ILAS overview for UK branches of foreign banks

Similar documents
Best Practices for Liquidity Regulatory Reporting According to FSA PS09/16 Moody's Analytics Liquidity Risk and FSA Reporting Webinar Series

The Hedge Fund Redemption

The PRA s approach to supervising liquidity and funding risks

Policy Statement PS11/15. CRD IV: Liquidity. June 2015

Consultation Paper CP27/14. CRD IV: Liquidity

Supervisory Statement SS18/13. Recovery planning. December (Last updated 16 January 2015)

DNB Liquidity Pillar 2 Supervision. Seminar Das neue SREP Konzept der Aufsicht Clemens Bonner (c.bonner@dnb.nl)

Key matters in examining Liquidity Risk Management at Large Complex Financial Groups

NATIONAL BANK OF ROMANIA

China International Capital Corporation (UK) Limited Pillar 3 Disclosure

Policy on the Management of Country Risk by Credit Institutions

Prof Kevin Davis Melbourne Centre for Financial Studies. Managing Liquidity Risks. Session 5.1. Training Program ~ 8 12 December 2008 SHANGHAI, CHINA

Asset and liability management: suggestions for greater effectiveness

Basel III: Liquidity Rules

Risk Management Programme Guidelines

Guideline. No: B-6 Date: February 2012

Optimize. OPTIMIZING CASH FOR COMPLIANCE

The Mortgage Market Review and Non-bank mortgage lenders is enhanced Prudential Supervision on the way?

Year end results. Basel II Pillar 3 Disclosures 2010

Capital Requirements Directive Pillar 3 Disclosure. Western Asset Management Company Limited December 2008

Impact assessment of the new liquidity rules on Luxembourg banks

Insurance Guidance Note No. 14 System of Governance - Insurance Transition to Governance Requirements established under the Solvency II Directive

Discussion Paper DP1/14. Ensuring operational continuity in resolution

Basel Committee on Banking Supervision

Capital Market Services UK Limited Pillar 3 Disclosure

RTGS operating hours review

Final report. Guidelines on the minimum list of qualitative and quantitative recovery plan indicators EBA-GL May 2015

Close Brothers Group plc

Basel II, Pillar 3 Disclosure for Sun Life Financial Trust Inc.

Consultation Paper CP37/15 The implementation of ring-fencing: prudential requirements, intragroup arrangements and use of financial market

D. E. Shaw & Co. (London), LLP Pillar 3 Disclosure

LIQUIDITY RISK MANAGEMENT GUIDELINE

Mortgage Market Review Data Reporting

GUIDELINES ON CORPORATE GOVERNANCE FOR LABUAN BANKS

Insurance Authority United Arab Emirates. Board of Directors Decision Number (25) of 2014 Pertinent to. Financial Regulations for Insurance Companies

Liquidity: A bigger challenge than capital

Business Reviews - Prudential plc Annual Report 2012

Basel Committee on Banking Supervision. Principles for Sound Liquidity Risk Management and Supervision

Central Bank of The Bahamas Consultation Paper PU Draft Guidelines for the Management of Interest Rate Risk

GUIDANCE NOTE FOR DEPOSIT TAKERS. Foreign Exchange Risk Management. May 2009 (updated March 2011 and January 2012)

Friends Life Assurance Society Limited

EBA-GL July Guidelines. on the minimum list of qualitative and quantitative recovery plan indicators

06/14. Implementing MiFID for Firms and Markets. Addendum Capital/Professional Indemnity Insurance (PII) requirements. Financial Services Authority

Consultation Paper on Liquidity Coverage Ratio Disclosure Requirements

Implementing the Bank Recovery and Resolution Directive response to CP13/14

Guidance Note: Stress Testing Class 2 Credit Unions. November, Ce document est également disponible en français

Guideline. Category: Sound Business and Financial Practices. No: E-18 Date: December 2009

The Internal Capital Adequacy Assessment Process (ICAAP) and the Supervisory Review and Evaluation Process (SREP)

Standard Life Assurance Limited OCTOBER Principles and Practices of Financial Management for the UK Smoothed Managed With Profits Fund

Consultation Paper CP13/14. Implementing the Bank Recovery and Resolution Directive

Capital Requirements Directive IV Framework Liquidity Requirements. Allen & Overy Client Briefing Paper 15 January

