Guidance regarding the completion of the liquidity reporting module:

Transcription

1 Guidance regarding the completion of the liquidity reporting module: Covering the reporting of a subsidiary s liquidity position, including behavioural adjustments, and compliance with Commission limits. Issued September 2007 JFSC.Basel II.M7 Liquidity Guide September

2 CONTENTS SECTION 1 Introduction... 3 SECTION 2 Maturity Ladder... 5 Introduction... 5 Note A All placements with group companies... 5 Note B Marketable investments... 5 Note C All placements with deposit takers... 6 Note D Loans, Overdrafts and Mortgages... 6 Note E Other Assets... 7 Note F FX Transaction Inflows and Outflows... 7 Note G - Facilities... 7 Note H Other inflows/ Other outflows... 7 Note I Deposits from group companies... 7 Note J Deposits from Retail & Corporate / Trust / Fiduciary... 7 Note K Other Liabilities including Capital & Reserves... 8 Note L - Committed Standby facilities provided... 8 Note M Commitments to make loans and advances... 8 Note N Behavioural adjustments re Inflows... 8 Note O Behavioural Adjustments re Outflows... 8 SECTION 3 Monthly Summary and Large Deposit Data... 9 Summary Data... 9 Large Deposit data... 9 JFSC.Basel II.M7 Liquidity Guide September

3 SECTION 1 INTRODUCTION Overview 1.1 Liquidity risk is the risk that a firm is not able to fund increases in assets and meet obligations as they come due. Guidance on this subject is provided by the Basel Committee on Banking Supervision ( BCBS ) in its paper Sound Practices for Managing Liquidity in Banking Organisations. Liquidity risk arises because banks are in the business of maturity transformation; they take in deposits that are often repayable on demand or at short notice and use these deposits to fund credit facilities to borrowers over longer periods. 1.2 The Commission set out in its consultation paper on this subject, issued in November 2006, that it would not seek to generally prescribe methods to manage liquidity but that there is a need to ensure that all Jersey incorporated deposit takers are, and remain, sufficiently liquid. This will be achieved through requiring compliance with minimum standards for liquidity risk management. Changes to the reporting of liquidity risk to the Commission were set out within that consultation paper, and are enacted within this module. 1.3 The purpose of the Liquidity Module is to assess a reporting bank s management of liquidity risk. The Commission will consider its contents to be a key indicator of the deposit taker s financial wellbeing. 1.4 The Commission s risk management requirements are a minimum and are not intended to replace or represent an entity s liquidity management policy ( LMP ). The Codes of Practice for Deposit-taking refer entities to the BCBS paper for guidance. The Commission has provided additional guidance in its guidance note Liquidity Management and Reporting, issued in May The Commission requires that all Jersey incorporated banks abide by standard mismatch limits for time periods out to one month from 1/1/2008. During the period before this, banks may approach the Commission to agree appropriate and prudent behavioural adjustments to reflect the actual liquidity risk they face. This will allow the Commission to assess liquidity risk for all banks using a consistent basis for mismatch limits whilst also recognising the unique behavioural aspects of their individual customer bases. Behavioural adjustments 1.6 Setting behavioural adjustments enables allowance to be made for the fact that some assets/liabilities may behave differently to their contractual terms. A key example is notice deposits where customers may be able to access funds without notice by paying a penalty. The penalty may affect the behaviour of customers in normal circumstances but it does not inhibit the contractual ability of customers to access their funds. JFSC.Basel II.M7 Liquidity Guide September

