2015-03-08 央行观察

人行回避了一点，即外汇储备的形成和政府发行国债的机制相同，而一旦以这一角度切入分析，则外汇储备就开始等同于发行国债获得的资金，似乎并没有什么一定不能“支出”或“划拨”的。

作者：季天鹤，万门大学CFO，央行观察特约专栏作家

近日，外汇局注资丝路基金引发关注，而伴随着外汇储备的创新使用，其能否无偿划拨的问题尚未完全解决。一方面，人们从常识出发，认为外汇储备作为政府资产，当然可以和国企股份等资产一样划拨。另一方面，人民银行和外汇局多次阐述反对划拨的理由，其中之一是外汇储备来源和税收不同，外储是人行发行负债购买的结果。但事实上，人行将外汇储备来源和税收比较本身并不合理。

首先我们回顾一下外汇储备的来源。在中国，人行在银行间外汇市场购买外汇，在资产侧形成了外汇储备，同时在负债侧创造了准备金存款，资产和负债同时等量增加。除购买外汇外，外汇储备投资可以使外汇储备增值，而该投资收益可上缴财政或划拨至其它方，例如在《朱镕基讲话实录》第四卷《我们的外汇政策是正确的》中提到，2002年外汇储备收益被划拨至社会保障基金，而该基金的资金来源还有国有企业IPO筹集的部分资金等。

既然人行将外汇储备来源和税收对比，那么我们也有必要看一下财政收支。在中国，最大口径的财政收支涵盖公共财政、政府性基金、国有资本经营和社会保障，其中公共财政收入（这当中包括税收）和支出无需专款专用，收不抵支时形成财政赤字。除财政收支外，财政部还发行国债，近年来每年发行额大于兑付额，因此国债余额逐年增加。由于人行经理国库，政府存款是人行的一项负债，如同个人储蓄存款是商行负债一样，而财政存款便受财政收支与国债的发行和兑付影响。在纳税人缴税和国债发行时，财政存款增加，而当财政支出和国债兑付时，财政存款减少。

如果财政部也编制一张资产负债表，那么我们会发现，在发行国债的过程中，财政部在资产侧获取“人民币储备”，也就是通过发行国债换来人民币，同时负债侧“国债余额”等量增加，形成购买者持有的国债头寸。在这个过程中，财政部“人民币储备”和“国债余额”的关系，恰恰等同于人行在购汇过程中，在资产侧获取“外汇储备”，在负债侧创造等量准备金存款。从创造机制上看，财政部发行国债增加政府存款是通过扩大负债而增加资产，而人行发行准备金存款购买外汇也是通过扩大负债而增加资产，两者完全相同。如果说外汇储备是人行发行人民币购买的结果，那么财政部的部分“人民币储备”也是财政部发行国债购买的结果。

而我们知道，财政部的政府存款余额（目前约为3万亿元）小于国债余额（目前约为10万亿元），而财政部在支出的时候并不仔细考虑哪部分政府存款是通过发行国债获得，哪部分是通过征税收费获得，而是把国债发行募集的资金和税收等一同纳入整体收支当中。因此，对人行通过扩大负债而获得的资产而言，理论上并不存在阻碍人行像财政部一样支出的障碍，无需考虑资产的来源，即区分扩大负债得到的资产和通过收益得到的资产。从另一个角度看，前文提到人行可以把外汇储备收益上交国库，而这和财政部将国企利润相同，都是上缴资产产生的收益。而我们也知道，除了利润，国企的股权也可以划拨给社保基金，那么人行的外汇储备资产被划拨给社保基金，似乎也不存在障碍。

而且，国债到期时，国家必须偿付本金，若无法新发国债，则政府的资产方将减少政府存款，而负债方减少国债余额，国家永远面临着无法续发的风险。但是目前，人行负债侧纸币和准备金存款的持有者无权兑换人行任何资产，而人行票据到期时，持有者只是减少了央票而多了准备金存款，对人行而言仅是负债科目变化而非总量变化。因此，如果面临更大赎回风险的财政部，并不认为国债余额和政府存款在数量上的错配是一个大问题，那么不面临赎回风险的人行，似乎更无需追求外汇储备和其创造的人民币的精确匹配。

