2015-03-28 央行观察

既不能将划拨一定减少央行净资产当作不能划拨的理由，也不能将划拨不一定减少央行净资产当成可以划拨的依据

作者：季天鹤，万门大学CFO，央行观察专栏作家

2015年3月8日由央行观察发表的文章《外汇储备不是税，那是啥？》提到，人民银行和外汇局有三点理由反对无偿划拨外汇储备，其中“外汇储备来源和税收不同”一条已在该文中讨论，本文将试图讨论另一点，即划拨外汇储备会引发资产负债表的不平衡，例如外汇局发布的《外汇管理概览》第六章《外汇储备管理》提到：“外汇储备是由人民银行用人民币在外汇市场上购买外汇形成的，在人民银行资产负债表上对应着等值的人民币负债。”资产少了，负债不变，净资产自然就少了。

但事实上，央行的外汇储备以 “中央银行外汇占款”（例如外汇局《2011 年中国跨境资金流动监测报告》第15页）的方式在央行资产负债表上体现。在《2012 年上半年中国国际收支报告》中，外汇局进一步提到：“央行外汇占款余额变动主要包括两个方面：一是中央银行进行外汇买卖时相应投放或吸收的人民币资金变动，二是由于外汇储备经营收益部分结汇而投放的人民币资金变动。” 外汇局提到的“等值对应”，指的就是上面两个过程中的人民币资金和外汇。

首先考察外汇储备经营收益。利息等外汇储备经营收益会导致外汇储备资产增加，但由于该收益和央行外的其他主体无关，因此经营收益不应对应央行负债的增加，而应对应央行净资产的增加。收益的未结汇部分由于没有人民币投放，不会对外汇占款产生影响，仅增加外汇储备的价值。而结汇部分一方面对应外汇占款增加，另一方面应对应央行净资产增加，这也和负债无关。因此未结汇的储备经营收益不投放人民币，而结汇的收益虽然投放人民币但并不体现为负债，于是经营收益会使外汇储备增加一块不对应人民币负债的资产，朱镕基总理提到的收益上缴应该也是指这块儿。

其次考察储备价值变动。外汇储备是多币种多市场多产品的投资组合，最终估值也是按照一种公允价格的方式计量，和外汇占款的计价原则不同。例如将外汇储备简化为美元和欧元纸币，这个资产组合没有任何利息股息收益。欧元和美元汇率波动会影响美元计价的外汇储备余额，却并不会影响外汇占款余额。由此我们看到一种可能：即使欧元化为乌有，也不会影响外汇占款和央行负债。而即使欧元升值，外汇储备估值上升，外汇占款和央行负债也不会有变化。

最后考察人民币升值的影响。在发行人民币购买外汇从而形成外汇储备的过程中，虽然每笔交易中人民币与外汇以当时的汇率“等值”交易，但外汇占款是历史成本的口径，即交易时“投放和吸收的人民币资金”，而外汇储备是公允价值的口径。例如外汇储备都是美元纸币，既无利息股息收益，也无相对于美元的价值变动，但由于之前买入美元的时候人民币汇率一直在变化，因此美元纸币余额与外汇占款余额的关系不可能是现行汇率，两者没有“等值对应”的依据。上面三点综合起来解释了为什么目前3.8万亿美元外汇储备对应了27万亿人民币的外汇占款。

外汇占款的历史成本计价法是合理的。例如，人民币升值中不断产生一种观点，即认为人民币升值给央行导致了巨大的损失，其逻辑就是将外汇占款按照外汇储备的人民币市值重估，贬值的美元对应较少的人民币值，央行也就不断亏损。但对央行而言，投放人民币换入外汇这一过程，在帐面上产生的是外汇占款和银行准备金，前者不随外汇储备的价值变动而变动，后者和外汇占款同受央行买卖外币影响而等量变动，因此人民币升值通过买入外币价格的变化等量影响资产和负债，在帐面上不会引发亏损。当然在相反情况下，贬值也不会引发盈利。