4 1.7 Further guidance addressing this issue is contained in the Commission s guidance note Liquidity Management and Reporting. Cumulative Mismatch Limits: 1.8 The appropriate classification of liquid assets, coupled with establishing behavioural adjustments, enables a bank to accurately demonstrate its liquidity risk profile. 1.9 For all Jersey incorporated subsidiaries, uniform maximum mismatch limits for [sight to < 8 days] of 0% and [sight to < 1 month] of -5% have been established on this basis. Banks Internal Reporting 1.10 Each Jersey incorporated deposit taker will be required to monitor its liquidity daily, based on the stated methodology. This requirement must be incorporated within each entity s LMP. Daily monitoring is considered necessary because liquidity risk is one of the key prudential risks affecting deposit-taking institutions and liquidity positions can vary significantly on a daily basis All Jersey incorporated deposit takers will be required to calculate a daily liquidity requirement using this methodology and immediately report to the Commission instances where any limit is exceeded, with an explanation of the cause. Any breaches must be remedied promptly and action taken to prevent future similar breaches. JFSC.Basel II.M7 Liquidity Guide September

5 SECTION 2 MATURITY LADDER IN THE PRUDENTIAL RETURN Introduction 2.1 Generally, assets and liabilities should be reported on a residual maturity basis except where explicitly stated. The reporting bank should also report interest accrued according to when it is due to be paid/received and other expected cash flows such as dividend payments and settlement of fixed asset purchases. All cash inflows and outflows arising from foreign exchange contracts should be reported gross in lines A.10 and B.10 (see note F). 2.2 A note explaining any key assumptions made in completing the form and the scope for significant potential variances should also be provided; accompanying the other prudential reporting paperwork. 2.3 Assets and liabilities are recorded on a maturity ladder and a mismatch position is calculated for each time bucket, and cumulatively across time buckets. A worst-case basis is used to determine the timing of cashflows, with assets being recorded at the latest potential maturity and liabilities at the earliest. Liquid instruments such as government securities, certificates of deposit ( CDs ), commercial paper (CP), and short dated floating rate notes (FRNs), should be classified according to their marketability, in accordance with note B. 2.4 During a period of strained liquidity, a bank s ongoing ability to execute certain foreign exchange transactions may be severely curtailed and the Commission may also require the completion of additional returns for individual currencies held. All returns should be completed in sterling equivalent. Note A All placements with group companies 2.5 All deposits placed with, and CDs or similar instruments issued by, group entities should be classified according to their contractual maturity date. No adjustment should be made for the marketability of these. Note B Marketable investments 2.6 These may be either debt or equity in nature. Non-marketable investments should be shown in line A.9 Other Assets (see Note E). 2.7 An asset should only be considered as marketable if it fulfils the following criteria: Prices are regularly quoted for the asset; The asset is regularly traded; The asset is readily sold, including by repo, either on an exchange, or in a deep and liquid market for payment in cash; and JFSC.Basel II.M7 Liquidity Guide September

6 Settlement is made according to a prescribed timetable, rather than being subject to negotiation. 2.8 The prescribed timetable dictates whether the Asset is classified as sight, [2 days to < 8 days] or [8 days to < 1 month]. 2.9 A discount should be applied to the market value of an asset before inclusion. The absence of a market value would in all cases preclude an asset being considered marketable. The valuations should be less than 1 month old. The discounts to be used are: Less than 1 year 1 year to less than 5 years 5 years and over Zone A: Sovereign debt, Bank CDs, Local Authority debt 0% 5% 10% Zone A: Other Debt Securities 5% 10% 15% Zone A: Main Index equities 20% All Zone B 40% 2.10 The definitions of Zone A and B are given within the Schedule to the Codes of Practice for Deposit-taking Business. Should there be any doubt as to the correct discount, the deposit taker should contact the Commission for clarification All marketable equity positions should be shown on line A.5. Marketable debt should be split by type across lines A.2 to A.5. Note C All placements with deposit takers 2.12 These should be classified according to the latest contractual maturity date. Any embedded repayment options should be considered only where the bank has the sole right of exercise. Balances on call or demand should be classified as sight. Note D Loans, Overdrafts and Mortgages 2.13 These should be classified according to the latest contractual maturity date. Mortgages secured on residential property are to be shown separately, in line A.8, from all other loans and advances, in line A.7. JFSC.Basel II.M7 Liquidity Guide September

