Current Issues in Liquidity Risk

Similar documents
COMMUNIQUE. Page 1 of 13

LIQUIDITY RISK MANAGEMENT: GETTING THERE

FSC Newsletter. Liquidity Risk Management. Number 3 Year Background

REGULATORY GUIDELINE Liquidity Risk Management Principles TABLE OF CONTENTS. I. Introduction II. Purpose and Scope III. Principles...

Guidance on Liquidity Risk Management

Guidance on Liquidity Risk Management

Demystifying the New Liquidity Requirements

Guidelines. No. 2/2010. Guidelines for Sound Liquidity Risk Management and Supervision

Prudential sourcebook for Banks, Building Societies and Investment Firms. Chapter 12. Liquidity standards

Prudential sourcebook for Banks, Building Societies and Investment Firms. Chapter 12. Liquidity standards

Basics of Liquidity Risk Management For Community Financial Institutions under $3 Billion in Assets

RESERVE BANK OF MALAWI

Index. Managing Risks in Commercial and Retail Banking By Amalendu Ghosh Copyright 2012 John Wiley & Sons Singapore Pte. Ltd.

SECOND PART OF CEBS STECHNICAL ADVICE TO THE EUROPEAN COMMISSION ON LIQUIDITY RISK MANAGEMENT

Guidance Note: Internal Capital Adequacy Assessment Process (ICAAP) Credit Unions with Total Assets Greater than $1 Billion.

Implementing the new liquidity risk management frameworks the lessons learned

Community Trust Company Basel III Pillar 3 Disclosures June 30, 2018

Basel Committee on Banking Supervision. Liquidity coverage ratio disclosure standards

CANADIAN BANKERS ASSOCIATION

GUIDELINES FOR THE INTERNAL CAPITAL ADEQUACY ASSESSMENT PROCESS FOR LICENSEES

Pillar 3 Disclosure Statement

Amex Bank of Canada. Basel III Pillar III Disclosures December 31, AXP Internal Page 1 of 15

Draft for Consultation FICOM ICAAP Guide

ECB Guide to the internal liquidity adequacy assessment process (ILAAP)

Community Trust Company Basel III Pillar 3 Disclosures December 31, 2017

Guidance Note: Stress Testing Credit Unions with Assets Greater than $500 million. May Ce document est également disponible en français.

STRESS TESTING GUIDELINE

INTERNATIONAL ASSOCIATION OF INSURANCE SUPERVISORS

BERMUDA MONETARY AUTHORITY BANKS AND DEPOSIT COMPANIES ACT 1999: PRINCIPLES FOR SOUND LIQUIDITY RISK MANAGEMENT AND SUPERVISION

Finalised guidance. Individual Liquidity Systems Assessment (ILSA) Simplified ILAS BIPRU Firms (ILSA) Simplified ILAS BIPRU Firms.

Liquidity Risk Management. Thomas Schmale, Solution Management Analytical Banking, SAP AG, 29 th May 2014

Risk Concentrations Principles

INTERNATIONAL ASSOCIATION OF INSURANCE SUPERVISORS

Consolidated Citigroup U.S. Liquidity Coverage Ratio Disclosure. For the quarterly period ended December 31, 2018

INTERNATIONAL ASSOCIATION OF INSURANCE SUPERVISORS

Sainsbury s Bank plc. Pillar 3 Disclosures for the year ended 31 December 2008

Appendix 3 In this appendix underlining indicates proposed new text and striking through indicates deleted text. The DFSA Rulebook

Operational risk and corporate governance

Regulatory Impact Assessment RBNZ Liquidity requirements for locally incorporated banks

1.0 Purpose. Financial Services Commission of Ontario Commission des services financiers de l Ontario. Investment Guidance Notes

