كتاب روابط اجتياز لـ 5.4 Identification of Liquidity Risk
5.4 Identification of Liquidity Risk
C 33/2015 STA يسري تنفيذه من تاريخ 3/1/2022- a.IBs must be able to identify the exposure to liquidity risk, in the short and long term, arising from institution-specific, market-wide or cross-border events for all its operations including subsidiaries, branches, or similar arrangements. In the process of identification, the IB must identify and recognise each significant on- and off-balance sheet position that can have an impact on its liquidity in normal and stressed times and establish a range of metrics. The IB must consider the types of events and activities that can expose it to liquidity risk. It must have a robust framework for projecting the contingent liabilities and other commitments, including calculating the impact of drawing on undrawn commitments.
The identification process must consider, among other things, the nature of exposure, the creditworthiness of the counterparty, correlations between the various business and geographical sectors, and the nature of the relationship with various counterparties. IB must be able to identify incidents that can negatively influence perception in the marketplace about its creditworthiness and the fulfilment of its obligations.
- b.IBs must consider the interactions between exposures to funding liquidity risk and market liquidity risk. An IB that obtains liquidity from capital markets and interbank market Shari’ah compliant instruments must recognise that these sources may be more volatile than normal deposits and IAs.
- c.An IB must be able to model the contractual and behavioral profiles of its fund providers with respect to normal and disruptive market conditions, which can be impacted by its smoothing techniques. For instance, an IB must ensure the availability of sufficient funds as and when the demand arises from non-remuneration accounts and other accounts guaranteed by IB. In addition, an IB must also model the behavioral profile of its investment accounts, as the IB may be affected by runs or panic withdrawals of funds by the Investment Accounts Holders (“IAH”s) in the case of rate of return risk, Shari’ah non-compliance risk or reputational risk which may have an impact on the liquidity condition of the IB.
- d.An IB must ensure that assets are prudently valued according to relevant financial reporting and supervisory standards. An IB must fully factor into its risk management, the consideration that valuations may deteriorate under market stress, and take this into account in assessing the feasibility and impact of asset sales during stress on its liquidity position.
- e.In analysing the risk profile of investment accounts, an IB must take into consideration the smoothing techniques adopted by the IB in line with the Central Bank’s standards and regulations. Stress testing, including scenario analysis, must be used to evaluate the behaviour of IAH and other fund providers of the IB and its impact. IB’s own historical data may provide a good basis for performing an internal assessment of the expectations and incentives of IAH, in normal as well as stressed times
- f.For restricted investment accounts, an IB normally makes matching investments. However, in the case where restricted investment accounts have the right to withdraw funds before the assets are liquidated, the IB may need to fund the gap for the intervening period until the assets are converted into cash. If the withdrawals are more than expected, the IB may be exposed to liquidity risk.
- g.Due to the IB’s dual role in meeting its obligations to current and investment accounts, and managing the expectations of its IAH, it is imperative that the IB performs liquidity cash-flow analysis periodically and under various market conditions. The analysis must include assumptions about the repayment of invested funds to the IAH to the extent that the amount of capital erosion due to investment losses is sufficiently mitigated by Investment Reserve Risk (“IRR”).
- h.If the IB is sourcing funds using contracts other than Mudaraba or Wakala, especially if using sale based instruments, such practices will expose the IB to refinancing risk (through renewal of contract) in stressed market conditions. Observing the Shari’ah requirements in such cases, especially Shari’ah rules pertaining to sale of debt which, among other things, requires that renewal of the contract can only be made after the initial contract has been terminated. Counterparties may be less willing to hold their funds with the IB, resulting in a liquidity shortage and possibly a liquidity crisis, especially in the case of stressed markets, as well as perceived or actual financial or reputational problems of the IB.
- i.IB must be aware that identification of liquidity risk must take into consideration various liquidity risks associated with its own balance sheet (corporate books) operations. An IB may face funding liquidity problems due to:
- i.refinancing risk (e.g. due to system-wide liquidity stress or credit crunch),
- ii.the inadequacy of the liquidity infrastructure in the jurisdiction, or
- iii.the inability of a particular counterparty to renew a liquidity facility, in the absence of more general liquidity stress.
Due to the significant size of such transactions and their potential impact on the profitability and liquidity of the institution, IB must monitor the timing, counterparties, nature and terms of transactions (e.g. secured or unsecured), etc.
- j.IB must also keep track of information related to significant counterparties and other market related information that can impact, directly or indirectly, the management of its liquidity risk. Such information about significant counterparties, most notably financial institutions, may include, but is not limited to, institutional credit rating, market reputation regarding repayment capacity, share prices, profitability, frequency and capacity to renew the funding, financial results of cross-border operations, credit ratings of issued Sukuk, etc. The market-related information may include Islamic money market rates, profit rates paid to IAH and fund providers by competitors, market indices, latest auction rates of local and sovereign Sukuk, as well as movements in foreign exchange and commodities markets – both in local and cross-border markets.
- k.IB must design a set of indicators to aid this process to identify the emergence of increased risk or vulnerabilities in its liquidity risk position or potential funding needs. Such early warning indicators must identify any negative trend and trigger an assessment and potential response by management in order to mitigate the IB’s exposure to the emerging risk. Early warning indicators can be qualitative or quantitative in nature and may include, but are not limited to:
- -Rapid asset growth, especially when funded with potentially volatile liabilities.
- -Growing concentrations in assets or liabilities.
- -Increases in currency mismatches.
- -A decrease of weighted average maturity of liabilities.
- -Repeated incidents of positions approaching or breaching internal or regulatory limits.
- -Negative trends or heightened risk associated with a particular product line, such as rising delinquencies.
- -Significant deterioration in the IB’s earnings, asset quality, and overall financial condition.
- -Negative publicity.
- -A credit rating downgrade.
- -Stock price declines or rising debt costs.
- -Widening debt or credit-default-swap spreads.
- -Rising wholesale or retail funding costs.
- -Counterparties that begin requesting or request additional collateral for credit.
- -Correspondent banks that eliminate or decrease their credit lines.
- -Increasing retail deposit outflows.
- -Increasing redemptions of Islamic CDs before maturity.
- -Difficulty accessing longer-term funding.
- l.Early warning indicators must be closely monitored by senior management on a regular basis. Limits and analysis of the indicators in (l) above must be reviewed and breaches/emerging trends must be escalated up to the board committees or the full board, if significant enough. Clear procedures and escalation criteria must be put in place based on the warning indicators, these include the circumstances where the CFP must be invoked.