7 Note E Other Assets 2.14 This includes non-marketable debt or equity investments - those that do not qualify for classification under the terms of note B. Non-marketable equity investments would include investments in unlisted companies and should be shown in the 5 years & over incl undated column whilst non-marketable debt investments should be classified according to the latest contractual maturity date. Any embedded repayment options should be considered only where the bank has the sole right of exercise Other assets will include fixed assets, other debtors and accrued interest receivable and these should be classified according to the latest contractual due date or as undated. For example, fixed assets would normally be considered undated and shown at balance sheet value in the 5 years & over including undated column. Note F FX Transaction Inflows and Outflows 2.16 Report cash flows on a gross basis in all cases. Cash flows should include all unsettled amounts classified by settlement date, with inflows on line A.10 and outflows on line B.10. Note G - Facilities 2.17 Report undrawn amounts where the facility is legally committed. Facilities provided by group companies should be shown in line A.11, and might, for example, include liquidity facilities made available by the reporting bank s group treasury. All other facilities should be shown in line A.12. Note H Other inflows / Other outflows 2.18 Include all other known inflows/outflows that are legally committed. Note I Deposits from group companies 2.19 Include all deposits received from group companies according to their earliest potential maturity. Note J Deposits from Retail & Corporate / Trust / Fiduciary 2.20 For the purpose of this schedule, Retail is defined as accounts in the names of individuals. Notice deposits that allow immediate withdrawal with interest penalties should be classified as sight deposits. Retail amounts are to be shown in lines B.2 & B.3, whilst Corporate / Trust / Fiduciary amounts are to be shown JFSC.Basel II.M7 Liquidity Guide September

8 in lines B.4 & B.5. For both of these categories, demand & notice deposits are shown in the first line, with fixed term deposits on the second line. Note K Other Liabilities including Capital & Reserves 2.21 These should be classified according to the latest contractual due date. Capital & Reserves should be shown separately, in line B.8, from other liabilities, which should be shown in line B.9. Many capital and reserve items will be undated, for example share capital, and should be shown in the 5 years & over incl unrated column. The main exception to this would be subordinated debt, which should be classified according to its final maturity. Note L - Committed Standby facilities provided 2.22 Report undrawn facilities provided to third parties where the facility is irrevocably committed. Note M Commitments to make loans and advances 2.23 Report undrawn amounts where the loan is legally committed. Note N Behavioural adjustments re Inflows 2.24 Report a behavioural adjustment (that has been agreed with the Commission) as a deduction from the contractual time bucket and an addition to the time bucket agreed for the behavioural adjustment. Note O Behavioural Adjustments re Outflows 2.25 Report behavioural adjustments agreed with the Commission as above. JFSC.Basel II.M7 Liquidity Guide September

9 SECTION 3 MONTHLY SUMMARY AND LARGE DEPOSIT DATA Summary Data 3.1 The purpose of the summary data is to give an overview of the daily figures reported internally (in compliance with the Commission s daily liquidity reporting requirements). Summary data for both the one week and one month limits should be reported for the previous quarter as follows: The Average figure should be the mean across each daily report for a working day falling within the period commencing the day after the last prudential reporting date and ending with the current prudential reporting date; and The Lowest figure should be the least positive if all daily reports give positive figures, or the most negative figure given by any of those daily reports. 3.2 Enter each figure as an integer number of percentiles, rounding to the nearest percentile e.g. enter 5 where the value is between 4.5% and % inclusive. Large Deposit data 3.3 Report both the ten largest depositors that are banks and the ten largest other depositors, these already having been aggregated by beneficial owner. 3.4 Identifiers may be used, rather than disclosing the identity of the beneficial owner, but only if: Identifiers are used consistently between consecutive returns; and A list setting out the beneficial owner relating to each identifier used is available to the Commission upon request. JFSC.Basel II.M7 Liquidity Guide September