FTP – Exploring a ‘Best Practice’ Approach

Funds Transfer Pricing used in banks and building societies has evolved significantly since the banking crisis and particularly with the introduction of the strengthening liquidity standard and new CRD IV & BASEL III standards

Our FTP White Paper is now in its second publication and is aimed to help our clients implement their own individual approach to Funds Transfer Pricing (“FTP”).

This paper is based on the views and experiences of both our own expert consultants and also from detailed consultation with our bank and building society clients who use our ALMIS® software and also industry experts.

Our aim is to provide some guidance as to the structure and what needs to be considered when client Firms are developing their FTP policies, methodologies and models. It is particularly aimed at the needs small and medium sized institutions that do not access the international capital markets for their funding.

In this paper, we give some background, explain the definition and objectives of FTP and then provide a technical road map for calculating pricing, taking account of the main components as identified. It will be particularly of relevance to banking institutions that are predominantly funded from retail / SME sources.

Request FTP White Paper – 2016 Update

The following links give valuable insight on this evolving subject – published by global, European, US and UK regulatory bodies.

The Bank for International Settlements published a paper written by Australian regulator Joel Grant.  This paper was a reaction to the lack of liquidity pricing post-crash and looks at liquidity pricing in some detail.

http://www.bis.org/fsi/fsipapers10.pdf

The EBA published a very high level paper on guidance over liquidity pricing in October 2010

https://www.eba.europa.eu/documents/10180/16094/cebs18_Guidelines.pdf

The FSA send a dear treasurer letter to all banks following a thematic review of 10 UK banks and highlighting general weaknesses in FTP

http://www.fsa.gov.uk/pubs/international/ftp_treasurer_letter.pdf

Following the thematic review the Bank of England publish a very informative paper on approaches and techniques for FTP on banks written by Fabrizio Cadamagnani of the Banking and Insurance Analysis Division, Rashmi Harimohan of the Bank’s Monetary Assessment and Strategy Division and Kumar Tangri of the Risk Infrastructure, Liquidity and Capital Division.

http://www.bankofengland.co.uk/publications/Documents/quarterlybulletin/2015/q204.pdf

In March 2016 the Federal Reserve System published Interagency Guidance on Funds Transfer Pricing Related to Funding and Contingent Liquidity Risks.

https://www.federalreserve.gov/bankinfore.g./srletters/sr1603.htm

As part of Building Society regulation, the Bank of England include for the first time FTP in the building society source book and specific guidance included in consultation paper CP1216.

http://www.bankofengland.co.uk/pra/Documents/publications/cp/2016/cp1216.pdf

ALMM Update

The PRA has finalised the date of changes to liquidity reporting rules. On 22 April 2016, FSA 050-053 will be switched off and the EU requirements to report additional liquidity monitoring metrics introduced. Firms will not be required to report both sets of returns simultaneously. Note the first reporting date for returns C67.00, C68.00, C69.00, C70.00 and C71.00 will be 30 April for monthly reporters, and 30 June for quarterly reporters.

C66.00 (Maturity analysis) has been dropped

For the months from April 2016 to October 2016 only, the reporting remittance date for monthly reporters is the 30th calendar day after the reporting reference date. Afterwards it reverts to 15 calendar days. Quarterly reporters have 30 calendar days to remit returns.

Reporting remains monthly – but quarterly for institutions that are not part of a group with subsidiaries or parent institutions located outside the UK and the “balance sheet total of the institution represents only a small proportion of the sum of individual balance sheet totals of all institutions in the respective Member State and the institution has total assets which are not significant”. This means almost all UK banks and building societies are quarterly.

http://www.bankofengland.co.uk/pra/Pages/publications/ps/2016/ps1516.aspx

Navigating COREP Taxonomy Changes

The much-anticipated update to the current (version 2.3.1) taxonomy (the set of definitions published by the EBA which precisely interpret the meaning/value of numerical data entered into COREP and FINREP returns) has been published. This new version (2.4.1) currently does not have an implementation date but has already superseded version 2.4 which was never implemented.

The EBA has also issued a version 2.5 which will supersede all previous versions to become the definitive taxonomy from December 31st 2016. Amongst others, one of the first reports affected will be the monthly LCR for period ending Dec 2016.

To complicate the situation even further, the recent European LCR Delegated Act, implemented by the UK regulatory authorities, requires dual reporting of the monthly COREP LCR. As version 2.3.1 does not cover the Delegated Act’s requirements, in practical terms this will mean firms using both the existing COREP taxonomy version 2.3.1 and a manual Excel spreadsheet work around until such time as version 2.4.1 (or version 2.5) is implemented.

