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The financial crisis exposed the lack of depth in existing • Increased focus on regulatory supervision, monitoring
liquidity risk measurement and management practices market indicators and information sharing between
of banks and financial institutions across the globe. regulators
As the global financial system emerges from the crisis
• Enhanced public disclosures about liquidity information
with unprecedented levels of liquidity support from
central banks, it has become imperative to strengthen To help Indian Banks understand the key
liquidity management practices. To further this end, the recommendations of the BCBS consultative document
Basel Committee for Banking Supervision (BCBS) has and its potential impact of existing liquidity management
issued a consultative document on the “International practices in India, Ernst & Young has compiled a brief
framework for liquidity risk measurement, standards document which is enclosed herewith for your kind
and monitoring.” The recommendations contained in the perusal. The document provides a perspective on:
consultative document are expected to be finalized by the • Evolution of liquidity risk management
end of 2010 and implemented by 2012.
• Key features of the proposed framework
The key recommendations in the consultative document
include: • Current state of liquidity risk management in India
• Increased use of severe stress scenarios to evaluate • Bridging the gap with the proposed framework
the balance sheet strength • Key challenges for Indian Banks and the approach
• Incorporating liquidity risks, costs and benefits in towards implementing the framework
product pricing and performance measurement We sincerely hope that you find the enclosed document
• Introduction of standard ratios and monitoring tools resourceful. In case you need further information and
insights, please feel free to reach out to us.
• Increased focus on the asset-liability structure and
availability of high-quality liquid assets to cushion
against stressed market conditions
• Comprehensive framework for measuring off-balance Hemal H Shah
sheet and contingent liquidity risks
Partner — Financial Services,
Risk Advisory,
Ernst & Young Pvt. Ltd.
Abbreviations
BCBS Basel Committee for Banking Supervision RSF Required amount of stable funding
SLR Statutory liquidity ratio CBLO Collateralized borrowing and lending obligation
2004
2003
2002
2001
“Sound practices for managing liquidity in
2000 2000 banking organization” published by BCBS;
Circular on ALM systems principles revised in 2008
issued; reporting requirements 1999
1999
prescribed by this circular still
in practice 1998
1997
1996
1995
1994
1993
“Framework for measuring and
1992 1992 managing liquidity” issued by BIS
outlining the broad ALM principles
1991
1990
Increased importance 2
8
and use of severe stress
test scenarios
Requirement to disclose Introduction of the
specific quantitative concept of liquidity risk
information about ALM tolerance in times of
as a part of the public stressed market
disclosures conditions
Increase focus on
Product pricing and
regulatory supervision,
7 Key enhancements over performance measurement 3
monitoring market
the principles issued in 2000 to incorporate liquidity costs,
indicators and information
benefits and risks
sharing between regulators
Increased stress on
Contingency funding plans maintaining high quality
to be made more practical, liquid assets as a cushion in
including the periodic stressed situations
testing of the plans More comprehensive
assessment of
contingent liquidity
risks and off-balance
6 4
sheet items
The BIS principles issued in 2000 focused on the overall structure of liquidity
management and propagated an approach that focused on assessing funding gaps.
The focus of the new principles is mainly on stress testing, standardizing liquidity
measures across banks and most importantly integration of product pricing and
performance measurement with the liquidity risk framework.
20
Supervisors to assess future capital resources and capital needs of a bank
19
12 Stress tests to specifically recognize and address all potential risks from complex products
10 Simultaneous stress testing of the composite impact of liquidity risk and asset valuation
9 Introduction of the concept of reverse stress tests that can affect the viability of the bank
8 Stress tests to focus on forward looking scenarios, i.e., enhanced relevance of dynamic liquidity reports
7 Stress testing to focus on firm-wide risks specifically relating to funding and liquidity gaps
6 Involvement of independent internal audit and risk function in validating stress testing framework
5 Enhanced infrastructure and data quality, i.e., increased focus on data warehousing systems
3 Collaboration expected between traders, business managers, controllers to arrive at stress testing framework
2 Measures are complementary to existing measures and are expected to be filtered to a portfolio level
1 Stress testing to form a part of the governance framework; results expected to impact strategic business decisions
With the increased focus on stress testing, the revised framework has
prescribed detailed principles that are aimed at reducing differences in
methodologies followed to conduct stress testing.
Concentration of funding
Liquidity risk — management Principles for sound liquidity risk Principles for sound stress
and supervisory challenges: management and supervision: testing practices and supervision:
February 2008 September 2008 May 2009
The various principles prescribed by BIS between 2007 and 2009 form the basis for the new framework. The framework
stresses on convergence in the following areas:
• Two standard ratios to measure and monitor the health of a bank’s liquidity. The method for computation of ratios has
been standardized to facilitate comparative analysis between institutions.
