china's banking reform: the remaining agenda

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This article was downloaded by: [Moskow State Univ Bibliote] On: 03 December 2013, At: 22:24 Publisher: Routledge Informa Ltd Registered in England and Wales Registered Number: 1072954 Registered office: Mortimer House, 37-41 Mortimer Street, London W1T 3JH, UK Global Economic Review: Perspectives on East Asian Economies and Industries Publication details, including instructions for authors and subscription information: http://www.tandfonline.com/loi/rger20 China's Banking Reform: The Remaining Agenda Charles C. L. Kwong a a School of Arts and Social Sciences , The Open University of Hong Kong , Kowloon, Hong Kong SAR Published online: 27 Jun 2011. To cite this article: Charles C. L. Kwong (2011) China's Banking Reform: The Remaining Agenda, Global Economic Review: Perspectives on East Asian Economies and Industries, 40:2, 161-178, DOI: 10.1080/1226508X.2011.585056 To link to this article: http://dx.doi.org/10.1080/1226508X.2011.585056 PLEASE SCROLL DOWN FOR ARTICLE Taylor & Francis makes every effort to ensure the accuracy of all the information (the “Content”) contained in the publications on our platform. However, Taylor & Francis, our agents, and our licensors make no representations or warranties whatsoever as to the accuracy, completeness, or suitability for any purpose of the Content. Any opinions and views expressed in this publication are the opinions and views of the authors, and are not the views of or endorsed by Taylor & Francis. The accuracy of the Content should not be relied upon and should be independently verified with primary sources of information. Taylor and Francis shall not be liable for any losses, actions, claims, proceedings, demands, costs, expenses, damages, and other liabilities whatsoever or howsoever caused arising directly or indirectly in connection with, in relation to or arising out of the use of the Content. This article may be used for research, teaching, and private study purposes. Any substantial or systematic reproduction, redistribution, reselling, loan, sub-licensing, systematic supply, or distribution in any form to anyone is expressly forbidden. Terms & Conditions of access and use can be found at http://www.tandfonline.com/page/terms- and-conditions

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Page 1: China's Banking Reform: The Remaining Agenda

This article was downloaded by: [Moskow State Univ Bibliote]On: 03 December 2013, At: 22:24Publisher: RoutledgeInforma Ltd Registered in England and Wales Registered Number: 1072954 Registeredoffice: Mortimer House, 37-41 Mortimer Street, London W1T 3JH, UK

Global Economic Review: Perspectiveson East Asian Economies and IndustriesPublication details, including instructions for authors andsubscription information:http://www.tandfonline.com/loi/rger20

China's Banking Reform: The RemainingAgendaCharles C. L. Kwong aa School of Arts and Social Sciences , The Open University of HongKong , Kowloon, Hong Kong SARPublished online: 27 Jun 2011.

To cite this article: Charles C. L. Kwong (2011) China's Banking Reform: The Remaining Agenda,Global Economic Review: Perspectives on East Asian Economies and Industries, 40:2, 161-178, DOI:10.1080/1226508X.2011.585056

To link to this article: http://dx.doi.org/10.1080/1226508X.2011.585056

PLEASE SCROLL DOWN FOR ARTICLE

Taylor & Francis makes every effort to ensure the accuracy of all the information (the“Content”) contained in the publications on our platform. However, Taylor & Francis,our agents, and our licensors make no representations or warranties whatsoever as tothe accuracy, completeness, or suitability for any purpose of the Content. Any opinionsand views expressed in this publication are the opinions and views of the authors,and are not the views of or endorsed by Taylor & Francis. The accuracy of the Contentshould not be relied upon and should be independently verified with primary sourcesof information. Taylor and Francis shall not be liable for any losses, actions, claims,proceedings, demands, costs, expenses, damages, and other liabilities whatsoeveror howsoever caused arising directly or indirectly in connection with, in relation to orarising out of the use of the Content.

This article may be used for research, teaching, and private study purposes. Anysubstantial or systematic reproduction, redistribution, reselling, loan, sub-licensing,systematic supply, or distribution in any form to anyone is expressly forbidden. Terms &Conditions of access and use can be found at http://www.tandfonline.com/page/terms-and-conditions

Page 2: China's Banking Reform: The Remaining Agenda

China’s Banking Reform: The RemainingAgenda

CHARLES C. L. KWONGSchool of Arts and Social Sciences, The Open University of Hong Kong, Kowloon, Hong Kong SAR

ABSTRACT Since 1994, China has endeavoured to establish a banking system that works moreclosely to commercial principles by transforming the specialized banks (SBs) into state-ownedcommercial banks (SOCBs). However, lending decisions of the SOCBs were still determined bystate directives instead of profitability consideration. This paper argues that although the post-WTO banking reforms have accomplished staggering results, China’s SOCBs need an overhaul ofownership structure if China aims to develop a full-fledged market-based banking system. It alsoargues that the current banking reforms are not comprehensive enough to sustain China’s long-term economic development because there still remain noticeable capital constraints facing small-and medium-sized private enterprises, particularly those in rural areas.

KEY WORDS: Chinese banks, state-owned commercial banks (SOCBs), banking reform,ownership reform, rural finance

Introduction

A most remarkable feature of China’s banking system is its rapid transformation

from the one monopolized by state banks to the one with a wider range of non-state

banking institutions. The state-owned commercial banks (SOCBs) and their non-

state counterparts are now more responsive to market signals and discipline. A

considerable headway has been made in implementing key reforms in the banking

sector, which is evidenced by the banks’ improved balance sheets, enhanced corporate

governance and compliance with international best practices. The public listing of the

four major SOCBs represented a milestone in ownership reform in China’s banking

sector. This move exposed the state banks further to market forces and competition.

However, this paper argues that if the mission of China’s banking reform is to be

completed in developing a full-fledged market-based banking sector and thereby

sustaining the country’s long-term economic growth and development, a further

retreat of state influence is of vital importance. For instance, when the central

government initiated the RMB4 trillion stimulus package in 2008, state banks were

pressured by local governments to extend loans to key projects to maintain economic

growth. Not a small number of these projects finally turned out to be unmatched by

Correspondence Address: Charles C. L. Kwong, School of Arts and Social Sciences, The Open University of

Hong Kong, 30 Good Shepherd Street, Ho Man Tin, Kowloon, Hong Kong SAR. Email: clkwong

@ouhk.edu.hk

Global Economic Review

Vol. 40, No. 2, 161�178, June 2011

1226-508X Print/1744-3873 Online/11/020161�18

# 2011 Institute of East and West Studies, Yonsei University, Seoul

DOI: 10.1080/1226508X.2011.585056

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Page 3: China's Banking Reform: The Remaining Agenda

effective demand, which intensified the problem of overcapacity.1 More importantly,

it may cause recurrence of non-performing loans (NPLs) accumulation in the

banking sector.