但历史成本法使央行避免了在人民币升值中破产的同时，也分离了外汇储备和外汇占款，造成外汇储备减值时也不会破产的后果。央行购汇在资产侧增加外汇占款，负债侧增加银行准备金，一一对应的是这两者，而外汇占款和外汇储备之间并不“等值对应”，与外汇占款对应的准备金也不和外汇储备“等值对应”。因此一方面不结汇的储备收益，无论是欧元升值还是利息收益都不影响外汇占款，另一方面，不购汇的储备减损也不影响外汇占款，无论是股价下跌或无偿划拨，后者非但不会崩坏央行的资产负债表，反而对央行资产负债表不产生任何影响。

当然，央行可以在划拨中加入购汇的环节，按照现行汇率减计外汇占款和净资产。但参照不结汇的储备经营收益的例子，划拨要不要购汇以及以何种价格购汇就需要思考了。如果没有购汇这个环节，外汇占款没有减少，就需要考虑如何将划拨反映到其他资产的减少上。但不管报表如何处理，划拨就是划拨，本身就可能造成市场卖出人民币买入外汇逼空央行和人民币的后果，特别是受让方将高流动性资产转化为低流动性资产甚至消费之后。所以，既不能将划拨一定减少央行净资产当作不能划拨的理由，也不能将划拨不一定减少央行净资产当成可以划拨的依据。

Neither can reducing central bank net assets by a certain amount as a result of allocation be used as a reason against allocation, nor can the fact that allocation doesn't necessarily reduce central bank net assets be considered as a basis for allowing allocation.

On March 8, 2015, an article titled "Foreign Exchange Reserves are not Taxes, then What Are They?" was published by "Central Bank Watch." The article discussed three reasons put forth by the People's Bank of China and the State Administration of Foreign Exchange against the unconditional allocation of foreign exchange reserves. One of these reasons, namely "the difference between the source of foreign exchange reserves and taxation," had been discussed in the article. This article aims to explore another point, which is that the allocation of foreign exchange reserves can lead to an imbalance in the central bank's balance sheet.

For instance, in the sixth chapter of the "Overview of Foreign Exchange Management" released by the State Administration of Foreign Exchange, it is stated that "foreign exchange reserves are formed by the People's Bank of China purchasing foreign exchange in the foreign exchange market using the Chinese yuan, corresponding to an equivalent amount of Chinese yuan liability on the People's Bank of China's balance sheet." If the assets decrease while liabilities remain unchanged, the net assets naturally decrease. However, in reality, the central bank's foreign exchange reserves are reflected on its balance sheet as "Central Bank Foreign Exchange Allocations," as indicated in the "2011 Report on China's Cross-Border Capital Flow Monitoring" by the State Administration of Foreign Exchange on page 15.

In the "China International Balance of Payments Report for the First Half of 2012," the State Administration of Foreign Exchange further explains that the change in the central bank's foreign exchange allocation balance primarily includes two aspects: first, the corresponding injection or withdrawal of Chinese yuan funds by the central bank during foreign exchange trading; second, the injection of Chinese yuan funds resulting from the conversion of a portion of foreign exchange reserves operating income. This "equivalent correspondence" mentioned by the State Administration of Foreign Exchange refers to the Chinese yuan funds and foreign exchange in the above two processes.

Let's begin by examining the operational income of foreign exchange reserves. Income from interest and other foreign exchange reserve operations leads to an increase in foreign exchange reserve assets. However, since this income is unrelated to entities outside the central bank, it should not result in an increase in central bank liabilities but rather an increase in central bank net assets. The portion of income that remains unsettled does not involve the injection of Chinese yuan and thus has no impact on foreign exchange allocations; it merely increases the value of foreign exchange reserves. On the other hand, the settled portion corresponds to the increase in foreign exchange allocations and also corresponds to the increase in central bank net assets; this is unrelated to liabilities. Therefore, while unsettled reserve operational income does not involve Chinese yuan injection, the income from settlement is injected into Chinese yuan but does not manifest as liabilities. Consequently, operational income results in an increase in foreign exchange reserves, creating an asset that is not offset by Chinese yuan liabilities, which Prime Minister Zhu Rongji referred to as "income remittance."

