The financial supervisory system in South Korea possesses an anomalous structure that is globally unparalleled. The structure involves the Financial Services Commission (FSC), a bureaucratic body, carrying out financial industry policy and financial s...
The financial supervisory system in South Korea possesses an anomalous structure that is globally unparalleled. The structure involves the Financial Services Commission (FSC), a bureaucratic body, carrying out financial industry policy and financial supervisory policy, while the Financial Supervisory Service (FSS), a quasi-private organization, carries out financial supervision enforcement.
This layered (or "dual/overlapping") supervisory structure, consisting of a bureaucratic body that handles both industry and supervisory policy and a subordinate quasi-private organization responsible for enforcement, has caused significant controversy in Korean society.
Major financial incidents—such as the credit card crisis, savings bank crisis, Dongyang incident, and private equity fund crises—occur ceaselessly, and the debate over fundamental reform has persistently been raised. Despite the lack of disagreement among scholars regarding the current system's problems and potential reforms, the supervisory system has not been fundamentally restructured and has maintained this layered bureaucratic-private structure for over 20 years. Therefore, this study analyzes the reasons for the persistence of the financial supervisory system (i.e., why the institution has not changed) from the perspective of Historical Institutionalism, focusing on path dependence.
Prior to the Asian Financial Crisis (or IMF Crisis), the debate over financial supervisory system reform was characterized by the conflict between the Ministry of Finance (MoF) and the Bank of Korea (BOK) over the separation of the Office of Bank Supervision(OBS). At the time, the BOK was responsible for both the supervision policy and enforcement for banks, while the MoF held the supervisory policy authority for securities and insurance, with enforcement carried out by the Securities Supervisory Board and
Insurance Supervisory Board, respectively. Consequently, the MoF, under the framework of government-led economic growth, sought to acquire supervisory authority over banks.
This conflict was resolved through the critical juncture of the foreign exchange crisis. The IMF proposed the establishment of an integrated, non-governmental (or "quasi-private") financial supervisory body separated from the government. The BOK accepted the separation of the OBS in exchange for its Governor gaining the chairmanship of the Monetary Policy Committee. The then-Ministry of Finance and Economy (MoFE) accepted the establishment of the integrated non-governmental supervisory body on the condition that a civil servant organization (secretariat) be installed under the newly formed FSC. As a result of the IMF, MoFE, and BOK adjusting their respective interests under the strong external shock of the foreign exchange crisis, the dual supervisory system, composed of the FSC (bureaucratic) and FSS (quasi-private), was launched. The integrated financial supervisory system, which was launched to abolish "government-controlled finance" (Kwan-chi Geum-yung)—identified as a cause of the crisis—saw the dual bureaucratic-quasi-private nature of its structure gradually deepen as the FSC Secretariat continuously expanded its personnel and functions after its establishment.
After President Lee Myung-bak was elected in 2008, the Presidential Transition Committee consolidated the financial industry policies of the FSC and the Ministry of Finance and Economy to establish the current Financial Services Commission (FSC). This physically separated the FSC and FSS (which had previously been dual but physically integrated) and further strengthened the layered bureaucratic-quasi-private structure, as the FSC retained guidance and supervisory authority over the FSS.
Subsequently, Presidents Park Geun-hye, Moon Jae-in, and political figure Lee Jae-myung all proposed financial supervisory system reform as a key pledge. However, the resulting reforms have consistently focused only on restructuring the FSS, not the fundamental supervisory system itself.
The financial supervisory system spans multiple government agencies—including the Ministry of Economy and Finance (MoEF) (international financial policy), the FSC (domestic financial policy/supervisory policy), and the FSS (supervision enforcement)— making fundamental reform impossible without a large-scale government reorganization. Nevertheless, the bodies tasked with discussing the reform of the system were often established under the FSC itself, thus lacking the authority to discuss broad government reorganization. Consequently, discussions were consistently limited to restructuring the FSS, which was achievable without major government organizational change. By neglecting the fundamental problems of the supervisory system debate and instead pursuing partial improvements within the existing institutional framework, the
financial supervisory system has developed path dependence.