The remaining agenda of China’s banking reform hinges on the difficulties facing

the SOCBs in resisting the practice of lending based on government pressure.

Without an overhaul of the ownership structure of the SOCBs, further improvement

on corporate governance and risk management will be implausible. However, it is

likely that central leaders are cautious to release control in the banking sector, which

is in line with the doctrine of socialist market economy endorsed by the third plenum

of the 14th Central Committee on 14 November 1993. The notion of socialist market

economy recognized an enlarged role of market and privatization in the course

of economic reform, but the state-owned sector would remain the mainstay of the

economy.2

Nonetheless, viewing from a wider perspective, a well functioned financial system

should be able to serve the whole economy in a balanced way. After three decades of

reform, the rural financial reforms are still lagging behind, thus creating the risk of

slowing down further rural development. Without an efficient financial market,

investment in rural industries and agricultural production will be inhibited, and the

effects of any further effort to enhance rural income will be very marginal.

The Pre-1994 Banking Reform: A Snapshot

The establishment of People’s Bank of China (PBOC) in 1948 marked the starting

point of the banking system under the People’s Republic of China (PRC) rule.

China’s banking sector during the pre-reform period was characterized as a mono-

bank system in which banks operated under a scheme of ‘‘Tong Shou Tong Zhi’’

(unified income and unified expenditure). All deposits from individuals and

enterprises, mainly state-owned enterprises (SOEs), must be held by the PBOC. All

loans to SOEs and state projects were extended by the PBOC. In a nutshell, the

PBOC became the centre of settlement for both deposits and loans. In conformity

with the centralist character of the planned economy, the top priority of the central

planners was not attached to efficiency consideration of the banking system.

During the initial stage of industrial development in the 1950s and 1960s, China

encountered severe capital shortage, which would have entailed high interest rates if

capital allocation was made by market mechanism. However, the mono-bank system

was to allocate financial resources with zero interest rate to fulfil state plans and to

ensure insulation from potential domestic and foreign influence. The repercussion of

the mono-bank system was far-reaching because interest-free loans led SOEs to

severe soft-budget constraints and moral hazard problems, resulting in massive NPLs

accumulated in the 1980s and the early 1990s.

Economic reforms in the late 1970s brought about decentralization of economic

activities and prompted diversification of banking institutions in the early 1980s.

They allowed a larger role of market in allocating resources and developing non-state

enterprises, mainly collective enterprises. The share of nominal industrial output by

SOEs decreased from 76.0% to 64.9% from 1980 to 1985 while that by collective

enterprises increased from 23.6% to 32.1%, an average annual growth of 18.7%

during the period (Guo, 2002). Expanding non-state sector was accompanied by

162 C. C. L. Kwong

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mounting financial resources held by decentralized units including households,

enterprises and local governments. Further, the opening-up to the outside world

through foreign direct investment (FDI) and setting up of special economic zones

(SEZs) necessitated state-owned specialized banks (SBs) to deal with international

financial transactions. The amount of utilized FDI soared from US$1769 million in

1979�1982 to US$4291 million in 1983�1985.3 The highly centralized mono-bankingsystem in the pre-reform era could no longer accommodate the financial needs

brought about by the reform.

From 1979 to 1984, four SBs were reinstituted and they were separated from the

PBOC. The Agricultural Bank of China (ABC) was re-established in 1979 to handle

deposits and lending in rural areas. The Bank of China (BOC) was reinstituted under

the State Council in 1979 to manage the country’s foreign exchange. The People’s

Construction Bank of China (PCBC) (renamed as China Construction Bank in 1996)

was made subordinate to the State Council in 1979 to finance construction and fixedassets investment while the Industrial and Commercial Bank (ICBC), established in

1984, specialized in funding business activities (Lardy, 1998; Okazaki, 2007). On top

of reinstituting the SBs, the central government transformed the PBOC into a formal

central bank in 1984 by transferring its deposit and lending activities to ICBC. The

re-establishment of the SBs and the setting up of a formal central bank laid the

important foundation of separating central bank and commercial bank functions.

The central bank, PBOC, has since then become the main government agency for

manoeuvring monetary policy, supervising the financial sector and fine-tuning themacroeconomy.

Aside from re-establishing the SBs, new commercial banks and non-bank financial

institutions (NBFIs) were allowed to open to cater for different financial needs in

urban and rural areas. Nine national and regional banks, such as the Bank of

Communications (BOCOM) and the Guangdong Development Bank, were set-up in

the 1990s. NBFIs also flourished in the decade. Up to 1994, about 60,000 rural credit

cooperatives (RCCs), 1500 urban credit cooperatives (UCCs) and 590 trust and

investment companies (TICs) were set-up (Chai, 1997). SBs’ specialized roles havestarted to blur since the 1980s and each SB has faced increasing competition from

other SBs and the new financial institutions.

The reinstituting of SBs and the diversification of financial institutions in the 1980s

represented only a hierarchical and structural transformation. Though with minimal

competition, the SBs still dominated the banking sector. The market share, in terms

of assets, of the four SBs (i.e. the Big Four) was 85.4% in 1988 and fell slightly to

84.2% in 1993 (Chen et al., 2000) and continued to perform the fiscal functions

assigned by the central government. SBs were expected to extend loans to SOEs eventhough many of the state enterprises were loss-making. The soft loans were to

maintain the operation of the enterprises by which stable employment could be

guaranteed.