我们还可以看到，新闻经常报道地方政府欠条在当地以货币方式流通，该欠条并不能在全国通行，而只能在当地使用，但任何中国地方政府的人民币存款则可以在全国使用。与之相似，作为人行债务的人民币目前主要在国内流通，但人行持有的外汇储备则可以在全球流通（在过去由黄金扮演该角色）。经过这样的对比，我们就更能看清楚政府发行债券获得更高流动性资产的过程，和人行发行人民币获得更高流动性资产的过程是对应的，但与人行不同，打白条的政府花掉其换得的人民币纸币或银行存款时并无半点犹豫。

所以一方面，人行关于市场主体“不是把外汇无偿交给国家，而是卖给了国家，并获得了等值人民币，这与税收和财政收入明显不同”的说法，我认为是正确的，即外汇储备的形成和税收与财政收入确实不同。但另一方面，人行回避了一点，即外汇储备的形成和政府发行国债的机制相同，而一旦以这一角度切入分析，则外汇储备就开始等同于发行国债获得的资金，似乎并没有什么一定不能“支出”或“划拨”的。所以，外汇储备不能无偿划拨的理由，不应是“与税收不同”。

The People's Bank of China avoids one point, which is that the mechanism for forming foreign exchange reserves is the same as the government issuing national debt. Once analyzed from this perspective, foreign exchange reserves start to be equated with the funds obtained from issuing national debt, and there seems to be no definite barrier to "spending" or "allocation".

Recently, the injection of funds into the Silk Road Fund by the State Administration of Foreign Exchange has attracted attention. Along with the innovative use of foreign exchange reserves, the question of whether they can be allocated without compensation has not been completely resolved. On one hand, people commonly believe that foreign exchange reserves, as government assets, can certainly be allocated like shares of state-owned enterprises. On the other hand, the People's Bank of China and the State Administration of Foreign Exchange have repeatedly stated reasons against allocation, one of which is that the sources of foreign exchange reserves and taxes are different, with foreign reserves being the result of the central bank issuing liabilities to purchase.

However, in fact, the comparison the People's Bank of China draws between the sources of foreign exchange reserves and taxes is not reasonable. First, let's review the sources of foreign exchange reserves. In China, the central bank purchases foreign exchange in the interbank foreign exchange market, forming foreign exchange reserves on the asset side and simultaneously creating required reserve deposits on the liability side. Assets and liabilities increase in equal amounts. Apart from purchasing foreign exchange, investment of foreign exchange reserves can appreciate their value. This investment income can be turned over to the government or allocated to other entities. For example, in Volume 4 of "Transcripts of Zhu Rongji's Speeches" under the title "Our Foreign Exchange Policy is Correct," it is mentioned that in 2002, the income from foreign exchange reserves was allocated to the Social Security Fund. The funds of this fund also came from a portion of funds raised by state-owned enterprises' IPOs.

Since the People's Bank of China is comparing the sources of foreign exchange reserves and taxes, it is also necessary to look at fiscal revenue and expenditure. In China, the largest-caliber fiscal revenue and expenditure includes public finance, government funds, state-owned capital operations, and social security. Revenue (including taxes) and expenditure of public finances do not require special accounts, and a fiscal deficit is formed when revenue does not cover expenditure. In addition to fiscal revenue and expenditure, the Ministry of Finance also issues national debt, with annual issuance exceeding redemption in recent years, resulting in an increasing balance of national debt. Since the People's Bank of China manages the national treasury, government deposits are a liability of the central bank, similar to how personal savings deposits are a liability of commercial banks. Fiscal deposits are influenced by fiscal revenue and expenditure, as well as the issuance and redemption of national debt. When taxpayers pay taxes and national debt is issued, fiscal deposits increase. When fiscal expenditure and national debt are redeemed, fiscal deposits decrease.

