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Funds Transfer Pricing
In this letter we report on a thematic review on funds transfer pricing (FTP),
undertaken by our Prudential Risk Division as part of our ongoing work on liquidity,
and explain the importance for firms of focussing on this area as part of the
preparation for their Individual Liquidity Adequacy Assessment (ILAA).
We assessed funds transfer pricing (FTP) practices at eleven firms in the banking,
investment banking and building society sectors, the smallest of which has a balance
sheet of less than £5bn. The need for the pricing of liquidity risk is set out in BIPRU
12.3.15 and this review yielded insights into current state and future development of
firms’ FTP processes.
Liquidity stresses are low frequency, but extreme severity events, which firms have
historically neglected, in the interests of shortrun efficiencies. We aim to reduce
risks to the UK financial system by encouraging more resilient, sustainable business
models.
The key messages for senior management are set out in the main body of this letter.
In the appendix we provide a fuller discussion as well as examples of what we
observed to be good and poor practice. We suggest that you review the development
of your FTP processes and use the good practice set out in this letter to guide your
work.
For the avoidance of doubt, our thematic review covered FTP practices pertaining to
liquidity and asset liability management (ALM) risk. It does not address other
common uses of FTP, for instance fixed cost contribution accounting, taxation and
credit and operational risk pricing.
Background
The importance of pricing liquidity risk derives from our Principles for Businesses 3:
'a firm must take reasonable care to organise and control its affairs responsibly and
effectively, with adequate risk management systems'.
We therefore set out in BIPRU 12.3.15 an evidential provision for firms accurately to
quantify the liquidity costs, benefits and risks in relation to all significant business
activities – whether or not they are accounted for onbalance sheet – and to
incorporate them in their (i) product pricing; (ii) performance measurement; and (iii)
approval process for new products. The quantification of costs, benefits and risks
should include consideration of how liquidity would be affected under stressed
conditions as set out in BIPRU 12.4. Firms should ensure that identified costs,
benefits and risks identified are explicitly and clearly attributed to business lines and
are understood by business line management.
1
This mirrors Principle 4 of the Basel Principles for Sound Liquidity Risk Management
and Supervision 1 . Effective FTP processes serve to align the risktaking incentives of
individual business lines, with the liquidity risk exposures their activities create for
the firm as a whole.
The pricing of liquidity risk is also now the focus of EU attention. Pursuant to
amendments to Annex V of the CRD in September 2009, the Committee of European
Banking Supervisors (CEBS) published Draft Guidelines on Liquidity Cost Benefit
Allocation 2 in March 2010, for public consultation.
FTP is thus a regulatory requirement and an important tool in the management of
firms’ balance sheet structure, and in the measurement of riskadjusted profitability
and liquidity and ALM risk. By attributing the cost, benefits and risks of liquidity to
business lines within a firm, the FTP process strongly influences the volume and
terms upon which business lines trade in the market and promotes more resilient,
sustainable business models.
Conversely, failure adequately to apply FTP processes risks misaligning the risk
taking incentives of individual business lines and misallocating finite liquidity
resource and capital within the firm as a whole. This can manifest itself in the conduct
of lossmaking business or in business where rewards are not commensurate with risk
taken, and thereby ultimately undermines sustainable business models. Examples
include entering into excessive offbalance sheet contingent commitments and
excessive onbalance sheet asset growth due to the inaccurate pricing of the costs,
benefits and risks of liquidity.
Findings
A key message emerging from this review is that, whilst firms are making progress in
addressing FTP shortcomings, there is still more to do before FTP is effectively
utilised to drive business strategy in line with firmwide objectives. This letter is
designed to help you by comparing approaches and pointing out some of the
techniques which we consider sound practice, and some of those we consider to be
poor practice.
Broadly speaking we found that some firms in our sample had practices that to
varying degrees constituted an effective FTP process. However in significant respects,
in our judgement and based on the information received mostly during September
2009, virtually all firms fell short of FTP requirements laid out in BIPRU 12.3 and
12.4. One firm did not acknowledge a FTP process or the need for one. Most firms
were developing and improving their practices. A small number were weak in
virtually all respects.
1
http://www.bis.org/publ/bcbs144.pdf?noframes=1
2
http://www.cebs.org/documents/Publications/Consultationpapers/2010/CP36/CP36.aspx
2
As we have said, we think that it is important for firms to have effective FTP
processes to manage balance sheet structure, riskadjusted profitability and liquidity
and ALM risk. We therefore require firms to put these in place so that business
incentives are aligned with overall strategic objectives and that management has all
the appropriate information at its disposal when making strategic and risk
management decisions.
Good practice was most in evidence in firms where senior management took a direct
interest in their firm's FTP regime, with a view to harnessing it to achieve strategic
objectives.
Our future work on FTP will focus on compliance by individual firms with BIPRU
12.3 and 12.4 requirements. You should be able to explain your approach to FTP as
part of your ILAA; as you know, we will begin our programme of reviewing firms’
ILAAs from 1 June 2010. The contents of this letter should help you meet our
expectations.
Our evaluation of your FTP processes will help us form a view of the risks facing
your firm, and will be reflected in your Individual Liquidity Guidance (ILG) and
ARROW Risk Mitigation Programmes.