The 1994 Banking Reform: Commercialization and Recapitalization of SBs

Commercialization of SBs

During the pre-reform period, SBs had been government policy agents to finance

state projects and SOEs. The primary problem associated with policy lending is that

China’s Banking Reform 163

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Page 5: China's Banking Reform: The Remaining Agenda

loans were extended to state entities on the basis of social and political consideration

instead of profitability and business criteria. Prior to the mid-1990s, the financial role

as fiscal agents assumed by the SBs remained basically intact. To avoid massive

layoffs by ailing SOEs, the SBs shouldered the key responsibility of rendering ‘‘soft

loans’’ to SOEs from the pre-reform period to the mid-1990s to maintain the

operation of many loss-making SOEs. In 1997, almost 40% of SOEs incurred

operating losses, rising from 19% in 1978. The total losses accumulated from

RMB4.2 billion yuan in 1978 to RMB74.4 billion in 1997, representing a spectacular

growth of 17.7 times (Wolf et al., 2003). The ratio of NPLs of the SBs reached 20.4%

in 1994 and was estimated to increase by 2% annually (Lardy, 1998).The PBOC lacked effective means of controlling the lending behaviour of the SBs,

which were dominantly affected by central directives. The ‘‘soft loans’’ resulted in

spectacular rise in money supply and inflation rates. Money supply (M2) increased

from 31.3% in 1992 to 34.5% in 1993 while the inflation demonstrated a hyper growth

from 6.4% in 1992 to 24.1% in 1994.4 The runaway inflation alarmed the central

leaders the possible macroeconomic instability resulting from quasi uncontrolled

bank loans by the SBs. On the other front, since the transformation of the General

Agreement on Tariffs and Trade (GATT) to World Trade Organization (WTO) in

1995, China started to request its membership in WTO. As part of the commitments

to WTO accession, China was required not only to reduce its tariff and non-tariff

barriers for imports but also to open up its telecommunication, banking, financial

and insurance sectors to foreign investors (Okazaki, 2007).

Facing both domestic and external pressures on its banking sector, the central

government embarked on an overhaul of the banking system in 1994 aiming at

developing the PBOC into an independent full-scale central bank to regulate the

banking sector and maintain macroeconomic stability. The Law of the People’s

Republic of China on the People’s Bank of China (PBCL) was enacted in 1995 to

establish a legal foundation for the superior status of the PBOC. The PBCL stipulates

that the PBOC, under the leadership of the State Council, devises and implements

monetary policy and monitors the operations of the financial sector (Article 2).

Article 7 of the PBCL entrusts the PBOC with a high level of independence by

specifying that the PBOC is free from the intervention of local governments,

government departments, organizations and individuals when it performs its central

bank functions. The central government’s decision explicitly urged the establishment

of a ‘‘sound macroeconomic control system’’. It was clearly stated that ‘‘the central

bank, the PBOC, under the leadership of the State Council, should implement

monetary policy independently’’. The independent status was further elucidated in

that ‘‘the power of the central bank and local authorities over economic adminis-

tration should be rationally delineated’’ and ‘‘the branches of the PBOC are certified

as agencies of its head office (Mehran et al., 1996, p. 2; PBCL 1995)’’.

However, it is worth noting that the independence of PBOC in policy-making and

implementation should not be overemphasized. Under China’s socialist market

economy, the PBOC is subordinate to the State Council. The Governor of the PBOC

is nominated by the State Council Premier and endorsed by the National People’s

Congress. The Governor is then appointed by the President of the State. Further, the

drafting and implementation of budget of the PBOC are monitored by the financial

department under the State Council (Article 38 of PBCL 1995). The independence of

164 C. C. L. Kwong

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Page 6: China's Banking Reform: The Remaining Agenda

the PBOC is merely in relation to local governments and government departments,

but not the State Council (Leung, 1998).

In dealing with the mounting NPLs, the banking sector overhaul took a decisive

step to commercialize the four SBs by separating commercial lending from policy

lending (World Bank, 1996; Lo, 2001). It was endorsed in the Third Plenum of the

14th Central Committee that the four SBs would gradually be transformed into

SOCBs. Policy-based loans are designated to the three policy lending banks

established in 1994.5 By doing so, the SOCBs could be freed from the burden of

‘‘soft loans’’ and concentrate their businesses in commercial lending based on market

disciplines. However, the transfer of policy lending from the SOCBs to the three

policy lending banks was more complicated than expected. Two points deserve

mention. First, the newly established policy banks were reluctant to accept the policy

responsibilities, particularly lending to SOEs, previously assumed by the SBs. The

SOCBs continued to be a major government-directed funding source for SOEs.

Almost half of the short-term loans of SOCBs were extended to SOEs in 1997 (State

Statistical Bureau, 1998). Second, since the policy banks did not receive deposits

from the public, their operation was financed by state fund by issuing financial bonds

to existing financial institutions, primarily the SOCBs. The state banks were under

constant pressure and directives from the PBOC to absorb the financial bonds issued

by the policy banks.6 As a result, commercialization of state banks did not

substantially improve the balance sheets of SOCBs in the 1990s.

Commercializing the SBs in 1994 aimed at separating policy and commercial

lending, through which the efficiency of the state banks was enhanced. However, in

practice, the reform failed to institute a credit culture based on market disciplines.

Lending decisions were still mainly influenced by state directives instead of

profitability considerations. The reform was also constrained by a lack of Chinese

bankers well-vested with knowledge of running commercial banks (Chen & Shih,

2004). The rising fragility of China’s banking sector was evident by the escalating

NPLs in the 1990s. Some estimates indicated that the ratio of NPLs of the Big Four

stayed at an alarmingly high level of 40% by the end of 1998 (Woo, 2003). The Big

Four were technically insolvent in the late 1990s.

Recapitalisation of SOCBs

The banking reform efforts in 1994 failed to realize the present target of improving

the balance sheets of the SOCBs. The central government perceived the need of

strengthening the capital position of the Big Four before fulfilling the WTO

commitments of opening up the banking sector to foreign competitors. Further,

the Asian financial crisis in 1997�1998 crystallized into the central leaders’ views that

the ailing banking sector could be a destabilizing factor in the economy when China

had established increasing links with the global economy. To accelerate the pace of

repairing the balance sheets of the state banks, the Ministry of Finance (MOF)

injected US$34 billion into the Big Four to lower the NPLs in 1998. The

recapitalization was supposed to alleviate the financial burden of the SOCBs arising

from the past policy lending. Such recapitalization by the central coffers was planned

to be ‘‘first and final’’ (Anderson, 2008, p. 172). To offer a quick fix to NPLs problem

in the SOCBs, four asset management companies (AMCs) were established in 1999 to

China’s Banking Reform 165

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Page 7: China's Banking Reform: The Remaining Agenda

absorb RMB1.4 trillion of bad loans from the Big Four. Dai Xianglong, former

governor of the PBOC, described the AMCs’ absorption of bad loans as the ‘‘last

supper’’ of the SOCBs (Brahm, 2002).