Community Trust Company Basel III Pillar 3 Disclosures March 31, 2017

BOARD OF GOVERNORS FEDERAL RESERVE SYSTEM

Aldermore Bank Plc. Pillar 3 Disclosures

Guidance on Liquidity Risk Management DECEMBER CONSULTATION

Report on Internal Control

Liquidity Basics Measuring and Managing Liquidity

BERMUDA MONETARY AUTHORITY GUIDELINES ON STRESS TESTING FOR THE BERMUDA BANKING SECTOR

Consolidated Citigroup U.S. Liquidity Coverage Ratio Disclosure. For the quarterly period ended June 30, 2018

LIQUIDITY RISK MANAGEMENT MODULE

The Basel Core Principles for Effective Banking Supervision & The Basel Capital Accords

Linking: Liquidity Risk & Credit Portfolio Management

Consolidated Citigroup U.S. Liquidity Coverage Ratio Disclosure. For the quarterly period ended September 30, 2017

INTERNAL CAPITAL ADEQUACY ASSESSMENT PROCESS MODULE

Overview of ERM Assessment Viewpoints (June 2016) Overview

Advisory Guidelines of the Financial Supervision Authority. Requirements to the internal capital adequacy assessment process

Consolidated Citigroup U.S. Liquidity Coverage Ratio Disclosure. For the quarterly period ended December 31, 2017

Liquidity Coverage Ratio Disclosures Report. For the Quarterly Period Ended September 30, 2017

TABLE 2: CAPITAL STRUCTURE - December 31, 2015

Consolidated Citigroup U.S. Liquidity Coverage Ratio Disclosure. For the quarterly period ended March 31, 2018

Guideline. No: B-6 Date: February 2012

MODEL CONTINGENCY FUNDING PLAN (for MHSI ALMPro Clients)

NAIC OWN RISK AND SOLVENCY ASSESSMENT (ORSA) GUIDANCE MANUAL

GUIDELINE ON ENTERPRISE RISK MANAGEMENT

4. This letter sets out our key regulatory priorities for 2017 for insurance companies and covers the following areas:

Meridian Finance & Investment Limited Disclosure under Pillar III on Capital Adequacy and Market Discipline As on December 31, 2017

Criteria Insurance General: Refined Methodology For Assessing An Insurer's Risk Appetite. Table Of Contents

Prudential issues seminar

Standard Chartered Bank UAE Branches

Enterprise Risk Management

Basel Committee on Banking Supervision. Consultative Document. Pillar 2 (Supervisory Review Process)

Pillar 2 - Supervisory Review Process

In various tables, use of - indicates not meaningful or not applicable.

Auditing Liquidity Risk. An Overview

Kenya Gazette Supplement No. 42 3rd April, (Legislative Supplement No. 19)

Capital Adequacy and Supervisory Assessment of Solvency Position

Recent Developments in the Austrian Banking System s Liquidity Situation and the International Regulatory Debate

ICAAP Report Q3 2015

Pillar III report 2017

Liquidity Coverage Ratio Disclosure. Bank AlBilad Liquidity Coverage Ratio Disclosure Dec 31, 2015

Thank you for giving us the opportunity to express our views regarding the recent consultation paper on Liquidity Buffers and Survival Periods (CP28).

Working through Risk Appetite

CAPITAL MANAGEMENT GUIDELINE

Excess liquidity can restrict NorthPark s profitability and have an adverse effect on its capital position.

PILLAR 3 DISCLOSURES MERCER UK AUGUST 2016

Capital Management 4Q Saxo Bank A/S Saxo Bank Group

ZAG BANK BASEL PILLAR 3 AND OTHER REGULATORY DISCLOSURES. December 31, 2017

Committee on Payments and Market Infrastructures. Board of the International Organization of Securities Commissions

INTERNATIONAL ASSOCIATION OF INSURANCE SUPERVISORS

Advanced Asset/Liability Management

Prudential Standard GOI 3 Risk Management and Internal Controls for Insurers

Liquidity Basics Measuring and Managing Liquidity. Course Agenda

INTERNAL CAPITAL ADEQUACY ASSESSMENT PROCESS GUIDELINE. Nepal Rastra Bank Bank Supervision Department. August 2012 (updated July 2013)

