How do countries run their state banks?

China's ICBC is currently the biggest bank in the world - and the government is a big reason for that

Royal Bank of Scotland boss Stephen Hester has decided to forego his bonus, something that the UK chancellor said is "sensible and welcome".

But, of course, the government could always have vetoed the bonuses: it owns most of the shares in the bank - 82%, in fact, after RBS's spectacular collapse in 2008.

But Prime Minister David Cameron has refused to block Mr Hester's bonus and that of other executives, saying it would be political interference in the bank.

The government has decided that pretending it does not own the bank is the best way to get its money back.

But this is not a given; there are many ways of running a state-owned bank. A government can decide to take an active role in its banking sector.

So how do some countries run the banks that they own - whether they want to or not?

UK

During the height of the financial crisis in 2008, the UK was forced to take ownership stakes of many of its banks - including Northern Rock, RBS, Lloyds TSB, HBOS and Bradford & Bingley.

The government set up UK Financial Investment (UKFI) to run the stakes in the firms. It is a formal company under the Companies Act with HM Treasury as its sole shareholder.

That means, the chief executive of UKFI cannot be formally directed to do anything by its board - the government. They essentially only have the power to sack him.

"UKFI's overarching objective is to manage these shareholdings commercially to create and protect value for the taxpayer," according to its mandate.

The UK has put in people from the private sector - a team of "experts" - that it thinks will maximise the return to the taxpayer.

Former private equity man Sir David Cooksey recently retired as chairman of the board, with former UBS executive Robin Budenberg taking over.

The man responsible for looking after RBS is Jim O'Neil, the incoming chief executive and an American who used to work at Merrill Lynch - acquired in a fire-sale by Bank of America in 2008.

Having already sold Northern Rock to Virgin Money last year, the key takeaway is the UK government wants nothing to do with running banks.

USA

In the UK, the previous management was replaced.

The US government decided to let the managements that almost bankrupted the firms continue to stay in charge.

In 2008, the US Treasury took share stakes in nine of the nation's biggest financial institutions, including Goldman Sachs, Citigroup and Bank of America.

The Federal Reserve also took control of collapsed insurer AIG.

The government took its stakes through buying preferred stock - meaning they had no voting rights - but the terms of the bailouts included caps on compensation and certain forms of mandatory lending.

The government had no intention to keep its stakes - and the banks were eager to pay of their loans and return to full private ownership, which happened in 2009.

The US on the face of it seems as eager as the UK to keep their hands off the banking system.

But the US has always had a large - if implicit - government role in the banking system through backing home loans.

Fannie Mae was founded in 1938 at a time when millions of families could not become homeowners because of a lack of mortgage funds. It was a government agency until 1968.

Freddie Mac was created in 1970 to provide competition to Fannie Mae.

They buy mortgages from approved lenders and then selling them on to investors.

In 2008, Fannie Mae and Freddie Mac made billions in losses as the US housing market plummeted, received almost $150bn in bailouts and were effectively nationalised.

And so now, the government currently owns or guarantees more than 90% of US mortgages - up from 70% when the market was supposedly stable, private and efficient.

Without the US government, would anyone have the confidence to take out an American mortgage?

Europe

In October 2011, Global Finance magazine put out its annual list of the world's safest banks.

Despite the eurozone debt crisis, the top five were all European. What should that tell us?

Well, they all had some form of "privileged" relationship with their governments.

According to the magazine, for the third year in a row, the safest bank is Germany's KfW.

The state-backed development lender founded in 1948 - even before the founding of the Federal Republic of Germany - is 80%-owned by the federal government and the states own the rest.

It has a five-member board that reports to a 37-member supervisory board - which is formally chaired by the federal economy minister.

The government therefore takes a direct role in running the bank. The bank funds itself through bonds back by the government, which is the richest economy in Europe.

KfW backs export-oriented firms and small businesses, lending at low rates, and deals with the privatisation of German state-owned enterprises.

(Still, no-one is perfect. The Bild newspaper once called KfW "Germany's dumbest bank" over a swap transaction with Lehman Brothers in 2008.)

The next two safest banks according to Global Finance are Caisse des Depots et Consignations - created by French King Louis XVIII in 1816 to manage the pension funds of state employees - and Bank Nederlandse Gemeenten, 50% owned by the state and 50% by the provinces.

All those banks are run in a "hands-on" way by the state.

But they also do not provide explicitly commercial services; they are tasked with specific roles that are deemed to have value beyond gaining profits.

That said, the next safest bank on the list is Zurich Cantonal Bank, which is the largest financial-services provider in the Swiss capital, owned by the canton and answers to the municipal council.

Across Europe, governments routinely set performance targets and compensation packages - all without much of an outcry from anyone.

There is no real acceptance of the very Anglo-Saxon idea that banking services are something that only the private sector does or should do.

China

Whereas China has the biggest publicly-traded bank in the world by market capitalisation, the Industrial and Commercial Bank of China (ICBC).

China is the second-biggest economy in the world, and there is not one aspect of public life that the Communist Party is not involved in.

ICBC is the largest of the 'big four' state-owned commercial banks after the Agricultural Bank, China Construction Bank and the Bank of China.

In the early 1980s, as China liberalised its economy, it created these four banks to oversee the specific parts of its economy that needed funding.

In 2006, ICBC and the others sold shares to the public in Hong Kong and mainland China. And then there are thousands of provincial commercial banks in China.

Still, the banks are under government control. The largest shareholder of these big Chinese banks is the Chinese social security fund, according to Bloomberg data.

Another organ, the State Administration of Foreign Exchange, or SAFE, manages China's $3tn of currency reserves on behalf of the central bank

The chairman of ICBC, Jiang Jianqing, is one of the alternating members of the Central Committee of the Communist Party for example.

And the ICBC is under orders to expand globally. The bank's goal is to more than double the share of profits that comes from outside China in the next five years, from about 3.8% to 10%, he told the Wall Street Journal.

China, of course, is very different from countries in the West. The US has accused China of pursuing "state capitalism", which aims to give its state-owned firms an advantage over foreign companies.

To China's ears, that does not sound like criticism but praise.

The Chinese government sees control of the banking system - including its controversial exchange rate - as crucial to maintaining a growing, stable economy.