Despite the massive AMC carve-out, NPLs remained at a startling level

immediately after China’s admission to WTO in December 2001. The NPLs ratios

of ICBC, BOC, CCB and ABC were at high levels of 25.4%, 23.37%, 15.17% and

36.63%, respectively in 2002 (Okazaki, 2007). The capital adequacy ratio (CAR),

a measure of the capital strength of a commercial bank, was still below the

international standard of 8% (Table 1). Central leaders realized the pressing need for

another round of bailout. Further recapitalization, amounted to US$75 billion, ofthe SOCBs in 2003�2006 defeated the initial design of a ‘‘once-and-for-all’’ relief plan

for China’s debt-ridden state banking system. Table 2 shows that by 2006, official

financial support provided for state banks amounted to US$402 billion.

Central government’s ongoing financial support successfully lifted the CAR of the

SOCBs to a level higher than the international standard of 8% (Hansakul, 2006)7 and

reduced the NPLs ratio to an official figure of 7.83% in 2007 (Q3�the third

quarter).8 The rapid drop in NPLs ratio was also attributable to the double-digit

credit growth since 2000. More importantly, the bailout of SOCBs only transferred

the financial burden from the state banks to the AMCs and other government

agencies such as the PBOC and the MOF, instead of instituting an effective

mechanism to solve the governance problems. In relative terms, the substantial

capital injection did not result in corresponding enhancement of the SOCBs’financial indicators. Compared with other Asian developing countries, China’s

NPLs ratio was higher than some neighbouring countries such as Indonesia,

Thailand and Malaysia in 2007 (Anderson, 2008). After rounds of recapitalization,

the NPLs ratios of the SOCBs have still consistently remained higher than their non-

state counterparts such as joint-stock commercial banks (JSCBs) and city commer-

cial banks (CCBs), and the national average in recent years (Table 3).

Though the SOCBs’ NPLs ratios have been demonstrating a steady decline, it is

worth noting that the amount of special-mention loans, referring to debts that may

turn into NPLs, increased by RMB35.8 billion in the first five months of 2008 to

RMB2.16 trillion, according to the China Banking Regulatory Commission (CBRC)

(Lagerkranser, 2008). The figure rose further by RMB54 billion during the period of

April�June in 2010, accounting for 3.91% of total loan assets (Shen & Wong, 2010).

There was only 6% of special-mention loans turning into NPLs in 2006 (Kudrna,2007), but it is likely that the special-mention loans may deteriorate to NPLs in

Table 1. Capital adequacy ratios of the SOCBs 1997�2002 (%)

Year ABC BOC CCB ICBC

1997 2.93 3.91 3.54 4.051998 8.13 11.74 9.31 10.401999 1.44 8.5 3.79 4.572000 n.a. 9.8 6.51 5.382001 1.44 8.3 6.88 5.762002 n.a. 8.15 6.91 5.54

Source: Okazaki (2007).

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Page 8: China's Banking Reform: The Remaining Agenda

coming years if shrinking corporate profits in some industries under global economic

downturn undermine the companies’ ability to repay debts. The possible rebound of

NPLs indicates that government bailout only alleviated the ‘‘stock’’ problems of bad

debts, but not the ‘‘flow’’ problem. Chinese banks are still in lack of adequate internal

governance and risk management mechanism to maintain a stable and acceptable

level of NPLs.

Other financial indicators further confirm the underperformance of the SOCBs.

For instance, from 2005 to 2006, the smaller CCBs, such as the Zhuzhou CCB and

the Bank of Dalian, achieved a much faster growth of profitability than the SOCBs

did (KPMG, 2007). These figures are consistent with the study by Yao et al. (2007),

which uses panel data of 22 Chinese banks from 1995 to 2001 to assess their

performance. The results indicate that non-state banks are 8�10% more efficient than

their state counterparts. The relative inefficiency of state banks was attributable to the

government protection while the non-state banks were facing a hard budget

constraint. Lin and Zhang (2009) reaffirm the findings by Yao et al. (2007). Based

on that data from 60 Chinese banks during the period 1997�2004, Lin and Zhang

reveal that the SOCBs were less efficient and profitable, in terms of return on asset

(ROA) and costs to operating income (COI), than the JSCBs, CCBs and foreign

banks. The underperformance of the SOCBs raises the issue of moral hazard and

cost-effectiveness of bailing out the state banks. It implies that the bailout has not

fundamentally changed the state banks’ corporate governance and lending practice.

Table 2. Official financial support to SOCBs 1998�2006

Item Date Amount (US$ billion) Source

Capital injection to Big Four 1998 34 Ministry of FinanceAMC carve-out 1999 5 Ministry of FinanceAMC carve-out 1999 48 People’s Bank of ChinaAMC carve-out 1999 120 People’s Bank of ChinaCapital injection to Big Four 2003�2006 75 People’s Bank of ChinaSubsidized NPL carve-out 2004�2006 100 People’s Bank of ChinaTax relief for NPL write down 2004�2006 20 Ministry of FinanceTotal 402

Source: Anderson (2008).

Table 3. NPLs ratios of banking institutions

2007 2008 2009

Commercial banks in total 6.2 2.4 1.6State-owned commercial banksa 8.0 2.8 1.8Joint-stock commercial banks 2.1 1.3 1.0City commercial banks 3.0 2.3 1.3Rural commercial banks 4.0 3.9 2.8Foreign banks 0.5 0.8 0.9

Note: aNPL figure since 2007 cover the Big Four and the Bank of Communications (BOCOM). BOCOM was

categorized as a SOCB in 2007.

Source: CBRC (2007, 2008, 2009).

China’s Banking Reform 167

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The Remaining Agenda

Commercialization and recapitalization of state banks have improved the SOCBs’

balance sheets in an impressive pace. However, the accomplishment is accompanied

by huge financial inputs provided by the central coffer. More importantly, the major

state banks are still under strong government influence in their loan decisions. Within

the framework of China’s socialist economy, despite the fact that banking reforms

were carried out to enhance banks’ efficiency to cope with the increasing competition

after its accession to WTO, it is unlikely that the central government will surrender itscontrol in the banking sector. The banking sector remains to be the main platform for

the Chinese government to fine tune and stabilize its macroeconomy. This point is

illustrated by the RMB4 trillion stimulus package, which is discussed in later section.

