Page 329 - Special Topic Session (STS) - Volume 1

STS441 Burcu Zühal İ.E. et al.
In this context, the CBRT has taken a major step in terms of constructing a
data set that enables micro level analysis by initiating the “Systemic Risk Data
Monitoring System”. To increase the resilience of Turkish economy against
exchange rate volatility, Turkey’s Financial Stability Board decided to establish
a new regulatory framework of FX risk management based on a company
specific data set where risks can be monitored in detail. For this purpose, the
duty of collecting detailed data about foreign currency positions of non-
financial firms has been assigned to the CBRT. At first, non-financial firms,
which have FX loans over 15 million US dollars constitute the scope of the
system. The aim is to conduct analysis of detailed company level data and use
the results as an input in the surveillance process in order to allow more
precise calculation of risks and effective policy making.
According to the CBRT Law, the Bank is authorized to collect data on
economic issues and produce statistics by compiling and processing data. In
order to establish the legal basis to collect data for purposes other than
producing statistics, amendments to the Central Bank Act. Law Nr 1211 are
made. With the amendments, the CBRT has gained the authority to request all
kinds of information and documents from real and legal persons to monitor
their transactions affecting their foreign exchange positions. Central Bank
determines the scope of the requested information and documents, method
of collecting and monitoring data, supervision of accuracy and all the other
principles of implementation. Judicial fine shall be imposed against companies
that do not give the required information and documents, or give incomplete
or incorrect information. Regulation on the Principles and Procedures
regarding the Monitoring of Transactions Affecting Foreign Exchange Position
by the CBRT has been enacted and announced in the Official Gazette dated
17/2/2018. The regulation rules that firms report the data forms specified by
the CBRT quarterly and annually. The annual reports are subject to
independent auditing process in order to maintain a high quality database.
Firms are allowed to submit their quarterly reports in two months, and annual
reports in three months. Besides, firms are allowed for two additional months
for independent auditing process.
The system is based on a comprehensive data set to monitor FX position,
cash flow and derivative instrument utilization of non-financial companies
which has FX debt over 15 million US dollars. 15 million US dollars of reporting
scope threshold has been set due to the fact that the majority of FX debt (%80)
has concentrated on ca. 2,000 companies with FX debt of 15 million US dollars
or over. 20,000 companies with FX debt under the specified threshold account
for %20 of the total FX debt.
After completing the legal basis, the system has been established by the
CBRT in cooperation with Credit Registry Bureau of Turkey for installation of
system infrastructure, software, maintenance, and operation and support

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