 percent of GDP, and market
percent of GDP,2 and government securities are limited to short-term issues, with a
maximum maturity of three years. The secondary market is thin; banks are the primary
dealers and investors in this market. The NBM regularly issues 14-day bills, on a fixed-
rate full allotment basis, to drain excess reserves. There are no significant private
investment undertakings.
1. The most significant financial risks are hard to quantify and stem from deep and
interconnected weaknesses. Gaps in the authorities’ legal powers and protections leave
them poorly placed to address significant shortcomings in governance of both banks and
non-bank financial institutions. Failure to identify and assess the integrity and
competence of the control and ultimate beneficial ownership of the banks and other
financial institutions means the scale of concentration and potential for contagion within
A. Legal System
including its ability to revoke authorization. The ruling permits any court to suspend
NCFM’s decisions pending a final court decision, and a number of NCFM regulatory
actions have been suspended since then. A draft law is in Parliament; however there is no
clear view among the authorities if the NCFM should be given greater powers.
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Financial Management
3. A similar CC ruling on October 1, 20133 curbed the NBM’s powers to effectively carry
out its functions. The decision permitted any court to suspend key actions and decisions
of the NBM before final settlement of the case, with two exemptions to the ruling,
amendment partly restores some of the powers of the NBM, in particular protecting its
monetary authority, and putting some constraints on court orders to suspend regulatory
actions.4
4. A number of other factors hinder the NBM’s effective regulatory and supervisory actions.
These include (i) need for procedural consistency and clarity on preliminary appeal of
NBM decisions; (ii) need for clarity on scope of the judicial review process particularly
relating to NBM supervisory decisions, so that the courts should focus on the legality of
NBM actions, rather than contesting the substance; (iii) allocation of the burden of proof
to the plaintiff; (iv) need for detailed procedures of appeal of the administrative
authorities’ normative decisions to shorten the current unlimited timeframe; and (v)
the NBM. While the government in principle supports the legislative changes necessary
B. Bank Governance
5. Many bank ownership structures are unduly complex, using shell companies, often
offshore, to disguise the identity of ultimate beneficial owners (UBOs). Major changes in
the ownership structure of the largest banks in the past two years have been accomplished
by acquisition of voting shares in parcels below the 5 percent threshold for regulatory
consent, as well as through fraudulent “raider attacks” that undermine the interests of
high-cost deposits, including interbank placements channeled via offshore banks. There
are indications that a substantial portion of this funding has gone to finance owners’
7. The roles and responsibilities of ownership, internal oversight (board), and management
are substantially blurred, undermining governance. All banks indicated that the
controlling shareholders nominate and appoint board members, creating boards that have
interests of the depositors, public and taxpayers despite fiduciary duty imposed by the
Law on Financial Institutions (LFI). The ambiguity of the UBOs and their nontransparent
actions masks the board member nomination processes. There are no independent board
members and the minimum number of three directors is unusually low. Furthermore, the
controlling shareholder typically appoints the CEO, who is vested with substantial
8. Boards lack independence, and are not well qualified to oversee financial institution
operations. Board members can exhibit conflicts of interest, and few have substantial
financial institution experience. Members are appointed for a term of four years, they can
9. Boards do not fulfill their proper role of strategic planning, oversight or risk
management as well as internal audit. Neither board audit committees nor other board
committees, such as board risk committees, are in place. The risk management
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Financial Management
mechanisms necessary to identify, measure and report existing and potential risks are not
formalized and are not effectively independent. Boards are not made explicitly
responsible, by law, for the truthfulness and integrity of their banks’ financial reporting.