This complicated and uncertain environment is a challenge for both financial firms, many of whom are still finding their way through the rigours of COREP and FINREP, and for service providers like ALMIS® International who must ensure their software is always compliant, regardless of the frequency and uncertainty of regulatory directives from the EBA.

ALMIS® International will continue to develop its Regulatory Reporting module to comply with the now published ‘gold standard’ of version 2.5. However, we will continue to work closely with the EBA and the PRA at UK national level so that if version 2.4.1 is implemented between now and December 31st, our software, training and support will ensure your returns remain compliant and help you navigate a smooth course.

For more information contact Jenna Haston [email protected] or call +44 131 452 8898

COREP Taxonomy Updates

There have been some recent press releases issued by the EBA regarding updates to the Data Point Model and the XBRL Taxonomies according to the Implementing Technical Standards (ITS) on Supervisory Reporting.

The first of these is a corrective update, taxonomy 2.4.1, which is to be used in place of the previously published taxonomy 2.4. This taxonomy will apply for submissions with reference dates 6 months from the point of their publication in the Official Journal- provided that this is prior to December 2016. At the time of writing, there has been no publication relating to taxonomy 2.4 or 2.4.1 in the Official Journal.

The second press release is related to the publication of taxonomy 2.5. It is explicitly stated that this will be used for reference dates from 31 December 2016 onwards.

In the interim, the active taxonomy continues to be 2.3.1.

We will continue looking out for further news on the situation, and liaise with contacts in the industry in order to keep our clients updated with the most recent regulatory developments.

European Commission settles approach to ALMM (additional liquidity monitoring metrics) reporting and confirms timing

Long awaited Commission Regulations settling the approach to the new ALMM reporting regime have been published. As previously thought the regulations drop Maturity analysis (for the time being anyway).

The reporting regime will require certain institutions to submit the required reports monthly (with April 2016 as the first month for which information is to be reported); however for most UK firms the reporting requirement will be quarterly.

Reports to be submitted will cover: Concentration of funding by Counterparty, Concentration of funding by Product Type, Prices for various lengths of funding, Roll-over of funding and Concentration of Counterparty Capacity by Issuer/Counterparty.

A key challenge will be the need for firms to collect data on new funding and rollovers.

We continue to liaise with the EBA on details regarding reporting deadlines as well as the content of submissions when reported on a quarterly basis. We are continuing to monitor for any update from the PRA related to this statement on ALMM.

Almis Strengthen Core Team

Almis International have continued their growth strategy with two senior appointments.

Simon Garrett joins as Head of Implementation, having previously worked in a similar role with Oracle.  He  will manage software implementation using the respected ‘ALMIS® Implementation Methodology’ (AIM), delivering projects on time and within budget.   He brings 20 years experience in the financial services industry as both a customer and software vendor and is already adding value to the team.

Colin McKay joins as Chief Operating Officer

November 1st 2015, ALMIS® International announces the key appointment of Colin McKay as Chief Operating Officer (COO). This key appointment signals an exciting new phase in the expansion of the company, established in 1992, which has seen significant growth over the past two years. ALMIS® International now supports over 50 clients with the development of a comprehensive Asset Liability Management (ALM) and Regulatory Reporting solution for small and mid-size banking firms.

Joe Di Rollo, founder of ALMIS® International, will transition from his current roles of Managing Director and Head of Operations, to that of Chief Executive Officer (CEO), with an intention to concentrate on product development, customer relations and regulatory developments.

Already a Non-Executive Director of ALMIS® International for some time, Colin now assumes his new executive role after 25 years as a finance lawyer advising banks in domestic and international markets. During spells in London, Tokyo and Edinburgh Colin has worked in several firms including Freshfields, Eversheds and most recently Shepherd and Wedderburn. Along the way he has led service delivery teams, held various management positions and run several key financial institution accounts.

Colin said, “Joe has developed a world-class solution which the banking market needs now more than ever. With the support of a loyal and expanding client base, the prospects for growth of the business are exciting”.

In welcoming Colin to the team Joe comments,” I believe Colin has the ideal combination of banking expertise, management best practice and customer relations experience to take us forward to the next stage of growth and consolidation.”

ALMIS® International hosts its annual user group meeting later this month at which clients will have the opportunity to meet Colin and hear of his initial plans.

For more information, contact Jenna Haston by email or call on 0131 452 8898.

LCR under the new Delegated Act 58 Banks and Building Societies attend ALMIS® webinar

From 1st October all UK Banks and Building Societies are required to produce the LCR under the new delegated act. To help bring clarity to the new delegated act and address the key points which affect small banks and building societies ALMIS® International, already experts in delivering an automated solution, hosted a highly informative and interactive webinar on Tuesday 29th September, attended by 58 delegates.

The webinar was led by Joe Di Rollo (Managing Director) of ALMIS® International and covered the main points for completing and calculating the new LCR.