EBA final draft Regulatory Technical Standards

Prudential Standard APS 210 Liquidity

Managing liquidity risk Collaborative solutions to improve position management and analytics

Mortgage Market Review Data Reporting

THE INSURANCE BUSINESS (SOLVENCY) RULES 2015

BERMUDA MONETARY AUTHORITY

ABI RESPONSE TO CP140: INTERIM PRUDENTIAL SOURCEBOOK FOR INSURERS: GUIDANCE ON SYSTEMS AND CONTROLS, AND CP142: OPERATIONAL RISK SYSTEMS AND CONTROLS

Solutions for Balance Sheet Management

Brevan Howard Asset Management LLP Pillar 3 Disclosures. Brevan Howard (2014). All Rights Reserved.

RBS Collective Investment Funds Limited

Liquidity Coverage Ratio

Disclosure 17 OffV (Credit Risk Mitigation Techniques)

GUIDELINES ON INVESTMENT MANAGEMENT FOR LABUAN INSURANCE AND TAKAFUL BUSINESS

Report on Internal Control

ICAAP Report Q2 2015

Julian Hodge Bank Limited. Pillar 3 disclosures as at 31 October 2012

Extending the CHAPS and CREST Settlement Day

S t a n d a r d 4. 4 a. M a n a g e m e n t o f c r e d i t r i s k. Regulations and guidelines

Guidelines on operational functioning of colleges

RBS Collective Investment Funds Limited

FOREIGN EXCHANGE RISK MANAGEMENT

on Asset Management Management

Prudential Standard APS 210 Liquidity

NOVEMBER 2010 (REVISED)

Outsourcing. FSA Regulated firms (including offshore outsourcing) Contents. March 2004

BOARD OF GOVERNORS FEDERAL RESERVE SYSTEM

Liquidity Stress Testing

UK Green Investment Bank plc

Bank Capital Adequacy under Basel III

Risk & Capital Management under Basel III

Policy Statement 09/20. Financial Services Authority. Stress and Scenario Testing. Feedback on CP08/24 and final rules

U.S. regulatory capital: Basel III liquidity coverage ratio final rule

How To Improve Profits At Bmoi

CAPITAL RESOURCES AND PROFESSIONAL INDEMNITY INSURANCE REQUIREMENTS FOR PERSONAL INVESTMENT FIRMS (NO 2) INSTRUMENT 2015

Risk management systems of responsible entities: Further proposals

Capital Requirements Directive IV Framework Operational Risk. Allen & Overy Client Briefing Paper 13 January

shareplc: Pillar 3 Disclosures CONTENTS Oxford House Oxford Road Aylesbury Buckinghamshire HP21 8SZ phone visit

Capital Adequacy: Advanced Measurement Approaches to Operational Risk

EBA FINAL draft implementing technical standards

Pillar 3 Disclosures

Pillar III Disclosures Calendar Year 2008

Application for a Banking Authority Foreign Bank Branches Prudential Statement J2

TAILORED RESOLUTION PLAN 2013 PUBLIC VERSION

Risk Management. Credit Risk Management

FSA general insurance actuaries what do they actually do? A better question would be: What don t they do? Well the only thing is pricing!

Standard Life Investment Funds Limited

RECOMMENDATION OF THE EUROPEAN SYSTEMIC RISK BOARD of 22 December 2011 on US dollar denominated funding of credit institutions (ESRB/2011/2)

GUIDELINES ON RISK MANAGEMENT AND INTERNAL CONTROLS FOR INSURANCE AND REINSURANCE COMPANIES

Risk Management Guidelines For Co-operative Financial Institutions

Transcription:

ILAS overview for UK branches of foreign banks Draft version 0.6 Revised June 2010 Page 1 of 8 Katalysys

Table of Contents 1 Introduction... 3 2 Overview of the new liquidity framework... 3 3 Scope... 5 4 Timetable... 5 5 Reporting frequency and deadlines... 6 6 Assessment Process... 6 7 Cost implications... 7 8 Further references... 8 9 Glossary of terms... 8 Page 2 of 8 Katalysys