Though China welcomes foreign strategic partners to collaborate with their state

banks, it treasures more the foreign partners’ expertise on managerial efficiency,

corporate governance and risk control, rather than their participation in daily

operation and loan decision. Increasing foreign participation in SOCBs will

unavoidably undermine China’s autonomy in exercising macroeconomic policythrough the state banks.

Governance and Ownership Reform

Until the mid-1990s, the issue of corporate governance was irrelevant to the SOCBs

as their main duty was to channel funding to the SOEs and state project. SOCBs were

not accountable for profits and losses. As mentioned above, the ‘‘soft loans’’ extendedto the state sector led to the soaring of NPLs. Since the banking reform implemented

in 1994, effective governance of Chinese banks is essential to providing managerial

incentives for prudent lending, which is of primary importance to prevent

accumulation of NPLs. The most important step of strengthening banking super-

vision was the setting up of CBRC in 2003, which regulates all banks and depository

institutions. One of the major tasks of the CBRC is to ensure that the SOCBs are

operating under prudent commercial bank practices such as the 10-plus loan

classification system9 and the internal rating based loan system to evaluate thepotential risks of loans extended to the market (Hansakul, 2006). It is a vital step to

develop a lending practice among SOCBs to take into account the risk factor when

they make their loan decisions. However, Podpiera (2006) points out that the lending

behaviour of the SOCBs does not indicate fundamental changes. For the period

1997�2004, profitability of the enterprises did not appear to be the major

determinant for SOCBs’ lending decision. Rather, the findings of Podpiera reveal

that lending decisions by SOCBs were mainly determined by the growth rate of

savings deposits.Though China has fulfilled most of the 25 Core Principles adopted by the Bank for

International Settlements (BIS) committee on banking regulation and supervision,

some principles are not really de facto fulfilled. To illustrate, Principle 1 requires the

regulatory agency to have full autonomy, power and resources to exercise its

supervisory and monitoring role. However, the CBRC is hierarchically under the

State Council which can veto the decision made by CBRC and the appointment of key

officials in CBRC is still under the control of the Communist Party. The state banks

are also required to recruit independent directors to oversee the decision-making

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process and operation of the SOCBs, but most of the independent directors are either

government officials or ex-bank staff, who can rarely perform independent super-

visory role (Kudrna, 2007).

To bring in stronger outside governance and oversight to increase the state banks’

operation efficiency, three of the Big Four (ICBC, CCB and BOC) were listed on

stock exchanges in Hong Kong and Shanghai in 2005/2006 to allow more market

discipline to monitor their performance. After years of preparation and trimming

down the NPLs, the ABC was finally listed in Hong Kong and Shanghai in mid-2010.

Foreign strategic partners are now more welcome not just for their capital, but also

for their knowledge in bank practices, product design and international exposure.

However, the influence of foreign partners in the Chinese banks should not be

magnified since the ceiling of foreign ownership in a Chinese bank is 25% and the

ceiling of a single foreign bank holding share of a Chinese bank is capped at 20%.

The state remains the major shareholder of the Big Four (see Table 4). Except

BOCOM, more than half of the share of the Big Four is held by state departments

and agencies. The state shares in BOC, ICBC and ABC are maintained at a high level

of 70�80%. After several years of post-IPO operation, three of the Big Four SOCBs

have accumulated more experience in corporate governance and daily operation of a

large-sized listed commercial bank. When ABC prepared its public listing, it did not

invite any foreign strategic investor. Only a few smaller ‘‘cornerstone investors’’, such

as the Standard Chartered Bank, were solicited to subscribe the share, but not

participate in the operation of the ABC.10

In most cases, the major foreign investors are entitled to nominate one candidate in

the director board, usually consisting of 15�18 members (McGuinness & Keasey,

2010), of the state banks, but their role in key decision-making is more de jure than de

facto (Kudrna, 2007). The involvement of foreign partners in daily management is

marginal (Table 5). Though the state banks have tried to recruit foreign bankers to

join their senior management, this outside talent, in general, served in the state banks

only for a short period of time. Their inputs for improving the banking efficiency are

therefore very limited.11 Influence of foreign partners is substantially constrained by

the fact that top positions in state banks are still appointed by the party leadership

and the chairperson of a SOCB also serves as the party secretary of the bank (Brehm,

2008). Civil service appointees in top positions imply that state banks cannot be fully

insulated from government influence on lending decisions. The rationale of limited

foreign ownership and participation in bank operation is best captured by the

statement made by Chinese Premier Wen Jiabao on 14 March 2006:

The goal of reforming the state-owned commercial banks is to establish a modern commercial bank

system. . .The reform of China’s state-owned commercial banks must ensure that the state stake

takes a dominant share to control the economic lifeline and guard against financial risks.12

In response to recent queries from WTO members, China clearly indicated no plans

to increase the limits on foreign ownership of Chinese banks, given China’s stage of

development and the global financial instability.13 China’s reluctance in further

liberalizing its banking sector appears to be a reflection of China’s strong attachment

to its socialist market economy in which market forces are the means for resources

allocation, but state dominance in key or strategic sectors remains. State influence in

China’s Banking Reform 169

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Table 4. Pre- and post-IPOa major shareholders of SOCBs

Pre-IPOb Post-IPOc

State share Foreign strategic investor State share Foreign strategic investor

BOCOM Ministry of Finance (25.53)*NCSSFd(14.22)China Central SAFE InvestmentLimitede (7.68)

HSBC (19.9) Ministry of Finance (26.48)NSSF (11.34)

HSBC (19.15)

CCB China Central SAFE InvestmentLimited (71.13)China Jianyin Investmentf (10.65)

Bank of America (9.0)Tamasek (5.1)

China Central SAFEInvestment Limited (57.03)

Bank of America (10.95)Tamasek (5.81)

BOC China Central SAFE InvestmentLimited (79.90) NCSSF (3.91)

RBS China (9.61)Tamasek (4.81)

China Central SAFEInvestment Limited (67.49)NCSSF (4.46)

Tamasek (4.13)

ICBC Ministry of Finance (43.28)China Central SAFE InvestmentLimited (43.28)NCSSF (5.0)

Glodman Sachs (5.75)Allianz (2.25)American Express(0.45)

Ministry of Finance (35.3)China Central SAFEInvestment Limited (35.4)NCSSF (4.2)

Glodman Sachs (3.9)Allianz (1.0)American Express (0.2)

ABC China Central SAFE InvestmentLimited (50%)Ministry of Finance (50%)

NIL China Central SAFEInvestment Limited (40.03)Ministry of Finance (39.21)NCSSF (3.02)

Standard Chartered Bankg

(0.37)

Note: *Figures in the parentheses are the respective shares of domestic/foreign investors.aIPO � Initial public offering.bRefer to the share structure immediately before IPO (The dates of H-share listing for BOCOM, CCB, BOC, ICBC and ABC were June 2005, October 2005, June 2006, October

2006 and July 2010, respectively).cAs at 30 June 2009 for CCB, BOC, ICBC and 30 September 2010 for ABC.dNCSSF �National Council for Social Security Fund.eAlso refer as Central Huijin Investment Limited (Huijin).fChina Jianyin Investment was wholly owned by China Central SAFE Investment Limited.gABC did not invite strategic investors to participate in bank operation, but solicited several cornerstone investors to buy the share of ABC.