President s Choice Bank

ICAAP Q Saxo Bank A/S Saxo Bank Group

President s Choice Bank

Consultation paper on CEBS s Guidelines on Liquidity Cost Benefit Allocation

CANADIAN TIRE BANK. BASEL III PILLAR 3 DISCLOSURES As at December 31, 2016 (unaudited)

Analysis of FSA Regulation

Intra-Group Transactions and Exposures Principles

Supervisory Lessons Learned

Transcription:

Current Issues in Liquidity Risk Leonard Matz May, 2009 sitemap www.sungard.com

Copyright Notice Large portions of this presentation are copyrighted by my publishers, John Wiley and Sons and Sheshunoff Information Services, Inc. No part may be reproduced in any form or incorporated in any information retrieval system without prior written permission from the copyright owner. www.sungard.com

BRANDING AGENDA

1. New regulations and regulatory guidance: BIS Committee on Banking Supervision Council of European Bank Supervisors FSA (UK) 2. Lessons learned from the 2007-2009 crises 3. Liquidity FTP 4. Scenarios 5. Stress tests 6. Best practice reports.

BIS Principles for Sound Liquidity Mgmt in a Nutshell Cash/Intraday Management Continuous Control & Review of Liquidity Position Multi-Entity & Multi Currency (Principle 6) Intraday Control (Principle 8) Cash/Intraday Management Continuous Control & Review of Liquidity Position Multi-Entity & Multi Currency (Principle 6) Intraday Control (Principle 8) Cash Flow Projection Stress Tests Funding Strategy Liquidity Pricing Liquidity Risk Tolerance Principle 5 Bank Specific/Systemic Events (Principle 10) Testing of Funding Plans Contingency Funding Plan (Principle 11) Funding Diversification/Monitoring (Principle 7) Principle 4 Principles 2 and 3

The FSA Requirements in a Nutshell Systems and Controls Requirements ILAS Groups Reports Strategic Tactical Operative Cash/Intraday Management Collateral Management Cash Flow Projection Scenario Generation Funding Transfer Pricing Liquidity Risk Tolerance Intra-day Liquidity Risk Management Management of Collateral Positions Stress Testing Contingency Funding Plans Pricing Liquidity Risk Governing Body & Senior Management Oversight Diversification Market Access Individual Liquidity Adequacy Standards Group Wide Management Legal Entities Business Lines, Currencies Reporting Weekly/Daily

BRANDING LESSONS FROM THE 2007-2009 CRISIS

Liquidity Lessons from the Sub-Prime Crisis Rigorous monitoring, real-time liquidity controls, and cash-flow projections must be imposed and should have minimum standards. Retrospective and concurrent measures of liquidity (e.g., loanto-deposit ratio, funding ratio) have little value, while prospective views including off-balance-sheet exposures and instability scenarios of deposits are critical. Going-concern analyses are useless, while scenario-based stress analyses linked to contingency planning must be mandatory. Forward-looking risk mitigation measures such as collateral management for contingencies, contingency funding planning, and funding diversification must become the norm. Peter Neu and Philippe Morel, All Dried Up: The Impact of the Subprime Crisis on Liquidity Risk Management, BCG Discussion Paper, 25 April 2008, page 2.

Liquidity Lessons from the Sub-Prime Crisis As liquidity risk is a consequence of other risks, it is of the utmost important that stress scenarios consider interactions between market, credit, and operational risks, and that they include contagion and P&L effects. Peter Neu and Philippe Morel, All Dried Up: The Impact of the Subprime Crisis on Liquidity Risk Management, BCG Discussion Paper, 25 April 2008, page 3.

Liquidity Lessons from the Sub-Prime Crisis In the unlikely event of a funding crisis, good contingency planning can make the difference between being in control or being at the mercy of forces that can lead a bank on a downward spiral. Peter Neu and Philippe Morel, All Dried Up: The Impact of the Subprime Crisis on Liquidity Risk Management, BCG Discussion Paper, 25 April 2008, page 4.

