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Basel III: LCR, NSFR, and other liquidity management tools Identifying the warning signs of a liquidity crisis market related monitoring toolsIdentification and Use of Key Risk Indicators Designing Liquidity Stress TestingDesigning Stress ScenariosModeling a Diverse Range of Stresses Indust
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1. TD Bank Financial GroupImplementation of Basel III Liquidity Ratios, Liquidity Stress Testing, and Contingency Funding PlansPresented by Dervish Halil May 11, 2011
2. Basel III: LCR, NSFR, and other liquidity management tools
Identifying the warning signs of a liquidity crisis market related monitoring tools
Identification and Use of Key Risk Indicators
Designing Liquidity Stress Testing
Designing Stress Scenarios
Modeling a Diverse Range of Stresses
Industry best practices and regulatory developments
Timeline of regulatory developments
Best practices for liquidity stress testing and contingency funding planning
Resources, References, and Q&A
To ensure adequate liquidity coverage and sustain ongoing operations and reputation in the event of a funding disruption
For funding planned and committed asset growth and strategic opportunities and acquisitions
With respect to deposit instruments, term, customers, distribution channels and currencies
In debt and securitization markets with a high priority on maintenance of high investment grade credit rating
The market being the regulatory environment, banking industry, and financial markets
To ensure the pricing for all loan and deposit products and/or business activities (both on- and off-balance sheet) incorporates an appropriate charge to cover associated liquidity risk To ensure adequate liquidity coverage and sustain ongoing operations and reputation in the event of a funding disruption
For funding planned and committed asset growth and strategic opportunities and acquisitions
With respect to deposit instruments, term, customers, distribution channels and currencies
In debt and securitization markets with a high priority on maintenance of high investment grade credit rating
The market being the regulatory environment, banking industry, and financial markets
To ensure the pricing for all loan and deposit products and/or business activities (both on- and off-balance sheet) incorporates an appropriate charge to cover associated liquidity risk
3. Basel III: LCR and NSFR The liquidity coverage ratio (LCR) is designed to ensure banks hold sufficient, unencumbered liquid assets in order to cover cash outflows during a 30 day period of severe firm specific and systemic market stress
The net stable funding ratio (NSFR) aims to encourage more medium and long term funding of the assets and activities of banks, and the stress is firm specific over an extended 1 year time horizon
Firms have until 2015 (LCR) and 2018 (NSFR) to report and meet the minimum 100% requirements
4. Basel III: LCR and NSFR Challenges Firm-wide and even subsidiary level reporting may be required
Firms operating in multiple jurisdictions need to ensure local regulatory discretionary elements are appropriately factored into aggregate reporting
Presents interpretation, data consolidation, standardization, and aggregation challenges
Unintended consequences of the implementation of the ratios include, but are not limited to:
The efficiency of financial markets
The availability of financial assets, and the distortion of the demand for these financial assets
The stability of financial institutions
The cost of extending credit to the Canadian and global economy
5. Basel III: Implementation TDs Implementation of reporting
Currently, QIS is being reported using end user computing standards compliant spreadsheet and database tools
Gathering of business requirements necessary for a longer-term, strategic, robust systems-based solution is underway
Systems-based solution should be able to handle evolving reporting templates, regulations, and requirements communicated by the regulators
6. Basel III: Monitoring Tools and Other Best Practices Guidelines In addition to the LCR and NSFR, other Basel III monitoring tools include:
Contractual maturity mismatch
Concentration of funding
Available unencumbered assets
LCR by significant currency
Other market-related monitoring tools
Other best practices include
In addition to the Basel III liquidity standards, the 2008 Principles for Sound Liquidity Risk Management offers best practices guidelines as follows:
Board and senior management oversight
Establishment of policies and risk appetite
Allocating liquidity costs, benefits, and risks to all business activities
Liquidity and enterprise-wide stress scenario testing
Development of robust contingency funding plans
7.
8. Identifying the Warning Signs of a Liquidity Crisis Early Warning Indicators
TD analyzes both qualitative and quantitative early warning indicators relevant to the firms liquidity risk profile
Frequent dashboard review by senior management of indicators, status, outlook, and liquidity impact are used to assess liquidity operating stage
If the outlook of key high impact liquidity risk drivers deteriorates, it may trigger a change in operating stage
In addition, senior management across various disciplines use their expertise and judgment beyond the indicators to initiate discussions on further potential risks
9. Early Warning Indicators
10.
11. Considerations in Designing Stress Scenarios Utilize integrated approach when developing scenario specifications
Leverage subject matter experts across various disciplines, including but not limited to Economics, Credit, Market and Operational Risk, and Finance
Assess cash flow implications related to key liquidity risk drivers
Consider different degrees of severity by varying scenarios duration and impact levels
Consider relationships between risk drivers
Leverage combination of subject matter expert judgement and observed quantitative relationships
Ensure management reviews results
Assess results against established risk appetite and take actions to remediate accordingly
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13. Timeline: Industry Best Practices and Regulatory Guidelines
14. Stress Testing Best Practices Know your business and inherent liquidity risk drivers
Institution complexity and level of exposures should drive stress testing framework and cash flow modeling assumptions
Use a variety of stress scenarios, time horizons and severity levels
Stress testing should be run on a regular basis
As the operating stage becomes more severe, frequency of testing should increase
Conduct regular review of stress testing outcomes to ensure alignment with the established liquidity risk appetite
Any liquidity gaps exceeding risk tolerance merit remedial action
Results should be integrated with the firms contingency funding planning
15. Contingency Funding Planning Best Practices Contingency funding plans provide clarity during deteriorating liquidity conditions
Robust CFPs clarify strategies, roles and responsibilities when total focus should be given to mitigating the firms exposure to potential or realized adverse liquidity conditions
Management should assess the operating stage and execute the applicable remediating actions
Fully integrated with stress testing framework
Know your business and available sources of liquidity
Considers existing sources of liquidity and whether it is sufficient to fund normal operating requirements under stress events
Identifies potential alternative contingent liquidity sources
Considers the firms specific legal, regulatory, and tax related encumbrances to available sources of liquidity
16. Contingency Funding Planning Best Practices Robust CFPs ensure effective communication
Internal and external stakeholders should be considered in the CFP process
Implementation and escalation procedures should be clearly defined
CFPs should be reviewed on a regular basis to ensure relevance to the risks to which the firm is exposed
In addition, simulations of the plan should be enacted to test coordination, decision-making, and operational execution ability
(talk about breaking down silos, geographies, etc.)(talk about breaking down silos, geographies, etc.)
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18. References and publications on Liquidity Risk
19. Questions and Answers