• The standard ratios are based on stress scenarios and assess the ability to meet liquidity requirements over a 30 day
horizon and a 1 year horizon
• The new framework also prescribes monitoring tools. These monitoring tools are expected to replace current balance
sheet ratios and maturity gap analysis conducted by banks to assess funding mismatches.
Concentration of funding
Liquidity risk — management Principles for sound liquidity risk Principles for sound stress
and supervisory challenges: management and supervision: testing practices and supervision:
February 2008 September 2008 May 2009
• Banks are required to assess this ratio continuously over • Cash outflows to be assessed based on the run-off on
a 30-day horizon deposits in stressed market conditions; minimum run-off
ratios by category prescribed
• Definition of stock of high quality assets restricted to
those with low credit and market risk, ease of valuation, • Cash outflows to include potential draw on committed
listed on recognized exchange markets, presence of lines and contingent funding liabilities
active market and committed market makers, and low
• Cash inflows to include only contractual flows from
market concentration
completely performing assets; absolute freeze on lines of
• Definition of liquid assets restricted to cash, central bank credit expected in case of stress
reserves, government/central bank issued debt and
corporate bonds with low credit risk and haircuts
The ratio focuses on the ability of a bank to meet its liquidity requirements
in extreme stress scenarios over a 30 day horizon.
Concentration of funding
Liquidity risk — management Principles for sound liquidity risk Principles for sound stress
and supervisory challenges: management and supervision: testing practices and supervision:
February 2008 September 2008 May 2009
(Indian perspective)
Contractual maturity mismatch
Liquidity coverage ratio (LCR)
Concentration of funding
Liquidity risk — management Principles for sound liquidity risk Principles for sound stress
and supervisory challenges: management and supervision: testing practices and supervision:
February 2008 September 2008 May 2009
Detailed
assessment of
Need to revisit the mark-to-market
definition of retail (MTM)/margin cash
and wholesale flows from derivative
deposits within the transactions based
ALM policy on actual term
Assess actual
run-offs based on sheets
behavioral studies
in stress scenarios
Lack of liquid
to determine Subordinated
markets in
run-off ratios stability status to
government
securities means financial
only certain institutions makes
securities may inter-bank funding
qualify for the an unacceptable
Continuous computation of source in case of
Liquidity stress Need to
assessment of liquid funds
coverage ratio: consolidate
liquidity measures
key impact areas liquidity measures
will require
Since contingency from an Indian for banks with a
improved data Lack of deep repo
cash flows are perspective foreign presence
warehousing markets means that
futuristic and dynamic high-quality assets
liquidity reports do not may be restricted to
adequately address cash and securities
contingencies, qualifying for
assessment statutory liquidity
Committed funding
methodology needs ratio (SLR)
lines and undrawn
to be devised
facilities likely to
require increased
Derivative scrutiny to assess Need for
valuations will liquidity impact clarification on
become a key country-risk
input for liquidity impact, while
reporting, making measuring
the need to high-quality liquid
validate derivative assets based on
valuations critical credit ratings
Concentration of funding
Liquidity risk — management Principles for sound liquidity risk Principles for sound stress
and supervisory challenges: management and supervision: testing practices and supervision:
February 2008 September 2008 May 2009
• Banks required to assess this ratio continuously over • Net stable funding ratio (NSFR) is similar to maturity
a 1 year horizon mismatches currently performed for structural liquidity
reports; however, the focus is only on a 1-year time
• Available amount of stable funding arrived at by applying
bucket in aggregate and is based on stress scenarios
ASF factors to liabilities on the balance sheet
• Facilities from central banks except under open market
• Required stable funding arrived at by applying RSF
operations (OMO) are not to be considered in this ratio to
factors to assets in the balance sheet
avoid dependence on central bank funding
• Required stable funding to also cover off-balance sheet
items; certain degree of discretion available to local
country supervisors on RSF factor to be applied
The ratio focuses on the ability of a bank to meet its liquidity requirements in
continued stress conditions over a 1 year period.