10. Internal audit functions lack independence. Although auditors meet with the board, none
indicated that they regularly meet without management present. Consistently, audit
C. Asset Quality
11. Sector wide asset quality is deteriorating and is of significant concern in some banks.
While NPLs were trending down in 2013, reaching 11.6 percent by year end, they rose to
13.2 percent in the first quarter of 2014. Some banks, including systemic institutions,
have NPL ratios exceeding 60 percent of total loans. Despite the Insolvency Law of
2013, which sought to encourage restructurings, the insolvency culture remains weak and
enhanced creditworthiness. This risks placing too much emphasis on collateral rather
12. Incorrect use of low risk weights for loans secured on residential property6 and numerous
cases of loan misclassification undermine the reported capital adequacy figures. Reliance
while concentration risk arises from breaches of large exposure limits. In some cases,
very large deposits are placed cross-border in obscure transactions, which may combine
fictitious creation of ‘liquid’ assets7, tax evasion, and money laundering. Additionally, a
few commercial banks have substantial reliance on sizeable (largely FX) deposits placed
13. Dollarization is not a particular concern at present. The proportion of FX assets and
liabilities on commercial bank balance sheets has been stable over the last six years. FX
during this period and FX deposits from 44 percent to 54 percent. The continuing high
level of remittances and sufficient level of foreign exchange reserves mitigate the risks of
loans. It will be important for the NBM to ensure that banks maintain vigilance and do
not provide FX or FX linked loans unless the borrower has a reliable FX income.8
Moreover, banks need to take due account of the credit risks involved, as well as the FX
exposure. It will also be important to ensure that FX assets placed in banks abroad are
freely available: there are indications that some balances, while notionally overnight
D. Insurance Sector
14. The insurance market has consolidated and improved its financial strength since the 2007
Law on Insurance was introduced. The number of insurers has reduced—from 28 to 16—
in the nonlife sector but actual concentration may be greater than this, as unidentified
UBOs obscure the picture. Capital and solvency requirements based on the “Solvency I”
regime have been introduced and enforced. Reported technical provisions have improved
in strength.
15. The small size and absence of development of the insurance sector implies no material
systemic risk. Insurer investments in the banking sector appear manageable compared to
capital levels. Cash and bank deposits represent just 3 percent of life insurance assets and
9 percent of nonlife assets but ownership linkages with the unknown bank UBOs are
16. The opaque share registry system has compromised the effective regulation of banks and
insurance firms. The securities records of joint stock companies (JSCs) are scattered
across 11 registrars, which operate independently and have outdated standards and
registrars with a central depository have failed to date but there are attempts to reform the
Capital Market Law (CML), mandating the transfer of the registries of securities of
being developed by the NCFM to provide daily backups of all corporate securities
transactions, once the legislation is passed. Data verifications will be performed based on
17. Legal uncertainty regarding the settlement of government and central bank securities are
being addressed through new draft laws. Specific legal provisions are needed to protect
investors’ rights in the Book-Entry System (BES). The adoption of such laws is
important, although currently trade volume is low. There are plans to allow trading of
government bonds onto the Moldova Stock Exchange (MSE), though trading on the
18. Liquidity and general business risks are apparent at the National Securities Depository
(NSD), which require greater oversight. Liquidity risk arises from a three day settlement
standard, although there has been no participant default since operations started in 1998.
The size of the guarantee fund (fixed at MDL 30,000 per participant) appears to be
insufficient to handle potential settlement risks. A history of losses by the NSD suggests
little scope to raise funds for investment in new infrastructure and there appears to be no
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Financial Management
19. Regulatory fragmentation between NBM and NCFM could undermine the effective
oversight of FMIs. The authorities need to adopt and apply consistently the CPSS-IOSCO
Principles for FMIs, and allocate or share responsibilities according to their mandates and
Conclusion
The mission assessed financial sector risks and vulnerabilities, evaluated thequality of financial
sector regulation and supervision, and assessed financialsafety net arrangements. The mission
found significant risks in the bankingsector arising from non-transparent ownership of financial
andenforcement. The IMF and the World Bank are working with the authoritieson necessary
Economic performance
The recent global developments led to a rapid contraction in the world economy and financial
markets and deceleration in trade volume . Starting from the last quarter of 2008 in particular,
the global issues have had considerable reflections in Turkey, whose foreign trade volume
reached 50 percent of its gross domestic product. Both domestic demand and external demand
decreased. Output and income declined.External financing became more limited. The
unemployment rate increased. In the public sector, the budget deficit expanded and the public
sector borrowing requirement increased.On the other hand, interest and inflation rates have
fallen.