BRANDING LIQUIDITY FTP

BIS Guidance for Liquidity Risk CBA Principle 4: A bank should incorporate liquidity costs, benefits and risks in the product pricing, performance measurement and new product approval process for all significant business activities (both on- and off-balance sheet), thereby aligning the risk-taking incentives of individual business lines with the liquidity risk exposures their activities create for the bank as a whole. Principles for Sound Liquidity Risk Management and Supervision, Basel Committee on Banking Supervision, September 2008.

BIS Guidance for Liquidity Risk CBA Institutions should have in place an adequate internal liquidity cost/ benefit allocation mechanism supported where appropriate by a transfer pricing mechanism which provides appropriate incentives regarding the contribution of liquidity risk of the different business activities. This mechanism should incorporate all costs of liquidity (from short to long term, including contingent risk). SECOND PART OF CEBS STECHNICAL ADVICE TO THE EUROPEAN COMMISSION ON LIQUIDITY RISK MANAGEMENT, CEBS, June 17, 2008, page 8.

FSA - Quantification and pricing of liquidity risk 3.26 we are of the view that many firms failed to incorporate pricing for either asset price liquidity or funding liquidity into their processes, with the result that the risk taking incentives of individual business lines were misaligned with the liquidity risk to which the firm as a whole was exposed as a result of its activities. 3.27 We therefore put forward an evidential provision for firms accurately to quantify the liquidity costs, benefits and risks in relation to all significant business activities whether or not they are accounted for on-balance sheet and to incorporate them in their (i) product pricing; (ii) performance measurement; and (iii) approval process for new products. The quantification of costs, benefits and risks should include consideration of how liquidity would be affected under stressed conditions. 3.28 We will expect firms to ensure that those costs, benefits and risks identified are explicitly and clearly attributed to business lines and are understood by business line management. Consultation Paper 8/22, Financial Services Authority, December 2008, page 23.

BRANDING SCENARIOS

FSA - Quantification and pricing of liquidity risk 1. Principle 10: A bank should conduct stress tests on a regular basis for a variety of short-term and protracted institution-specific and marketwide stress scenario (individually and in combination). 2. Principal 10, Paragraph 95: Stress tests should enable a bank to analyse the impact of stress scenarios on its consolidated group-wide liquidity position as well as on the liquidity position of individual entities and business lines. 3. Principal 10, Paragraph 99: A bank should consider short-term and protracted, as well as institution-specific and market-wide, stress scenarios in its stress tests, including: a simultaneous drying up of market liquidity in several previously highly liquid markets; severe constraints in accessing secured and unsecured funding; restrictions on currency convertibility; and severe operational or settlement disruptions affecting one or more payment or settlement systems. Principles for Sound Liquidity Risk Management and Supervision, Basel Committee on Banking Supervision, September 2008.

Systemic Crises Expect the Unexpected 1990 1991 1992 1992 1994 1995 1997 1998 1999 2000 2001 2002 2002 2004 2007-8 Collapse of U.S. high yield (junk) bond market Oil price surge (first Gulf war) ERM (European Exchange Rate Mechanism) crisis U.K. Small Banks Crisis U.S. bond market crash Mexican Crisis Asian crisis Russian default, Ruble collapse. LTCM bailout gold prices TMT (telecommunications, media & technology ) sector collapse September 11 payments system disruption Argentine crisis government default German banking crisis Russian banking crisis U.S. subprime mortgage collapse, oil price surge, U.S. investment banking collapse

Bank Specific Crisis Wide Variety until 2007 www.sungard.com

Cyclical Stress Differences in Duration, Differences in Severity US Economy Recessions Since WW II

BRANDING STRESS TESTS

Evaluation of the Standby Liquidity Reserve Bank Specific Scenario at Stress Level 2

Liability Stickiness FORGET CORE DEPOSITS Inconsistent definitions Binary concept THE FOCUS IS ON STICKINESS a continuum

