Basel Intraday Liquidity Framework

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1 Basel Committee Publishes Final Document on Monitoring Tools for Intraday Liquidity Management SUMMARY The Basel Committee on Banking Supervision (the Basel Committee ), in consultation with the Committee on Payment and Settlement Systems, recently published a final document concerning supervisory monitoring tools for intraday liquidity management (the Intraday Liquidity Document ). 1 The Intraday Liquidity Document complements the Basel Committee s overall liquidity risk management framework 2 by setting forth a new set of metrics (or monitoring tools ) intended to enable national supervisors to monitor banks intraday liquidity risk and ability to meet payment and settlement obligations on a timely basis under both normal and stressed conditions. The tools are also intended to benefit authorities responsible for the oversight of payment and settlement systems. The Intraday Liquidity Document s prescribed framework includes: detailed design and reporting items for each of the intraday liquidity monitoring tools, which are intended to provide information to identify and monitor reporting banks intraday liquidity risk under normal conditions; and planning for stress scenarios, which would require reporting banks to assess potential adverse impacts of certain stress conditions and discuss responses to such impacts with their respective supervisors. The document also addresses other monitoring and reporting matters, which arise from differences within and among banking organizations with regard to systems, currencies, organizational structures and jurisdictions of operation. The framework contemplates monthly reporting by banks commencing on January 1, 2015 (to coincide with the Basel Committee s implementation timeline for the Liquidity Coverage Ratio under Basel III). New York Washington, D.C. Los Angeles Palo Alto London Paris Frankfurt Tokyo Hong Kong Beijing Melbourne Sydney

2 This intraday liquidity framework was initially proposed in a consultative document issued by the Basel Committee in July 2012 (the Consultative Document ). 3 Reflecting comments received in response to the Consultative Document, the Intraday Liquidity Document makes several noteworthy changes and clarifications to the initial proposal, including: 4 The scope of application of the regime has been further clarified. One of the monitoring tools in the initial proposal (addressing settlement timing of intraday payments) has been removed, and the data reporting requirements for several of the other monitoring tools have been changed and, in a number of cases, reduced. The requirement to report the likely impact of stress scenarios on a routine basis has been removed. Like all Basel Committee pronouncements, national supervisors would have to implement the Intraday Liquidity Document in their respective jurisdictions. The U.S. federal banking agencies have not yet addressed whether, or to what extent, U.S. banking organizations will be subject to the intraday liquidity framework. MONITORING TOOLS FOR INTRADAY LIQUIDITY MANAGEMENT I. Applicability The Intraday Liquidity Document clarifies that only internationally active banks would be required to apply the monitoring tools, but national supervisors in their discretion may choose to apply the monitoring tools to other banks within their jurisdictions. As in the initial proposal, the monitoring tools would apply both to (i) banks ( direct participants ) that participate in payment and settlement systems, 5 such as large-value payment systems ( LVPS ) and non-lvps ( ancillary ) systems, without using an intermediary and (ii) banks that use the services of direct participants (serving as correspondent banks ) to perform particular settlements on their behalf. II. Design and Reporting Items A bank s intraday liquidity, meaning funds which can be accessed during the business day, usually to enable banks to make payments in real time, carries the associated risk of the bank failing to meet a payment obligation at the time expected, thereby affecting its own liquidity position and that of other parties. 6 The Intraday Liquidity Document sets out seven monitoring tools that together are intended to provide national supervisors with sufficient information to identify and monitor banks intraday liquidity risk under normal (that is, not stressed) conditions. Each monitoring tool has been classified into one of three categories of applicability: (A) all reporting banks, (B) reporting banks that provide correspondent banking services and (C) reporting banks that are direct participants. The monitoring tools for each category are described below, along with such tools data reporting requirements and, where applicable, noteworthy differences from the initial proposal. -2-

