Nuestro país ha comenzado a implementar su más ambiciosa reforma del último tiempo en materia regulatoria: la modernización de su normativa financiera. La ya promulgada Ley N° 21.000 transforma profundamente la institucionalidad en materia de valores y seguros con la creación de una nueva autoridad, la Comisión para el Mercado Financiero (“CMF”), que sustituirá a la actual SVS. En una segunda etapa que ya se discute en el Congreso, se proyecta que este órgano concentre los poderes regulatorios actualmente radicados en la SBIF.
Entre los cambios que introduce la Ley N° 21.000, los más comentados han sido el paso desde una autoridad unipersonal al modelo de comisión y la separación de los poderes investigativos y sancionatorios. Sin embargo, esta ley incorpora otras interesantes novedades en la línea de las mejores prácticas internacionales, que merecen mayor atención. Es el caso del artículo 20 número 3, que introduce en nuestra legislación financiera la Evaluación de Impacto Regulatorio (“EIR”), una herramienta que podría contribuir grandemente en la actividad normativa de la CMF. En términos generales, la EIR consiste en un proceso que debe conducir la autoridad cada vez que se proponga dictar una nueva regulación y cuyo objetivo general es racionalizar y justificar la dictación de esa determinada normativa. Asimismo, el proceso evaluativo fortalece la transparencia de la actividad regulatoria, favoreciendo el escrutinio por parte de la industria y el público en general, ya que además suele ir acompañada de procesos de consulta pública. Siguiendo a Baldwin (2005), una EIR exige de la agencia la definición precisa del problema que se busca resolver. También requiere identificar quienes serán los posibles sujetos afectados por la normativa, sean miembros de la industria regulada o terceros que se verán alcanzados por sus efectos. Lo anterior le permite a la agencia determinar el tipo y la fuente de la información que requerirá para evaluar la norma propuesta y estimar su viabilidad en términos de la fiscalización de su cumplimiento.
Una buena EIR también debiese incorporar el análisis de alternativas a la clásica dictación de una norma aparejada de una sanción. Frecuentemente, la autoridad no es capaz de fiscalizar el cumplimiento de este tipo de normas, ya sea por falta de recursos o porque carece de la información necesaria para hacerlo, lo que en la práctica se traduce en que la regulación es incapaz de cambiar la conducta de la industria. Vale la pena, por tanto, analizar el uso de alternativas que puedan resultar más eficientes. Por ejemplo, la regulación por principios, que traslada al regulado la carga de determinar la forma de cumplimiento, o la autorización a la industria para proponer medidas de autorregulación en ciertas materias, bajo seguimiento de la autoridad. El análisis más complejo que debería realizar la autoridad en una medición de impacto regulatorio es el estudio de los costos y beneficios aparejados a su intervención. Es probable que existan alternativas menos costosas, o que sea posible traspasar el costo a los privados en forma eficiente. Incluso, es posible que los costos sean altos, pero que aun así se apueste por intervenir.
La EIR es un instrumento que se utiliza hace décadas en forma sistemática y obligatoria para prácticamente toda la administración en jurisdicciones tales como Reino Unido, Estados Unidos y la Unión Europea. En el ámbito internacional, la OECD ha sido su mayor promotor. De hecho, en su informe denominado “Política Regulatoria en Chile” (2016) este órgano constató que, salvo casos excepcionales, en nuestro país no se realiza acción alguna para estimar las consecuencias de una propuesta de regulación y recomendó la adopción sistemática de evaluaciones de impacto en todos los procesos regulatorios de los órganos gubernamentales.
No obstante lo sugerido por la OECD, la opción tomada por nuestro país de comenzar con la adopción de EIR limitada a un regulador específico en vez de extenderlo a toda la administración, parece ser la decisión más razonable. El estudio de alternativas regulatorias y la cuantificación de costos y beneficios son procesos técnicos y complejos que requieren estudios calificados y, precisamente, una de las mayores críticas al sistema de evaluación regulatoria en Estados Unidos (Moyano 2013) y Europa (Balwin 2005) es que la gran mayoría de las reparticiones y ministerios carecen de los recursos y capacidades para llevarlo a cabo correctamente, transformándolo en una mera obligación burocrática que descargar, frustrando así los objetivos de mejora regulatoria. En ese sentido, la elección de una agencia como la CMF para dar los primeros pasos en la medición del impacto de nuestras normativas también resulta auspicioso. La sucesora de la SVS no sólo tiene la capacidad institucional y la reputación técnica necesarias para emprender la tarea, sino que posee los recursos para diseñar un marco evaluativo, capacitar a su personal y, en suma, poner en marcha un buen programa de EIR.
La futura CMF enfrenta un desafío clave en la implementación de su sistema de evaluación. Uno de los objetivos de la reforma es progresivamente otorgarle a la agencia un rol central en la regulación de los dinámicos mercados financieros, por lo que, si este nuevo órgano es capaz de justificar adecuadamente su actividad normativa, habrá más espacio para su autonomía. De paso, si la experiencia es exitosa podría dar pie a la extensión de la EIR a otros ámbitos. La redacción genérica y amplia del artículo 20 numeral 3, lejos de ser un obstáculo para su aplicación, abre una inédita oportunidad a la Comisión para legitimar y transparentar su actividad regulatoria, acogiendo los mejores estándares técnicos. En ese sentido, es recomendable que se genere a la brevedad una guía que instruya las etapas, plazos y niveles de análisis que la CMF pretende llevar a cabo como parte de su evaluación regulatoria, de forma de que el proceso sea serio y previsible. Asimismo, es esperable que el regulador limite al máximo su facultad discrecional de prescindir de los trámites de evaluación y consulta pública de sus normativas. Un uso indiscriminado de esa prerrogativa le haría un flaco favor a la CMF, ya que socavaría la confianza que la reforma ha depositado en esta autoridad.
Virginia Rivas Sánchez. Abogada, U. de Chile (2011). LL.M., U. of California, Berkeley (2013). MSc. en Regulación, London School of Economics (2017).
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