Characteristics of Sticky or Volatile Liabilities

Sensitivity of Funds Providers By Type Amount Percent Very sensitive to perceived deterioration in credit quality or safety Money market mutual funds Rating sensitive providers Pension funds Insurance companies Broker / dealers Minimize These Regional and money center banks in your country Foreign banks Large corporations Community banks in your market area Diversify These Only sensitive to credit quality and liquidity when problems are very bad and highly publicized Local, uninsured, unsecured depositors Customers who are net borrowers (their loan balances exceed their deposit balances) Local, secured funds providers Insured depositors Maximize These

Example definitions of liquidity buffer: What can we sell? Capital Markets Flight to Quality Fraud / embezzlement loss MILD MODERATE SEVERE MILD MODERATE SEVERE US government bills, notes, bonds US government guaranteed Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Non-MBS US GSE Yes Yes Maybe Yes Yes Yes A1 / P1 CP MBS Maybe Not likely No Yes Yes Yes AAA Corp Maybe No No Yes Yes Yes AAA muni Doubtful No No Yes Yes Yes

BRANDING CONNECTING STRESS TESTS AND CONTINGENCY PLANNING

Stress Levels Problems Unfold Over Time Amount of Available Funds Green: Ordinary Course of Business Yellow: No current funding problems but a heightned level of risk. Orange: Reduction of Confidence and some funding problems. No access to new unsecrued funds. Limited or no access to new secured funds. Red: Serious funding problems. Too late to enhance liquidity.

Excerpt From a KRI Report

e.g. quantitative EWS report Funding differential between Fortis and Peers moving in opposite directions for more than 1 period AND differential larger than 3 bps..

Applying Stress Testing Stress testing is not an end unto itself. Results have to be used in the risk management process. Results should be carefully considered when setting risk limits. Contingency plans for actions such as asset liquidations should be based on stress test results.

Connecting the CFP and Stress Testing Notably, CFPs are generally linked to stress testing scenarios. In cases where a firm has more than one stress test, it is not uncommon to see variations tailored to each scenario to highlight the proposed actions for accessing liquidity in the scenario. The management of liquidity risk in financial groups, (Survey of 40 large, complex financial groups) The Joint Forum," Basel Committee on Banking Supervision, International Association of Securities Commissions, International Association of Insurance Supervisors, page 13, May 2006

BRANDING BEST PRACTICE REPORTING

Survival Horizon Summary Sample Report Normal Operations STRESS LEVEL SURVIVAL HORIZON USING ONLY THE CBC THAT IS APPROPRIATE FOR THE SCENARIO AND STRESS LEVEL - SEE GRIDS STRESS TEST FORECAST RESULT REQUIRED MINIMUM (POLICY LIMIT) OBSERVATION MINIMUM OR SOFT LIMIT - TRIGGERS ALCO DISCUSSION * 14 months 12 months none Bank Specific Fraud loss Mild 11 months 12 months None Moderate 7 months None 9 months Severe 2 months None 6 months Systemic Global recession Mild Moderate Severe * DOES NOT NECESSARILY TRIGGER THE CFP. First purpose of ALCO evaluation is to evaluate why hard or soft limit was breached. Identify weaknesses that may be fixed. Second purpose of ALCO evaluation is to evaluate the sufficiency of the liquidity reserve. Third purpose is to evaluate and potentially increase the remedial actions listed in the CFP. Fourth purpose is to recommend changes in balance sheet 33 structure to reduce MCO if previous steps are insufficient.

Diversification of Funding Sources Should this bank reduce retail deposits and increase fiduciary deposits to improve diversification?

Volatility Liability Dependence 300,000 60% 250,000 50% 200,000 40% 150,000 30% 100,000 20% 50,000 10% 0 1 2 3 4 5 6 7 8 9 10 11 12 CDs > $100K MMDAs > $100K Other DDAs > $100K Savings > $100K 0% TOTAL DEPOSITS > $100K RATIO Net Federal Funds Purchased (if applicable) LIMIT

Example Maturity Concentration Report Option Profits Amount Days 3 6