Source: ABC Third Quarter Report (2010); McGuinness and Keasey (2010); Thomas White Global Investing (2010).

17

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banking sector is still prevalent after the ownership reform, which was evidenced by

the RMB4 trillion stimulus package initiated by the central government in 2008 to

buffer the possible economic downturn amid global financial crisis. To reach the

investment targets delegated by the central government, local governments were

active in supporting local banks, mostly state banks, to extend loans to local

government financing platforms (LGFPs), which were mainly enterprises and

projects engaged in infrastructure and public utilities. LGFPs have strong tie and

support from the local governments and thus are able to acquire loans without much

difficulty. The loans in some sense can be interpreted as ‘‘local policy loans’’. Local

banks extended RMB3.1 trillion of LGFP loans, a 70.4% annual growth, in 2009,

which accounted for 32.3% of China’s loan growth for the same period (Jiang & Sun,

2010). The presence of ‘‘local policy loans’’ highlights that SOCBs’ commercial

interests are subordinate to broader political and socio-economic consideration.

The lockup period for foreign strategic ownership in China’s commercial banks

poses another constraining factor on foreign investors’ role as outside governance. In

theory, listing the SOCBs can discipline the bank performance by selling their shares.

However, in practice, foreign strategic investors were prohibited from selling their

state bank shares within three years, which restricted the exit right of the strategic

partners and undermines the market discipline on state banks.14 The lockup period

Table 5. Roles of foreign strategic investorsa in CCB, BOC and ICBC

Number ofmembers in

director board

Number of foreignstrategic investors in

director boardRoles played by foreign

strategic investors

CCB 17 one non-executivedirector for Bank ofAmerica

BA has seconded about 50personnel to assist in riskmanagement, corporategovernance and consumerbanking. Temasek concentratesassistance in staff training intreasury, SME credit andcorporate business. Strategicinvestors assume no dailymanagement duties.

BOC 17 one non-executivedirector for RBS and onefor Temasek

RBS provides support inwealth management andcorporate banking while UBSmainly offer assistance ininvestment banking andsecurity business. Strategicinvestors involve no dailymanagement duties.

ICBC 15 one non-executivedirector for GoldmanSachs

Allianz assist in insuranceproduct and business while BAaid in risk management,investment banking and creditcard business.

Note: aAs mentioned above, there is no foreign strategic investor in the ABC.

Source: Kudrna (2007) and McGuinness and Keasey (2010).

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was later extended to five years in 2009 to cushion possible impact brought about by

the global financial crisis on domestic banks. This move further limits the capability

of foreign strategic investors to act as effective outside governance by selling their

stakes in Chinese banks when the banks do not perform well. The findings of

Heffernan and Fu (2010) reconfirm the notion that corporate governance reforms

has so far generated very limited impacts on the performance of SOCBs. Usingempirical data of 76 Chinese banks, covering 95% of banking assets in China, from

1999 to 2006, it is indicated that neither the percentage of foreign ownership nor bank

listings has an apparent effect on performance, which is measured by economic value

added and net interest margin. A plausible explanation, as analyzed above, for the

moderate effects of ownership reform on bank performance is that foreign investors,

subject to multiple constraints, are unable to provide real inputs to improve corporate

governance in Chinese banks. Dominant state ownership in the banking sector

enables both the central and local governments to continue their discernible influenceon banks’ lending practice.

Rural Finance: The Underserved Sector

Three decades of rural economic reforms have changed the income structure of

China’s rural households. Apart from deriving income on farmland, non-farmactivities, mainly rural industry, have become another main source of rural income

since the mid-1980s. In 1985, farming generated 75.4% of rural household income

and the figures diminished to 43.9% in 2008. On the contrary, non-farm income has

been gaining its share in rural income from 24.6% in 1985 to 56.1% in 2008, which

indicates that rural residents have relied increasingly on non-farm activities to

maintain their income growth (Table 6).

In addition, the proliferation of rural industry in the 1980s and 1990s assumed an

important function of absorbing surplus labour released from the agricultural sector.Rural enterprises employed 30 million of workers in 1980 and the number skyrocketed

to 111.69 million in 1990, demonstrating a growth of 2.72 times during the 1980s

(National Bureau of Statistics of China, 2005). However, employment creation by

rural enterprises was impeded by the implementation of banking reform in 1994,

which aimed at commercializing the four SOCBs by separating commercial lending

from policy lending, unintentionally resulted in noticeable capital constraints facing

Table 6. Farm and non-farm income in rural China 1985�2008

Income fromFarming (yuan) (1)

Income from Non-farmActivitiesa (yuan) (2) (1)�(2)

(1)/(1)�(2)

(%)

(2)/(1)�(2)

(%)

1985 263.2 86.3 349.5 75.3 24.71990 456.0 201.4 657.4 69.4 30.61995 956.5 563.3 1519.8 62.9 37.12000 1090.7 1083.9 2174.6 50.2 49.82005 1469.6 1637.0 3106.6 47.3 52.72008 1945.9 2491.5 4437.4 43.9 56.1

Note: aTransfer income is not included in non-farm income.

Source: Calculated based on the data from ZGTJNJ (1986); ZGTJNJ, 2009 CD-ROM (Tables 9�20).

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the small- and medium-sized private enterprises, particularly those in rural areas.