Next, let's consider the variation in reserve value. Foreign exchange reserves are a diversified portfolio of multiple currencies, markets, and products, ultimately measured according to a fair value approach, unlike the valuation principles of foreign exchange allocations. For instance, if we simplify foreign exchange reserves to only U.S. dollars and euros, this asset composition yields no interest or dividend income. Fluctuations in the euro-to-dollar exchange rate would affect the U.S. dollar-denominated foreign exchange reserve balance but would not impact the foreign exchange allocation balance. This suggests that even if the euro were to lose value, it would not affect foreign exchange allocations and central bank liabilities. Similarly, if the euro appreciates, causing an increase in the valuation of foreign exchange reserves, this would not affect the foreign exchange allocation and central bank liabilities.

Lastly, let's examine the impact of the appreciation of the Chinese yuan. In the process of issuing the Chinese yuan to purchase foreign exchange and thereby form foreign exchange reserves, although each transaction involves an exchange of Chinese yuan and foreign exchange at the prevailing exchange rate, the foreign exchange allocation is based on historical costs, i.e., the Chinese yuan funds injected or withdrawn during transactions. In contrast, foreign exchange reserves are based on fair value. For instance, if foreign exchange reserves consist solely of U.S. dollar bills, with no interest, dividend income, or relative value changes concerning the U.S. dollar, the relationship between the U.S. dollar bill balance and the foreign exchange allocation balance cannot be based on the current exchange rate. There is no basis for "equivalent correspondence" between the two. The combination of the above three points explains why the current $3.8 trillion foreign exchange reserves correspond to ¥27 trillion foreign exchange allocations.

The historical cost valuation method of foreign exchange allocations is reasonable. For example, during the appreciation of the Chinese yuan, a viewpoint emerged that the appreciation caused significant losses to the central bank. The logic behind this was to reevaluate foreign exchange allocations based on the Chinese yuan market value of foreign exchange reserves. A depreciating U.S. dollar corresponded to a lower Chinese yuan value, causing continuous losses for the central bank. However, for the central bank, the process of injecting Chinese yuan in exchange for foreign exchange creates foreign exchange allocations and bank reserve requirements on the balance sheet. The former remains unchanged with fluctuations in foreign exchange reserve value, while the latter adjusts in tandem with foreign exchange allocation due to central bank foreign currency trading. Therefore, the appreciation of the Chinese yuan affects assets and liabilities equivalently through changes in the purchase price of foreign currency and does not lead to losses on the balance sheet. Conversely, depreciation also does not result in profits.

However, the historical cost method prevents the central bank from facing bankruptcy during Chinese yuan appreciation while also separating foreign exchange reserves from foreign exchange allocations. This mitigates the consequences of foreign exchange reserve devaluation on bankruptcy. On the asset side, the central bank's foreign exchange allocations increase, and on the liability side, bank reserve requirements increase. Each corresponds to the other, yet there is no "equivalent correspondence" between foreign exchange allocations and foreign exchange reserves, and the reserve requirements corresponding to foreign exchange allocations do not match foreign exchange reserves. Therefore, on one hand, the income from unrealized profits of unsettled reserves, whether due to euro appreciation or interest income, does not affect foreign exchange allocations. On the other hand, the loss of unrealized reserves from not purchasing foreign exchange also does not affect foreign exchange allocations. Whether due to declining stock prices or unconditional allocations, the latter not only does not destabilize the central bank's balance sheet but also does not affect it in any way.

Of course, the central bank can include a foreign exchange purchase component in the allocation process, deducting foreign exchange allocations and net assets based on the current exchange rate. However, taking the example of unrealized profits from unsettled reserves into account, whether foreign exchange purchases should be incorporated in the allocation and at what exchange rate needs careful consideration. If this purchase component is absent, foreign exchange allocations remain unchanged, necessitating consideration of how the allocation can reflect in the reduction of other assets. Regardless of how financial statements handle this, the allocation remains an allocation, inherently carrying the potential to compel the central bank and the Chinese yuan into a corner by prompting market sales of Chinese yuan and purchases of foreign exchange. This is especially true when the recipient transforms highly liquid assets into low-liquidity assets or even consumption. Therefore, it is not justifiable to use the argument that allocating funds will definitely reduce the central bank's net assets as a reason to oppose allocation. Furthermore, it is not acceptable to use the argument that allocating funds will not necessarily reduce the central bank's net assets as a basis for justifying allocation.