1 Introduction The new liquidity requirements are set out in the FSA Handbook of Rules and Guidance, Prudential sourcebook for Banks, Building Societies and Investment Firms (BIPRU) section 12. A UK branch of a foreign bank without a modification waiver must comply with all aspects of the new rules. This document highlights the key aspects of the new policy for UK-based branches of foreign banks without an intra-group or whole-firm waiver. 2 Overview of the new liquidity framework The new liquidity framework is driven by the overarching principle outlined in BIPRU 12.2.1R A firm must at all times maintain liquidity resources which are adequate, both as to amount and quality, to ensure that there is no significant risk that its liabilities cannot be met as they fall due. The FSA has followed a principle-based-approach for the overall framework while using a more prescriptive approach for reporting and quantitative measures. Systems and control requirements Individual liquidity adequacy standards (ILAS) Group-wide management of liquidity Reporting Systems and controls requirements (BIPRU 12.3, 12.4) Overarching principles of self-sufficiency and adequacy of liquidity resources fulfilled by developing appropriate internal policies, systems and controls Building Blocks Deliverables Governing body & senior management oversight Managing liquidity across legal entities, business lines & currencies (identify, measure, monitor and control) Pricing liquidity risk Funding diversification & market access Intra-day liquidity risk management Stress testing Management of collateral positions Contingency funding plans Develop a Liquidity Risk Management Framework which includes the following :- 1) Liquidity risk tolerance/appetite statement (including risk limits and early warning indicators) 2) Liquidity management policy 1 3) Stress testing guidance 4) Contingency funding plan 1 The branch would already have a documented Liquidity management policy as per IPRU 3.4.3 R Page 3 of 8 Katalysys

Individual liquidity adequacy standards (BIPRU 12.5, 12.7) Quantification of liquid assets required to survive stress scenarios considering the 10 risk drivers Building Blocks Idiosyncratic, market wide and combination stress tests across the following liquidity risk drivers 1) Wholesale funding 2) Retail funding 3) Intra-day 4) Intra-group 5) Cross-currency 6) Off-balance sheet 7) Franchise viability 8) Marketable assets 9) Non-marketable assets 10) Funding concentration Deliverables Stress test results Individual Liquidity Adequacy Assessment (ILAA) document Liquidity buffer quantitative measures Group-wide management of liquidity (BIPRU 12.8) Applies only to branches that have applied for intra-group or whole-firm modification Not applicable to branches that do not qualify for a modification Reporting (SUP 16) Standardized, granular, contractual and frequent reporting to enable FSA to apply advanced business intelligence capabilities for supervisory benchmarking Building Blocks Cash flow mismatches Liquid assets/currency Funding sources Leading Indicators Deliverables FSA047 - Daily Flows FSA048 Enhanced Mismatch Report (EMR) FSA050 Liquidity Buffer FSA054 - Currency Analysis: Percentages of assets/ liabilities in each currency FSA051 Funding Concentration by counterparty FSA053 Retail & Corporate Funding FSA052 Pricing data - Wholesale Liabilities: Price/volume of funding by type / currency FSA055 - Systems and Controls Questionnaire for non-ilas firms Page 4 of 8 Katalysys

3 Scope The table below outlines the scope of the new regime for branches of foreign banks. Branches without modification waiver Branches with modification waiver*** Selfsufficiency & adequacy of liquidity resources (BIPRU 12.1, 12.2) Systems & controls (BIPRU 12.3, 12.4) ILAS (BIPRU 12.5, 12.7) Simplified ILAS (BIPRU 12.6, 12.7) Regular frequency quantitative reporting (SUP 16) Low frequency quantitative reporting (SUP 16) 2 X (>1bn) (<1bn) X X X X *** In case where the whole-firm modification or intra-group modification waiver applications are approved, the responsibility of ensuring adequate liquidity for the branch rests with the parent bank or other group entity. 4 Timetable The FSA has provided a detailed flight-path and transitional period (BIPRU TP 26) based on the type of firm and existing liquidity reporting method as outlined in the table below:- Class of firm UK branches of foreign banks that do not hold a Global Liquidity Concession (GLC) under the current liquidity regime in IPRU Bank UK branches of foreign banks that hold a GLC under the current liquidity regime in IPRU Bank Switch on date for systems & controls Switch on date for quantitative requirements (ILAA and Liquidity buffer) Switch on date for reporting requirements 1 December 2009 1 November 2010 1 November 2010 1 November 2010 1 November 2010 1 November 2010 2 Balance sheet under 1 bn Page 5 of 8 Katalysys