Since the SOCBs were required to operate on commercial principles, 44,000 county

branches of SOCBs ceased to operate during 1998�2001 to cut operation costs.15

Since 2000, the ABC has retreated from sub-county areas and county branches

have now become the lowest management layer in the countryside (Zhang et al.,

2010). The ABC, which receives deposits mainly from rural areas, has shifted its

lending towards urban areas, which generates more promising returns. Loans

extended to township�village enterprises (TVEs) and private enterprises (PEs)

increased in absolute term from 1985 to 2008, but the share in total lending by

financial institutions demonstrated a decreasing trend (Table 7), which reached a

historic low of 2.16% in 2008. Compared with the output share of rural enterprises in

Gross Domestic Product (GDP), which maintained at about 25% since 2000

(Naughton, 2007; OECD, 2009), the negligible share of total lending acquired by

rural enterprises exhibited the difficulties of accessing credit in the countryside. The

enterprises have to utilize their accumulated profits to finance their production and

investment. However, rural enterprises face keen competition among flourishing

TVEs and the SOEs that have much more easy access to bank credit. Rural

enterprises are less likely to acquire ample capital to invest in product design and

quality improvement. The expansion of rural enterprises is thus constrained and it

impairs the ability of rural enterprises to absorb rural labour. The growth rate of

employment in rural enterprises has been decreasing since 1995 and negative growth

was recorded for two consecutive years in 1997 and 1998. Though the figure

rebounded to 4.5% in 2005, it tapered off once again in recent years (Table 8). As

rural household income relies more on non-farm activities, slow labour absorption by

rural enterprises inevitably mitigates rural income growth, which has direct bearing

on the level of rural consumption.

Since the retreat of SOCBs in the countryside, RCCs become the most important

financial institution in rural areas to meet the credit demand by the rural enterprises

and households. The merge of RCCs in recent years, however, further decreased the

number of county financial institutions. As of the end of 2007, the number of county

Table 7. Share of loans to rural enterprises 1985�2008 (billion RMB)

Total lending byfinancial institutions

Loans toagriculture Loans to TVEs

Loans to PEs and self-employed individuals

1985 643.09 41.66 (6.48)a 32.13 (5.0)b n.a.1990 1683.78 103.81 (6.17) 83.13 (4.94) n.a.1995 5398.90c 192.16 (3.56) 110.04 (2.04) n.a.2000 13548.37 488.90 (3.61) 606.08 (4.47) 65.46 (0.48)2005 30204.28 1152.99 (3.82) 790.18 (2.62) 218.08 (0.72)2008 53840.60 1762.90 (3.27) 745.40 (1.38) 422.1 (0.78)

Note: aFigures in parentheses are the respective share in total lending.bFigures from 1985 to 1995 were combined loan amount to TVEs, PEs and self-employed individuals.cFigures before 1995 were total lending from the four SOCBs while figures since 2000 covered all financial

institutions.

n.a.� not available

Sources: Calculated based on the data from ZGTJNJ (1991, 1996); ZGTJNJ CD-ROM (2007, Tables 20�2; 2009,

Tables 19�2).

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financial outlets dropped by 9811 or 7.3% since 2004, declining to a total of 124,000

outlets. Towns and villages are the most adversely affected areas. By 2010, almost 9%

of the 35,000 townships in China had no access to banking institution. About 60

million rural residents did not have ready access to banking services.16 Despite the

increase in deposit in RCCs, a rising amount of funds has been channelled out of

rural areas through depositing funds into the PBOC or purchasing bonds for which

the returns are more stable and less risky. Even with the repeated emphases by central

leaders on the importance of rural finance in rural development, the amount of loans

extended to agriculture and rural enterprises is still disproportionately small.

Banking reform since 1994 has focused on the institutional overhaul of banking

sector in urban areas. Rural financial reforms have so far lagged behind, thus creating

the risk of slowing down further expansion of rural enterprises and rural

development as a whole.

Concerted efforts have been made to ensure adequate financial services rendered to

the countryside. The China Postal Savings Bank (CPSB) was established in 2007 to

takeover the rural financial services previously provided by the post offices. The new

bank provides a network of 37,000 branches providing banking services, including

small loans to individuals, in rural areas.17 However, since the postal saving system

was not allowed to extend loans to rural households and enterprises until June 2006,

it is not certain whether the newly established CPSB can have adequate expertise in

credit and risk evaluation (Kwong, 2009). The lending capacity of the CPSB is also

limited by its asset size, which was only 30.4% of that of the ABC and 3.4% of the

total bank assets in China in 2009.18

Table 8. Growth of employment in rural enterprises 1990�2008

Workers employed in rural enterprisesa (million) Growth rate (%)

1990 111.69 19.21991 113.41 1.51992 124.87 10.11993 145.42 16.51994 148.84 2.41995 163.87 10.11996 173.67 6.01997 171.72 (1.1)1998 171.29 (0.25)1999 175.00 2.22000 168.93 (3.5)2001 169.02 0.052002 171.73 1.62003 175.87 2.42004 179.56 2.12005 187.61 4.52006 194.59 3.72007 199.49 2.52008 203.98 2.2

Note: aFigures include workers employed in TVEs, PEs and self-employed individuals. Figures in parentheses

represent negative growth rates.

Source: Calculated based on the data from ZGTJNJ (1991, 2005); ZGTJNJ CD-ROM (2009, Tables 4�20).

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In addition, the CBRC designed a plan to set-up 1294 new financial institutions in

rural areas over a three-year period (2009�2011) to cater for the escalating demand

for financial services in rural sector. Nevertheless, the response of local and foreign

banks has been lukewarm as the average size of each loan application in rural areas

remains small19 and more risky, which lowers the cost-effectiveness of processing

each loan application. Lending to rural areas has so far recorded a very highNPL ratio, which is almost three percentage point higher than the national average

(Table 9). Further, the lack of collaterals from farmers increases the default risks of

the loans. Lower profitability and higher risks deter the banks from taking bold steps

to tap into the rural business, particularly in poor regions. Setting up an extensive

credit-reporting system is a necessary step to allow lenders to better manage their

risks in rural lending by reducing information asymmetry,20 which enables financial

institutions to increase their lending to the underserved areas.

A further relaxation of interest rates charged by rural financial institutions canprovide adequate risk premium for the lenders, which induces more loans to risky

borrowers.21 Not withstanding, higher interest rates may deter farm households from

borrowing from financial institutions. Therefore, the problem of inadequate financial

services in rural China cannot be solved solely by market means. Government

initiatives, such as government-subsidized microfinance, tax exemption and conces-

sionary land rent for financial institutions, must be instituted to promote lending to

rural households and enterprises.