Concentration of funding
Liquidity risk — management Principles for sound liquidity risk Principles for sound stress
and supervisory challenges: management and supervision: testing practices and supervision:
February 2008 September 2008 May 2009
Less stable non-maturing retail deposits 70% Unencumbered corporate bonds with AA- to
50%
A- rating and effective maturity > 1 year
Less stable unsecured wholesale funding 70% Loans to non-financial corporate entities with
50%
less than 1 year maturity
Unsecured wholesale funding provided Loans to retail clients with residual maturity
50% 85%
by non-financial corporate customers < 1 year
(Indian perspective)
Contractual maturity mismatch
Liquidity coverage ratio (LCR)
Concentration of funding
Liquidity risk — management Principles for sound liquidity risk Principles for sound stress
and supervisory challenges: management and supervision: testing practices and supervision:
February 2008 September 2008 May 2009
Detailed
assessment of
Need to revisit MTM/margin cash
funding mix flows from
especially to the derivative
extent it relates to transactions based
inter-bank funding on actual term
sheets
Increased focus on
retail/SME funding
Concentration of funding
Liquidity risk — management Principles for sound liquidity risk Principles for sound stress
and supervisory challenges: management and supervision: testing practices and supervision:
February 2008 September 2008 May 2009
Key • Similar to existing • Significant defined • Lack of deep repo • Need for
considerations structural liquidity as more than 1% of markets may supervisors to
report the bank’s total reduce the amount enhance
• Assets to be reported liabilities of encumbered monitoring tools
based on latest • Categorization of assets • Potential need for
possible maturity and counter-parties/ • Securities pledged supervisors to
liabilities based on group companies as collateral for enhance
earliest possible becomes a CBLO/with CCIL monitoring tools
maturity significant may not qualify for and seek reports
• Behavioral consideration this requirement from banks in
assumptions to play • Stress on • Potential increase electronic formats
a large part in instrument in cost of funding • Need to standardize
determining diversification by retaining the market-based
contractual maturity • Rising importance larger value of triggers in the
mismatch of instrument unencumbered absence of deep
classification assets CDS and corporate
guidelines • Valuation may play bond markets
• Separate reporting a key role in this
of the metrics metric in case of
across time corporate bonds
buckets
Computation
Profile of
Indian banks
Incorporating assumptions
Stress testing Contingency funding plans
defined in the standard
• Liquidity mismatches • Time bucket-wise gap analysis • Aligning the asset-liability mix
• Data inputs for LCR and NSFR • Impact of historical patterns on • Operationalizing contingency
• Cash flow forecasts cash flows plans
• Data inputs for monitoring tools • LCR and NSFR computation • Stress testing assumptions and
• Contractual maturity mismatch validation
Migrating seamlessly to the proposed framework will require Indian banks to enhance the following aspects of the asset
liability management framework:
• Data gap analysis: The current framework of preparing ALM statements as prescribed by RBI is based on pre-defined
assumptions for each field of data extracted from core banking and treasury systems. The new framework will require a
re-mapping of all data sources, re-validation and re-computation of all assumptions.
• Data centric mismatch assessment: While the current ALM framework is heavily focused gap analysis, the new
framework will require increased use of behavioural studies and stress testing. The need to collate historical data and
make realistic assumptions is a critical requirement to put in place an effective stress testing framework.
• Updation of the ALM policy: The current policy framework of most Banks focuses on gap limits and balance sheet ratios.
The gap limits and ratios will be required to be re-computed in line with the revised framework. Most importantly, the new
framework puts increased focus on sharpening the stress testing documentation and contingency funding plans.
Link balance sheet items Compute modified duration Assess impact on value of
with market pricing curves of gap for the balance sheet equity based on leverage
Generate the bucket-wise Set the duration gap Stress test economic
cash flows analysis (DGA) limits value of equity
• Market based pricing for all • Quantification of interest rate • Overall profitability impact
assets and liabilities risk for the entire balance sheet assessment
• Quantification of interest rate • Quantification at different • Assess impact on theoretical
risk for each balance sheet item points on the interest rate value of equity
curve • Balance sheet stress testing
In the current liquidity management scenario in India, asset liability management and balance sheet management are
generally treated as separate functions. The new framework requires closer integration between the two functions. It
also requires integration of product pricing and assessment of cost-benefit from liquidity risks. With the introduction of
new framework, fund transfer pricing will become an integral part of the ALM framework.
• Market-based product pricing • Control over NII • Stable hedging program to lock
• Fund transfer pricing process • Strategic alignment of NII in long-term NII
between treasury and business management based on • Funding program aligned with
units product risk-return profile mismatches in structural cash
• Allocation of funds based on flows
risk-return analysis
Once Bank’s have adopted the principles of the new framework, it is likely to smoothen the transition to centralized
NII management. The new framework will also facilitate improved liquidity risk-return analysis.
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