This webinar was very relevant to understanding and navigating the issues posed by the new CRD IV liquidity regime which came into force on 1st October. There is definitely an appetite for greater understanding of the new regime and discussion of the more complex and ambiguous issues, as evidenced by the high turnout from both banks and building societies. Everyone agreed on the need for clarity in order to achieve effective compliance and best practice.

The webinar focused on the main points for completing and calculating the LCR and highlighted some key issues.

Key Issues

There is now increased choice for investing in HQLA’s (High Quality Liquid Assets). Delegates were asked which instruments they are considering. The results are captured in the graph below:

lcr-webinar-graph

Outflows are the most complex part of the return with some interesting differences in interpretation. One example of different opinions in interpretation discussed at the webinar is detailed below:

If a customer has a balance greater than the FSGS limit (shortly to be £75,000) should the entire balance be treated as a higher risk outflow of 10% or only the portion of the balance above the insured amount?

The EBA FINAL draft implementing technical standards states:

1.1.1.2 Deposits subject to higher outflows

“Credit institutions shall report here the full balance of the deposits subject to higher outflow rates in accordance with paragraph 2 and 3 of Article 25 of Commission delegated regulation (EU) 2015/61. Those retail deposits where the assessment under paragraph 2 of Article 25 for their categorization has not been carried out or is not completed shall also be reported here”.

This wording suggests that the intent is for the entire balance to be considered non-stable.

On the other hand…

Article 25 para 1 – Credit institutions shall multiply by 10% other retail deposits, including that part of retail deposits not covered by Article 24.

Firms are interpreting this to mean that only the excess over the guarantee is subject to the higher outflow.
ALMIS® software is designed to handle both interpretations.

In summary, ALMIS® is already a fully automated solution which produces the LCR from core data. This same core data is used for liquidity adequacy and analysis, providing a reliable, automated system to help ensure efficient compliance with the new regulations, regardless of interpretation.

For the presentation slides, please contact Jenna Haston by email on [email protected] or call on 0131 452 8898.

Liquidity under CRD IV and ALMM – Additional Liquidity Monitoring Metrics – Is there a positive aspect?

The imminent introduction of the new LCR and ALMM will indeed increase the volume and even frequency of reporting for many Building Societies but, after closer inspection, is it all bad news or can firms use this data to their competitive advantage?

Volume of Reporting

The amount of regulation reporting for liquidity from each individual firm is now twice the volume that the entire UK Building Society sector was producing prior to 2008. The six new ALMM reports alone contain over 15,000 data points. The new ALMM reports can be considered work in progress as the EBA gain approval from the European Commission and they add technical definitions and validations. For a temporary period, firms are reporting three different cuts of liquidity data as regulations move towards new standards.

Proportionality

There are, however, positive aspects to the new regime announced recently by the PRA.

  • Daily reporting will not be a requirement for firms with >£5bn assets.
  • The new LCR (liquidity under CRD IV) replaces the BIPRU 12 type A/B approach, is more rules based than principles driven and for many produces a lower minimum.
  • The minimum liquidity target is therefore considered easier for most building societies.
  • There is now a wider range of instruments to invest liquid assets.

Turning Compliance to Competitive Advantage

The volume and ‘work in progress’ nature reporting demand that all firms implement smart, automated and flexible systems. The up side though of getting this right will enable firms to better analyse and manage liquidity to their advantage – providing more accurate visibility over a Funds Transfer Pricing allowing understanding of the true cost of liquidity and how to best manage this.

To assist with this, we are developing auto population for four of the main reports and this auto population will be available from beginning of September 2015. We have also prepared a document that explains the reports and a more detailed ALMIS® specification.

For further information or to request an ‘ALMIS® Guide to understanding ALMM’, please contact [email protected]

ALMM – Additional Liquidity Monitoring Metrics

ALMM – timing of new introduction

6 new reports that contain over 15,000 data points. Under taxonomy 2.3 these contain very limited validations and can be therefore seen as work in progress.

Four categories of reporting are:

  • A contractual maturity analysis (c66)
  • The concentration of funding by counterparty and product (c67 & C68)
  • Volumes, spreads and roll-overs of funding in the past month (c69 & c70)
  • The concentration of counterbalancing capacity (c71)

Current timescale is that the ALMM will be introduced from 1 July 2015 but this is subject to approval by the European Commission and at the current time this approval has not been given. There is therefore wide expectation of a delay and a revised timetable.

Even with this earliest adoption, most UK firms will be exempt from monthly submissions (Chapter 7B, Article 16b of Regulation (EU) No 680/2014). For those firms (total assets less than EUR 30bn), reporting would not commence until the next quarterly (q3) September reference with reporting in November 2015

For a detailed specification or further information, please contact [email protected]