Conclusions

China’s accomplishments in banking reform have been staggering, particularly in

terms of reducing NPLs, lifting up CARs and enhancing internal corporate

governance. This can be attributable to central government’s financial supports

and the competitive pressure exerted by China’s WTO accession. However, the stateinfluence, either direct or indirect, on banks’ operation and loan decisions is still

prevalent. SOCBs are still outperformed by their non-state counterparts (e.g. JSCBs)

in terms of NPLs ratio and growth of profitability. The future success of China’s

banking reform relies on whether banks can truly operate according to market

principles such as profitability and repayability, which in turn rest on the extent of

state dominance in loan decision.

Central government leaders are still reluctant to surrender their controls to the

market, not to mention of foreign investors. Expanding market liberalization of

Table 9. Top five economic sectors with highest NPLs 2009

Economic sector NPL ratio (%)

Hotels and catering services 4.82Farming, forestry, animal husbandry and fishing 4.52Culture, sports and entertainment 3.24Scientific research, technical services and geologic prospecting 2.98Credit card 2.83National average 1.6

Source: CBRC (2009).

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China’s banking sector may weaken central government’s macroeconomic control,

though market reforms have brought substantial benefits to China’s SOCBs. China

will continue to try to strike a balance between liberalization and state control in the

banking sector. Viewing from the global financial turmoil in 2008, central policy-

makers will place financial stability on the top agenda and bold steps towards further

ownership reform are unlikely in the near future.On the other front, the lack of access to credit by farmers and rural enterprises

cannot be resolved merely by market solutions. Government’s policy initiatives, such

as tax exemption or concessionary land rents, are needed to provide local and foreign

banks with incentives to invest in rural areas. This is especially important in remote

regions. Without addressing the credit problems in the countryside, a stable and

sustainable income increase can hardly be achieved. Consumption level of rural

households will probably continue to lag behind their urban counterparts. China’s

banking reform would be far from complete without addressing the issues of

ownership structure and rural finance.

Notes1 For example, China produced 58 million tons of extra capacity in the first half of 2009 when global

demand was estimated to decline by 14.9%. ‘‘Overcapacity exacerbated by recession’’ (China Daily,

12 April 2010), Available at http://www.chinadaily.com.cn/bizchina/2010-04/12/content_9714677.htm

(accessed 2 March 2011).2 The Central Committee Plenum on 14 November 1993 endorsed a document, ‘‘Decisions on some

questions relating to the setting up of a system of socialist market economy’’. It is stated in the

document that: ‘‘. . .even if State property remains the main base of the national economy, all forms of

property � State, collective and private � will have to be used in developing the economy’’. See Fabbri

(2006).3 Author’s calculation based on National Bureau of Statistics of China (formerly State Statistical Bureau),

Zhongguo Tongji Nianjian 1985 (ZGTJNJ hereafter, China Statistical Yearbook 1985), (Beijing:

Zhongguo Tongji Chubanshe), p. 581.4 Author’s calculation based on the data from National Bureau of Statistics of China, 2003, pp. 313 and 704.5 The three policy lending banks are the Agricultural Development Bank of China, Export�Import Bank

of China and the State Development Bank of China.6 For example, the State Development Bank sold 77.5 billion yuan of financial bonds to beef up its capital,

42.9 billion yuan was sold to the SOCBs (Lardy, 1998).7 At end of 2005, the CARs of BOC, CCB and ICBC were 10.42%, 13.75% and 10.26%, respectively.8 Available at http://www.cbrc.gov.cn/english/home/jsp/docView.jsp?docID�2007051774830DBD1F200

10BFFD7F4A6791F6F00 (accessed 7 January 2008).9 It is a further refinement of the five-tier loan classification (i.e. performing loans, special mention loans,

sub-standard loans, doubtful loans and loss loans). For each tier of loans, it is further subdivided into

several levels (in general, from one to four levels) to better reflect the loan quality.10 Standard Chartered subscribed US$0.5 billion of the share issued by ABC (Hu & Zhang, 2010).11 Some analysts pinpoint that the short service term of the foreign bankers in China’s SOCBs may be due

to the culture shock in management style. It is difficult to verify the validity of this view, but recent

reports, at least, provide anecdotal evidence to support this view. See ‘‘Chan quits top BOCHK post

after two months’’, South China Morning Post, 5 March 2008, B8.12 Wen made this statement before the H-share listing of BOC on 1 June 2006. Quoted from ‘‘Chinese PM

says state must control reform of state-owned bank’’, Available at http://www.redorbit.com/modules/

news/tools.php?tool�print&id�427198 (accessed on 29 November 2010).13 ‘‘China defends foreign bank ownership limit at WTO’’ Available at http://www.news.alibaba.com/

article/detail/trade/100193619-1-china-defends-foreign-bank-ownership.html (accessed 13 December

2010).

176 C. C. L. Kwong

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14 ‘‘China to extend lockup for banks’ foreign owners’’ Available at http://www.reuters.com/article/

idUSSHA25281320090401 (accessed 29 November 2010).15 For the impact of 1994 banking reform on rural enterprises, see Kwong and Lee (2005).16 See ‘‘China to improve rural bank access’’ Available at http://www.ft.com/cms/s/0/fa33053a-bc0a-11de-

9426-00144feab49a.html#axzz1AitAFvH7 (accessed 11 January 2010) and ‘‘Agricultural Bank of

China’s micro-credit loan program in rural areas expands rapidly’’ Available at http://www.english.

people.com.cn/90001/90778/7070266.html (accessed 11 January 2011).17 See also ‘‘China Postal Savings Bank wins approval to distribute insurance’’ Available at http://

www.forbes.com/feeds/afx/2008/08/06/afx5297723.html (accessed 9 June 2010).18 Calculated based on the data from Agricultural Bank of China 2010 Third Quarter Annual Report, p. 3

and CBRC 2009 Annual Report, p. 122.19 He (2008) indicates that average loan amount to rural households in low income province, such as

Guizhou, was only 4612 yuan according to a survey conducted in Guizhou in 2005.20 Credit information of 74 million rural household was recorded by 2007, which was about one-third of

China’s rural households (See Gale, 2009). The proportion of households is calculated based on the data

from ZGTJNJ CD-ROM 2007 (Tables 3�14).21 Since 2003, the government has allowed the RCCs to charge interest rate 2.3 times higher than the

benchmark rate set by the PBOC while the new rural financial institutions, such as rural commercial

banks, have been allowed to charge up to four times of the benchmark rate (Gale, 2009).

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