3 With respect to reporting specifically, the Consultative Document generally would have required banks to report a standard set of measures for a monitoring tool in each reporting period, comprised of the average, the minimum, the maximum and a percentile figure (either 5 th or 95 th percentile, depending on the tool). The Intraday Liquidity Document replaces this set of measures in favor of the average and the three highest (or lowest, depending on the tool) daily results during the reporting period. Category A: Monitoring Tools for All Reporting Banks (i) (ii) (iii) (iv) Daily maximum intraday liquidity usage: Under the Intraday Liquidity Document, banks would be required to monitor the net balance of all payments made and received during the day over their settlement account (if a direct participant) or account(s) held with a correspondent bank(s). If a bank runs a negative net position on its settlement or correspondent account(s) at some point intraday, it would need access to intraday liquidity to fund this balance; accordingly, the largest net negative position during the business day would determine a bank s maximum daily intraday liquidity usage. Banks would report (a) the three largest daily negative net cumulative positions and three largest positive net cumulative positions on their account(s) in the reporting period and (b) the daily average of the negative net cumulative positions and of the positive net cumulative positions over the reporting period. Available intraday liquidity at the start of the business day: To monitor the intraday liquidity available at the start of each business day, banks would report both (a) the three smallest sums by value of intraday liquidity available at the start of a business day in the reporting period and (b) the average amount of available intraday liquidity at the start of each business day in the reporting period. The final design of this metric narrows the scope of the initial proposal, which also applied the tool to track liquidity throughout the business day, rather than only at the start. Under both the proposed and final guidance, however, banks would be required to break down the constituent elements of the sources of liquidity available to them. 7 Total payments: To track the overall scale of a bank s payment activity, this metric would require that, for each business day in a reporting period, banks calculate the total of their gross payments sent and received in the LVPS and/or across any account(s) held with a correspondent bank(s). Banks would report the three largest daily values for gross payments sent and received in the reporting period and the average daily figure of gross payments made and received in the reporting period. Time-specific obligations: Aimed at improving understanding of banks time-specific obligations (that is, those which must be settled at specific times within the day), this tool would require banks to compute the total value of such obligations that they settle each day and report the three largest daily total values and the average daily total value in the reporting period. The Intraday Liquidity Document narrows the scope of the reporting requirement that was initially proposed, which would have included reporting on failed (in addition to total) time-specific obligations and reporting the volume (in addition to value) for both failed and total time-specific obligations. Category B: Monitoring Tools for Reporting Banks that Provide Correspondent Banking Services (i) Value of payments made on behalf of correspondent banking customers: To improve supervisors understanding of the proportion of a correspondent bank s payment flows that arise from its provision of correspondent banking services, correspondent banks would calculate the total value of payments they make on behalf of all customers of their correspondent banking services each day and report the three largest daily total values and the daily average total value of these payments in the reporting period. 8 The final requirements for this metric omit an additional reporting item found in the initial proposal, which would have required the value of payments settled on behalf of each of the reporter s five largest financial institution customers. (ii) Intraday credit lines extended to customers: Under this monitoring tool, correspondent banks would report the three largest intraday credit lines extended to their customers in the reporting period, including whether these lines are secured or committed and the extent of those lines at -3-

4 peak usage. As with the previous tool, the final requirements for this tool omitted an additional reporting burden, which included a set of measures for credit extended to each of a bank s five largest financial institution customers. Category C: Monitoring Tools for Reporting Banks that are Direct Participants (i) III. Intraday throughput: To monitor the throughput of a direct participant s daily payments activity and to identify specific times during the day when such a bank might be particularly vulnerable to difficulties, the bank would report the daily average in the reporting period of the percentage of their outgoing payments (relative to total payments) that settle by specific times during the day, by value within each hour of the business day. Stress Scenarios To assist banks and supervisors in the evaluation of intraday liquidity under stress conditions, the Basel Committee has introduced four possible (but non-exhaustive) stress scenarios. Reporting banks would be required to employ the stress scenarios to assess potential adverse impacts on the monitoring tools above and discuss with supervisors how they would address such impacts, either through contingency planning arrangements and/or their wider intraday liquidity risk management framework. 9 The final framework, however, omits the routine reporting regime to regulators proposed in the Consultative Document in connection with the stress scenarios. The stress scenarios, which are substantially unchanged from those covered in the Consultative Document, consist of the following: Own financial stress: A bank suffers, or is perceived to be suffering from, a stress event: For both direct participants and banks that use correspondent banking services, own financial or operational stress may result in counterparties (including corresponding banks) deferring payments and/or withdrawing intraday credit lines, among other adverse impacts. Counterparty stress: A major counterparty suffers an intraday stress event which prevents it from making payments: A counterparty stress may leave both direct participants and banks that use correspondent banking services unable to rely on incoming payments from the stressed counterparty, reducing the availability of intraday liquidity that can be sourced from the receipt of the counterparty s payments. A customer bank s stress: A customer bank of a correspondent bank suffers a stress event: A customer bank s stress may result in other banks deferring payments to the customer, creating a further loss of intraday liquidity at its correspondent bank. Market-wide credit or liquidity stress: A market-wide credit or liquidity stress may have adverse implications for the value of liquid assets that a bank holds to meet its intraday liquidity usage. A widespread fall in the market value and/or credit rating of a bank s unencumbered liquid assets may constrain its ability to raise intraday liquidity from the central bank (for direct participants) or a correspondent bank(s) (for indirect participants). For each stress scenario, reporting banks would be required to consider the scenario s impact on one or more monitoring tools specified by the Intraday Liquidity Document to be assessed under the scenario. The Basel Committee further notes that, while each of the monitoring tools has value in itself, combining the information provided by the tools will give supervisors a comprehensive view of a bank s resilience to intraday liquidity shocks. The Intraday Liquidity Document provides several illustrations of how the tools -4-