If the Ministry of Finance also compiles a balance sheet, we will find that during the issuance of national debt, the Ministry of Finance obtains "Renminbi Reserves" on the asset side, i.e., obtains RMB by issuing national debt, and simultaneously increases "National Debt Balance" on the liability side by an equal amount, forming the national debt positions held by buyers. In this process, the relationship between the Ministry of Finance's "Renminbi Reserves" and "National Debt Balance" is precisely the same as that of the central bank's "Foreign Exchange Reserves" obtained on the asset side during foreign exchange purchases and the equal creation of required reserve deposits on the liability side. Mechanistically, when the Ministry of Finance issues national debt to increase government deposits, it does so by expanding liabilities and increasing assets. Similarly, the central bank increases assets through the expansion of liabilities when it issues required reserve deposits to purchase foreign exchange. The two processes are identical. If foreign exchange reserves are the result of the central bank issuing RMB to purchase, then a portion of the Ministry of Finance's "Renminbi Reserves" is also the result of issuing national debt to purchase RMB.

Furthermore, we know that the balance of government deposits (currently around 3 trillion RMB) held by the Ministry of Finance is smaller than the balance of national debt (currently around 10 trillion RMB). When the Ministry of Finance spends, it doesn't meticulously consider whether the portion of government deposits was obtained through issuing national debt or through taxation and fees. Instead, the funds raised by issuing national debt and taxes are all included in the overall revenue and expenditure. Therefore, for the assets obtained by the People's Bank of China through expanding liabilities, theoretically, there is no obstacle to spending like the Ministry of Finance does. It doesn't need to consider the source of the assets, i.e., distinguishing assets obtained by expanding liabilities from those obtained through income. From another perspective, as mentioned earlier, the People's Bank of China can turn over the income from foreign exchange reserves to the national treasury, just like how the Ministry of Finance turns over state-owned enterprise profits. Both are generated from the turnover of assets. Also, besides profits, state-owned enterprise equity can be allocated to the social security fund. Thus, there seems to be no obstacle to allocating the People's Bank of China's foreign exchange reserve assets to the social security fund.

Moreover, when national debt matures, the country must repay the principal. If new national debt cannot be issued, then the assets of the government will decrease as government deposits decrease, and the liabilities side will decrease as the balance of national debt decreases. The country always faces the risk of not being able to issue new debt. However, currently, holders of the liability side of the central bank, which includes banknotes and required reserve deposits, do not have the right to exchange them for any assets of the central bank. When the central bank's bills mature, holders merely exchange central bank bills for required reserve deposits. For the central bank, this represents a change in liability items rather than a change in the overall amount. Therefore, if the Ministry of Finance, which faces greater redemption risks, does not regard the mismatch in quantity between the balance of national debt and government deposits as a significant problem, then the People's Bank of China, which doesn't face redemption risks, seems even less needful to pursue precise matching between foreign exchange reserves and the RMB they create.

We can also observe that news frequently reports local government IOUs circulating as currency in local areas, which cannot be used nationwide but only locally. However, any local Chinese government's RMB deposits can be used nationwide. Similarly, although RMB, as the liability of the People's Bank of China, mainly circulates domestically, foreign exchange reserves held by the central bank can circulate globally (in the past, gold played this role). Through this comparison, we can better see the process by which the government issues bonds to obtain higher liquidity assets and how the central bank issues RMB to obtain higher liquidity assets are corresponding processes. However, unlike the People's Bank of China, when the government that issues promissory notes spends the RMB banknotes or bank deposits obtained from them, there is no hesitation.

Therefore, on one hand, the statement by the People's Bank of China that market entities "do not unconditionally give foreign exchange to the state for free, but sell it to the state and obtain an equivalent amount of RMB, which is clearly different from taxes and fiscal revenue," I believe is correct, namely that the formation of foreign exchange reserves is indeed different from taxes and fiscal revenue. However, on the other hand, the People's Bank of China avoids one point, which is that the mechanism for forming foreign exchange reserves is the same as the government issuing national debt. Once analyzed from this perspective, foreign exchange reserves start to be equated with the funds obtained from issuing national debt, and there seems to be no definite barrier to "spending" or "allocation". Therefore, the reason why foreign exchange reserves cannot be allocated without compensation should not be "different from taxes."