5 Reporting frequency and deadlines Reports Report type Frequency (deadline) 3 Branches of foreign banks without waiver Branches of foreign banks with waiver FSA047, FSA048 Cash flow mismatches Weekly (T +1) FSA050, FSA051 Liquidity buffer and funding Monthly (T + 15) concentration FSA052 Pricing data (wholesale) Weekly (Tuesday) FSA053, FSA054 Funding & Currency analysis Quarterly (T +15) FSA055 Systems and controls questioner Annual (T +15) ILAA Annual assessment approved by the governing body Annual FSA047, FSA048 Cash flow mismatches Quarterly (at most) FSA050, FSA051 Liquidity buffer and funding N/A concentration FSA052 Pricing data (wholesale) N/A FSA053, FSA054 Funding & Currency analysis N/A FSA055 Systems and controls N/A questionnaire ILAA Annual assessment approved by the governing body N/A 6 Assessment Process The overall liquidity assessment process is as shown below:- Internal assessment (by 1-Nov-2010) Policies & Liquidity Buffer ILAA & Stress test results FSA - Supervisory Liquidity Review Process Adequacy and overview Benchmarking FSA - Individual Liquidity Guidance Limits Monitoring and reporting Business As Usual (starting 1-Nov-2010) FSA Reporting Internal early warning indicators monitoring 3 For branches with balance sheet under 1bn, weekly data items FSA047, FSA048 and FSA052 are to be submitted monthly, with a 15 business day submission deadline and weekly reporting in times of a crisis. Page 6 of 8 Katalysys

7 Cost implications The expected cost implications for branches of foreign banks to comply with the new liquidity regime are provided in the table below. The cost implications are based on the Cost benefit analysis section of the FSA Policy Statement PS09/16 released in October 2009. Cost factor Description Impact Costs to firms of holding increased liquid assets (Cost of self-sufficiency) Operational liquidity reserve Costs due to supervisory requirements for changes in funding Other costs to firms (IT, reporting, training etc) The need to hold more sterling gilts could potentially reduce the revenue of the branch. The buffer to be maintained by the branch to meet its operational obligations. Firms may be subject to costs arising from supervisors requiring increases in duration of funding and a higher proportion of retail funding. The additional costs for reporting, documentation requirements, record keeping, monitoring, risk management, IT infrastructure and other administrative costs In the consultation paper CP08/22, FSA assumes that the top 10 UK banks will increase their holding of government bonds to between 6% and 10% of their total assets. 4 FSA estimates this to be about 2% to 6% of the branch assets. This cost will vary based on the branch s funding profile. Based on the initial consultation, FSA has provided an estimate of the average costs likely to be incurred by branches 5 :- Average one-off costs: 600,000 Average on-going cost (per year): 150,000 Average on-going cost (per year) stress reporting : 170,000 4 Based on the 2009 returns of 88 branches (without GLC) FSA estimates that 40 branches are already selfsufficient and the remaining 48 branches will incur a cost of 400 million a year 5 We believe that the average cost will be substantially lower for branches with assets under 1 billion. The average one-off costs for these branches will be in the range of 200,000-400,000 depending on the size and complexity of the business. Page 7 of 8 Katalysys

8 Further references 1. Presentation slides FSA liquidity briefing for branches (Nov 2009) http://www.fsa.gov.uk/pages/doing/events/pdf/liquidity_slides.pdf 2. The FSA policy document and consultation papers on liquidity http://www.fsa.gov.uk/pages/library/policy/policy/2009/09_16.shtml 3. Individual Liquidity Adequacy Assessment format http://www.fsa.gov.uk/pubs/international/adequacy_assessment.pdf 9 Glossary of terms BIPRU - Banks, Building Societies and Investment Firms Prudential sourcebook CFP Contingency Funding Plan EMR Enhanced Mismatch Report (FSA048) GLC Group Liquidity Concession (as per the existing rules) ILAA Individual Liquidity Adequacy Assessment ILAS Individual Liquidity Adequacy Standards ILG Individual Liquidity Guidance IPRU Interim Prudential Source Book (Banks) LRM Liquidity Risk Management SLRP Supervisory Liquidity Review Process Page 8 of 8 Katalysys