5 could be used in different combinations to assess a bank s resilience to intraday liquidity risk. 10 example, the monitoring tool for time-specific obligations can be assessed in combination with the tools for total payments and available intraday liquidity at the start of the business day. If a high proportion of a bank s payment activity is time critical, the bank has less flexibility to deal with unexpected shocks by managing its payment flows, especially when its amount of available intraday liquidity at the start of the business day is typically low. In such circumstances, the supervisor might expect the bank to have adequate risk management arrangements in place or to hold a higher proportion of unencumbered assets to mitigate this risk. IV. Other Monitoring and Reporting Issues The Basel Committee s guidance on several additional monitoring and reporting issues aims to assist reporting banks and their supervisors in determining the most appropriate way the monitoring tools should be implemented in light of differences both within and among banking organizations with regard to systems, currencies, organizational structures and jurisdictions of operation. The additional guidance covers the following topics: (i) Systems. Addressed separately at direct and indirect participants, the section on systems provides in pertinent part as follows: (ii) (iii) Because some direct participants manage payment and settlement activity on a system-bysystem basis, while others arrange to transfer excess liquidity from one system to another without restriction, the Basel Committee sets forth a set of principles to determine the appropriate basis for reporting system data. Among other things, these principles would allow a bank to aggregate data reported across systems subject to the bank s ability to demonstrate to a supervisor s satisfaction that it can transfer liquidity intraday between such systems. The guidance also clarifies that there are no separate reporting requirements for ancillary systems. Banks that use correspondent banking services should base their reporting per correspondent bank, but such banks would also be able to aggregate data across multiple correspondent banks if they can demonstrate an ability to move liquidity among such correspondent banks. 11 Currency. Banks that manage their intraday liquidity on a currency-by-currency basis should report on an individual currency basis. The Intraday Liquidity Document would allow intraday liquidity positions across currencies to be aggregated for reporting purposes if a bank can prove to its supervisor s satisfaction that it manages liquidity on a cross-currency basis and has the ability to transfer funds intraday with minimal delay, but banks would nonetheless report at an individual currency level so that supervisors can monitor the extent to which firms are reliant on foreign exchange swap markets. The Intraday Liquidity Document does grant flexibility where a bank s level of activity in any one particular currency is considered de minimis, in which case, upon agreement with a supervisor, separate returns would not be necessary. 12 Organizational structure. While the Basel Committee expects that the monitoring tools would typically be applied at a significant individual legal entity level, the guidance provides that the determination regarding the appropriate entity should take into account any potential impediments to moving intraday liquidity between entities within a group, including the ability of supervisory jurisdictions to ring-fence liquid assets, timing differences and any logistical constraints on the movement of collateral. Where banks can demonstrate that there are no impediments or constraints to transferring intraday liquidity between two (or more) legal entities intraday, they would be able to aggregate reporting for such entities. For -5-

6 (iv) Responsibility of home and host supervisors. In cases where a bank operates in a LVPS and/or with a correspondent bank(s) outside the jurisdiction where it is domiciled, the Basel liquidity framework provides that both home and host supervisors will have an interest in ensuring that the bank has sufficient intraday liquidity to meet its obligations in such LVPS and/or with such correspondent bank(s). 13 The Intraday Liquidity Document sets out principles for the allocation of responsibility between home and host supervisor, which would depend upon whether the bank operating in the non-domestic jurisdiction does so via a branch or a subsidiary. V. Reporting Regime Consistent with the initial proposal, the reporting of the monitoring tools is supposed to commence on January 1, 2015 (to coincide with the Basel Committee s implementation timeline for the Liquidity Coverage Ratio under the Basel III framework), and the reporting frequency would be monthly. 14 Under the Intraday Liquidity Document, if banks are unable to meet this implementation deadline because of data availability constraints with their correspondent bank(s), supervisors may give consideration to phasing-in implementation to a later date, preferably no later than January 1, Further, the Intraday Liquidity Document explains that public disclosure is not intended to be part of the reporting process, and banks and national supervisors would not be required to publicly disclose reported data. * * * Copyright Sullivan & Cromwell LLP

