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  • Introduction and Overview

    This manual explains how banks can comply with the requirements of Circular Number 33/2015 - Regulations re Liquidity at Banks. It must be read in conjunction with these Regulations.

    Banks fulfill an important role in the economy by providing maturity transformation (borrow short term and lend long term). The aim of these liquidity regulations is to ensure that banks have a robust liquidity risk management and governance process in place to mitigate this imbalance.

    It also ensures that banks are holding sufficient liquid assets to withstand a liquidity stress for a reasonable period of time.

    This manual follows the structure of the Regulations and is set out in three parts:

    1. 1) Qualitative requirements;
    2. 2) Quantitative requirements;
      1. A – Eligible Liquid Assets Ratio (ELAR)
      2. B – Advances to Stable Resources Ratio (ASRR)
      3. C – Liquidity Coverage Ratio (LCR)
      4. D – Net Stable Funding Ratio (NSFR)
    3. 3) Reporting requirements

    These three parts cover the key requirements of liquidity risk management and governance in banks and form the basis of the regulations.

    Note this Manual will remain a working document and under constant review throughout the period of the LCR transition period.

    • 1. Qualitative Requirements

      The manual addresses each of the qualitative requirements contained in the regulations and emphasizes the key focus of the Central Bank in its on and off site examination of banks.

      The qualitative rules come into force on 1 July 2015. Any bank that expects to be in breach of the regulation when the regulation commences should approach the Central Bank to discuss a remediation plan. Breaches will be dealt with on case by case basis. The Central Bank will apply proportionality in determining the suitability of some of the more complex requirements for smaller banks.

      Those banks that are aspiring to be Basel III approved will not have proportionality applied in relation to qualitative requirements, given such banks are expected to comply with all of the qualitative requirements before they can be considered for approval.

    • 2. Quantitative Requirements

      The quantitative requirements come into force on 1 July 2015.

      Banks that apply and are approved to be assessed under the Basel III requirements cannot elect to revert to the ELAR regulatory framework and once approved must comply with both the LCR and the NSFR when they become effective - i.e. on 1 January 2016 and 1 January 2018 respectively.

      There are four ratios under quantitative requirements (see below), two of which are provided by the Basel Committee on Banking Supervision (BCBS) in what is commonly called the Basel III framework. The Liquidity Coverage Ratio (LCR) is fully described in their publication 'Basel III: The Liquidity Coverage ratio and liquidity risk monitoring tools' dated January 2013. The Net Stable Funding Ratio (NSFR) is fully described in their publication ‘Basle III: the net stable funding ratio’ dated October 2014

      The ratios are as follows:

      A – Eligible Liquid Assets Ratio (ELAR)

      This is a measure to ensure banks hold minimum buffers of liquid assets.

      The ratio requires the bank to hold an amount equivalent to 10% of its total balance sheet liabilities (excluding those included in regulatory capital) in high quality liquid assets, as described in detail later in this manual.

      This ratio will be periodically reassessed and if necessary adjusted to reflect the appropriate Central Bank policy as well as any recalibration necessary to keep it aligned with the LCR.

      B – Advances to Stable Resources Ratio (ASRR)

      The ASRR is a measure that recognizes both the actual uses as well as the likely uses of funds in terms of the contractual maturity and behavioral profile of the sources of funds available to the bank, in order to ensure that there are limited maturity mismatches and cliff effects. Central Bank reporting for BRF 7 details the requirements of the ratio.

      C – Liquidity Coverage Ratio (LCR)

      This is a short term (30 days) stress test that covers bank specific and market wide stresses. It is determined by the Basel III standards and will be effective from 1 January 2016 at a compliance level of 70%. Subsequent years will see a flight path of an extra 10% per year until full (100%) compliance on 1 January 2019. Those banks that are permitted to use the Basel III ratios will comply at a 70% level as at 1 January 2016, 80% level at 1 January 2017, 90% at 1 January 2018 and 100% at 1 January 2019.

      The relevant section in this manual will provide the definitions and assumptions used in the LCR calibration. Most of these assumptions are taken from the Basel Committee for Banking Supervision (BCBS) document titled “Basel III: The Liquidity Coverage Ratio and liquidity risk monitoring tools “issued January 2013. The section will also provide guidance over areas where national discretion has been utilized.

      This section will be updated with any changes to the Basel III liquidity framework between the date of issuance of this manual and the effective date of the Basel III standards.

      D – Net Stable Funding Ratio (NSFR)

      This is a structural ratio that aims to ensure that the banks have sufficient long term funding beyond the LCR’s 30 day time horizon to meet both the funding of its long term assets and the funding of a portion of contingent liability drawdowns under a period of market wide stress.

      Like the LCR, the relevant section of the manual will provide guidance in a local context but fundamentally the guidance is derived from the October 2014 paper from the BCBS. Any subsequent changes will be updated accordingly.

      Banks approved by the Central Bank to move onto the LCR will also be required to comply with the NSFR. However, the date for compliance will be 1 January 2018 and until then banks must comply with the Advances to Stable Resources Ratio described in these guidelines.

      From the date of these Regulations the ratios that all banks must comply with are the ELAR and the ASRR. Only those banks approved by the Central Bank to do so will be able to use the LCR and the NSFR for regulatory compliance.

    • 3. Reporting Requirements

      All banks are required to report their liquidity position to the Central Bank in accordance with ELAR and ASRR reporting requirements as issued by the Central Bank.

      Those banks approved to move to the Basel III liquidity standards (LCR and NSFR) will be required to report their liquidity position to the Central Bank in a form and manner prescribed by the Central Bank.

      Banks may also be required to provide the Central Bank with ad hoc reports on liquidity as and when requested to do so.