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Financial Management
domestic product (gdp) in real terms fell by 6.2 percent in the last quarter of 2008 and by 10.6
percent in the first half of 2009 compared with the same period of the previous year.
rate, which was 10.3 percent in September 2008, increased to 16.1 percent in February 2009.
Partly due to the effect of the tax reductions implemented in certain sectors, the unemployment
In Turkey, the financial sector is yet at the stage of growth. It is small and shallow when
It is estimated that the ratio of financial assets, consisting of bank assets, shares and public and
private borrowing instruments, to gdp was 150 percent for Turkey, 246 percent for developing
countries and 421 percent for the world in 20013.The banking system has a major share in the
financial sector. In recent years, non-bank financial institutions have grown in number and size.
The financial services sector in Turkey includes banks and insurance companies and non-bank
At the end of 2014, the rate of total assets to gdp was 78 percent for the banking sector, 2.6
percent for the insurance sector, and 2.5 percent for mutual investment funds.In the financial
system, there is not a single authority responsible for supervision and inspection. The supervision
and inspection of banks and leasing and factoring institutions in Turkey is performed by the
Banking Regulation and Supervision Authority (bddk.org.tr). Banks are subject to regulation and
supervision by the Capital Market Authority for their capital market operations.
Generally, following the crises in 2007 and the restructuring process, the banking sector showed
a rapid growth performance in 2009-2015 period. The total assets rose from USD 130 billion to
USD 465 billion, their ratio to gdp from 57 percent to 77 percent. The numbers of branches and
staff rapidly increased.In this period, the financial structure of the sector also became stronger.
The shareholders’ equity of the sector increased from USD 16 billion to USD 54 billion and its
free equity from USD 3 billion to USD 40 billion. The capital adequacy ratio which was 18
percent as of December 2008, continued to grow and reached 19.4 percent in the first half of
2011. In addition, the risk management systems improved and public supervision became more
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Financial Management
effective in this period .The positive developments recorded by the banking system in 2009-2015
period have several reasons,includind the favorable domestic and international economic
situation and the change in the risk management conception.Another important reason is the
The financial system of the United States is complex and diverse, consists of a variety of state
federal and other authorities and administrations, financial and administrative departments and
institutions, private banks and corporations that carry out both domestic and international
financial transactions. Due to the huge impact on the entire global economy and world finance,
the US financial system more than any other national system is part of the global financial
system. The state budget occupies an important place in the overall structure of the US financial
system from the point of view of the state's influence on the state of finance, the economic
situation, the nature and direction of the government's economic policy. He acts as a powerful
indicator in determining the long-term plans of large corporations and banks. This role is obvious
already because of the enormous amount of public spending that directly and directly affects the
state of the economy and finance, the activities of manufacturing and trading firms that
implement state orders, banks and other financial institutions that serve the budget programs of
the US government.
In the financial system of the United States (like many other developed countries), banks play an
increased role. According to the Law of the Sigal Voice, banks are divided into commercial and
investment banks.
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A special role is played by the Central Bank of the country - the Federal Reserve System (FRS).
macroeconomic responsibility increases throughout the post-war decades, including in the 1990s.
However, the Fed is only partially responsible for overseeing banks and divides this function
The methods of state influence on the financial market are direct and indirect. Direct exposure
methods include:
o measures taken by the Securities and Exchange Commission and the Commodity Futures
Commission on their sectors, including the adoption of new and changing old provisions
and norms of exchange practices, bringing to justice (on the administrative line or
through the court) persons who violated such norms and other.