7 ENDNOTES See Basel Committee, Monitoring tools for intraday liquidity management (Apr. 2013) (the Intraday Liquidity Document ). In September 2008, the Basel Committee published its Principles for Sound Liquidity Risk Management and Supervision (the Sound Principles ), which provide guidance for banks on their management of liquidity risk and collateral. Principle 8 of the Sound Principles focuses specifically on intraday liquidity risk and sets forth qualitative guidance by way of six operational elements that should be included in a bank s strategy for managing intraday liquidity risk. In addition, in January 2013, the Basel Committee published Basel III: The Liquidity Coverage Ratio and liquidity risk monitoring tools (the Basel III LCR ), which set out a series of amendments to the Liquidity Coverage Ratio (the LCR ). However, while the LCR is meant to promote the shortterm resilience of the liquidity risk profile of banks, it does not incorporate intraday liquidity into its calibration. See Basel III LCR, 41. For additional information regarding the Basel III LCR, see Sullivan & Cromwell LLP s memorandum to clients titled Basel III Liquidity Framework: Basel Committee Publishes Changes to the Liquidity Coverage Ratio, dated January 15, See Basel Committee, Monitoring indicators for intraday liquidity management (July 2012). In addition to these and other changes, the Intraday Liquidity Document introduces certain changes in terminology. Most notably, the term financial institution, preferred throughout the initial proposal, has generally been replaced with the term bank. For a press release summarizing notable changes to the proposal made in the Consultative Document, see Basel Committee, Comments received on the consultative document "Monitoring indicators for intraday liquidity management", available at: Use of the term payment and settlement systems in the Intraday Liquidity Document encompasses payment systems, and clearing and settlement systems, for securities and derivatives (including central counterparties). See Intraday Liquidity Document, footnote 4. See Intraday Liquidity Document, 9. For specific guidance on the sources and uses of intraday liquidity, see id., The Intraday Liquidity Document provides specific examples of payments that may be included in this metric. See id., footnote 15. Banks are also encouraged to consider reverse stress scenarios and other appropriate scenarios, such as, for example, the impact of natural disasters or currency crises. See id., footnote 21. See id., Annex 3. A third category of system users direct participants of an LVPS that also make use of correspondent should discuss with their supervisor whether they can aggregate data for reporting purposes. Aggregation may be appropriate if the payments made directly through the LVPS and those made through the correspondent bank(s) are in the same jurisdiction and currency. The Intraday Liquidity Document points out, as an indicative threshold, that supervisors may consider a currency significant if the aggregate liabilities denominated in that currency amount to 5% or more of the bank s total liabilities. Basel III LCR, 211. In the Sound Principles, the Basel Committee states that the host supervisor needs to understand how the liquidity profile of the group contributes to risks to the entity in its jurisdiction, while the home supervisor requires information on material risks a foreign branch or subsidiary poses to the banking group as a whole. Sound Principles, 145. Sample reporting templates, reflecting the various required calculations for the monitoring tools summarized above, are provided in the Intraday Liquidity Document. See Intraday Liquidity Document, Annex

8 ABOUT SULLIVAN & CROMWELL LLP Sullivan & Cromwell LLP is a global law firm that advises on major domestic and cross-border M&A, finance, corporate and real estate transactions, significant litigation and corporate investigations, and complex restructuring, regulatory, tax and estate planning matters. Founded in 1879, Sullivan & Cromwell LLP has more than 800 lawyers on four continents, with four offices in the United States, including its headquarters in New York, three offices in Europe, two in Australia and three in Asia. CONTACTING SULLIVAN & CROMWELL LLP This publication is provided by Sullivan & Cromwell LLP as a service to clients and colleagues. The information contained in this publication should not be construed as legal advice. Questions regarding the matters discussed in this publication may be directed to any of our lawyers listed below, or to any other Sullivan & Cromwell LLP lawyer with whom you have consulted in the past on similar matters. If you have not received this publication directly from us, you may obtain a copy of any past or future related publications from John Castro ( ; in our New York office. CONTACTS New York Whitney A. Chatterjee H. Rodgin Cohen Elizabeth T. Davy Mitchell S. Eitel Michael T. Escue C. Andrew Gerlach Andrew R. Gladin Erik D. Lindauer Mark J. Menting Camille L. Orme Rebecca J. Simmons Donald J. Toumey Marc Trevino Mark J. Welshimer Michael M. Wiseman Wendy M. Goldberg Jiang Liu Washington, D.C. Eric J. Kadel, Jr Samuel R. Woodall III Stephen H. Meyer

9 Andrea R. Tokheim William F. Kroener III J. Virgil Mattingly Los Angeles Patrick S. Brown Stanley F. Farrar Tokyo Keiji Hatano SC1: C -9-

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