Methods of indirect state regulation are implemented by the Board of Governors of the Federal
Reserve System, the Ministry of Finance and the aforementioned commissions. In addition, these
bodies can influence the exchanges with the help of representatives of government agencies (so-
called independent representatives), members of the boards of directors of some exchanges and
o control over the money supply in circulation and the volume of loans through influence
on discount rates;
o guarantees of the government on deposits, loans, loans to the private sector, etc .;
o economic measures of the state (regulation of operations with foreign currency, gold,
treaties, etc.);
o the state's exit to the markets of loan capitals (issue of treasury bills, medium and long-
term bonds, issuance of obligations of certain state institutions, etc.), creating direct
Regulation of the stock exchanges is carried out through a rather complex network of state and
parastatal bodies. A certain contradiction inherent in the main principle of such regulation is that
the minimum level of interference in the practice of stock trading, coupled with the rather rigid
advocacy of the direct interests of the state and the protection of the consumer (investor) directly
There are numerous approaches to defining and analyzing the process of financialization. Some
define financialization in terms of the growing importance and influence of financial institutions,
including financial markets, and financial interests in national and international economies
which profits depend on financial activities and channels, rather than real productive activities or
trade in goods and services (Krippner, 2005; Arrighi, 1994). Financialization may also be
interpreted as the process whereby financial markets and institutions have an increasingly
indicators of financialization vary with the particular focus chosen and there is no one single
almost any standard, the size and importance of financial markets and activities has increased
dramatically in the U.S. economy, particularly since the 1980s. In general, there are three broad
Assessing the size and importance of finance as a distinct sector of the economy.
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Financial Management
Assessing the size and importance of financial activities, incomes and markets in the
economy as a whole.
Assessing the extent to which financial markets have encroached onto the traditional non-
financial economy.
Clearly, these areas are interrelated and there is significant overlap. Nevertheless, approaching
the question of financialization from multiple directions provides a more complete picture of the
The growth rаte of finance dеfined as a distinct sector of the economу provides one commonlу
usеd indicаtor of the process of finаncialization. In nаtional accоunts stаtistics, the finаncial
sector is tуpicallу definеd in terms of finance, insurance, and real estate activities, or FIRE.
Figure 2.1 shows the proрortion of the FIRE sector in рrivate sector GDP from 1950 to 2010 for
the U.S. economy.9 There is a clear increase in the FIRE share of the рrivate economу in the
1980s and 1990s. In the period 2000 to 2010, the share of FIRE does not continue to rise, but
level of debt in the U.S. economy. The expansion of the volume of debt presents
the increase in financial liabilities (for the borrowers) and credit assets (for the
lenders). Figure 2.3 shows the ratio of the stock of debt liabilities to GDP for the
private sector (i.e. private debt to private sector GDP) and for the entire economy
(public and private debt to total GDP). The private sector includes households, nonfinancial
Private sector debt grew from approximately 100 percent of private GDP to over 300
percent from 1960 to 2011, reaching a peak of 350 percent in 2008, immediately
before the U.S. economy collapsed. The ratio of private debt to GDP began to increase at a faster
total GDP shows a similar pattern. This suggests that the relative increase in the
debt to GDP ratio was driven by the increase in private debt, not public debt. After
2008, as the crisis unfolded, this situation changed, with public debt increasing and
private debt falling. With regard to the private debt, the household sector accounted
for about a third of this total: 33 percent of total private debt in 2011. Non-financial
total private debt in the same year. The accumulation of debt across different
financialization in the U.S. economy, and we examine these issues in more depth
activities and markets into traditionally non-financial spheres of the economy. For
activities, not simply in terms of financing investments in productive assets, but also
and assets side of the balance sheet of non-financial corporations. On the asset side,
there has been a significant increase in the acquisition of financial assets relative to
fixed capital assets by non-financial corporations since the 1980s (Krippner, 2011).
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References
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