If you or others in your firm wish to discuss the matters raised in this letter, please
contact your FSA Relationship Manager in the first instance.
Yours faithfully
[cc: CFO
: Other firms in the UK DLG if applicable]
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APPENDIX – DISCUSSION OF OBSERVATIONS
Executive Summary
Liquidity stresses are low frequency, but extreme severity events, which firms have
historically neglected, in the interests of shortrun efficiencies. Events over the last 32
months have exposed this vulnerability in many firms, such that almost all firms
surveyed have internal initiatives to improve their liquidity risk management regimes,
including FTP. Indeed PS09/16 makes reference to the aforementioned shortcomings
and to the need for effective FTP in Systems & Controls Requirements in BIPRU 12.3
and 12.4. Furthermore working groups at CEBS and Basel are considering FTP in the
context of liquidity.
We believe that the use of effective FTP processes by firms has the potential to reduce
risks to the UK financial system by encouraging more resilient, sustainable business
models.
Below are the key conclusions from our work.
· P&L attribution
Many firms did not attribute some elements of the costs, benefits and risks of liquidity
to business lines, instead holding costs at the centre. This acted to blunt the signalling
of the same to business lines and thus compromised incentives and the progression of
strategic objectives.
· FTP granularity
Of the costs, benefits and risks that were attributed, most firms did not apply FTP to a
sufficiently granular level to effectively incentivise business transaction decision
makers. This was observed both in the attribution of centrally generated funding costs
and of the cost of holding liquid asset buffers. This again acted to blunt the signalling
of costs, benefits and risks of liquidity to business lines.
· FTP consistency
Most firms did not apply consistent FTP methodologies across constituent businesses.
Therefore an asset, liability or off balance sheet risk could be priced differently,
simply on the basis of where it arose in the firm. In turn this skewed business
incentives and behaviours to the detriment of the overall firm. In addition, this could
convey confusing signals to the market, which in turn would harm the firm’s
franchise.
· Responsiveness of FTP
Many firms relied on offline systems requiring manual intervention or simplistic
assumptions in order to implement their FTP regime. Offline processes make the
FTP system less amenable to effective oversight and less responsive in volatile
markets, due to the time taken to generate information manually. This heightened the
risk of inaccurate pricing of liquidity and weakened the signalling of the costs,
benefits and risks of liquidity to business lines and the FTP regime’s impact on
business line behaviours.
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· FTP as a business signalling and strategic tool
Many firms charged FTP by reference to the weighted average cost of funding already
on balance sheet or weighted average cost of funding projected in annual budgetary
processes. There was no additional overlay allowing senior management to adjust
FTP rates to incentivise or discourage particular business activities based on a forward
looking management view or in response to current inventory or risk levels.
Furthermore, there was no consideration regarding the marginal cost of funding for
the firm when appropriate. The cost was expressed as a reference rate + spread, which
was then applied to business line balance sheets. Attribution did not differentiate
between long and short dated balance sheet items.
These features risked mispricing liquidity, particularly in volatile markets, leaving
firms vulnerable to conditions witnessed in the past two years. Effective use of FTP as
a business signalling and strategic tool was most in evidence in firms where senior
management took a direct interest in their firm's FTP processes, with a view to
harnessing it to further strategic objectives.
Furthermore the use of a weighted averaging methodology applied to business line
balance sheets, irrespective of duration, entailed the cross subsidisation of longer
dated risk at the expense of shorter dated risk, since the weighted average cost did not
discriminate between these. All other things being equal, longer dated assets present
greater risk than short dated assets, yet the weighted averaging methodology makes
no distinction between them. This therefore has the potential to skew business
incentives and behaviours to the detriment of the overall firm.
· Stress testing processes and off balance sheet risk
Some firms either did not price all undrawn off balance sheet contingent commitment
types to which they were exposed, or else applied unsubstantiated charges to them.
Therefore, business lines risked writing options for customers at levels where the risk
was not commensurate with rewards, skewing business incentives and behaviours to
the detriment of the overall firm. This was at least in part borne out of: the lack of
comprehensive stress and scenario testing to inform risk appetite for undrawn off
balance sheet commitments; and an ad hoc approach to reviews of behavioural
models.
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Discussion
In this survey we reviewed the FTP practices at 11 firms in the banking, building
society and investment banking sectors, yielding up the following salient
observations:
Organisational characteristics
All the firms except 1 had a FTP regime in place, operated by a central treasury area
under the oversight of ALCO or similar oversight committee.
The larger and more complex banks and investment banks in the survey organised
centralised funding out of a central treasury area for longer dated unsecured term debt,
with secured and shortdated unsecured funding sourced from funding desks sited in
their investment banking arms.
In 9 of the firms surveyed FTP rates were published to communicate the costs,
benefits and risks of liquidity to transactional decision makers.
Given that 1 firm had no FTP regime in place, the remainder of this discussion will
focus on the salient features of the other 10 firms surveyed.
FTP inconsistency across Group
Of the firms surveyed, only 4 applied FTP consistently across the group. Of the
remaining 6 firms:
· 2 had differing regimes due to recent merger activity and were in the process
of integrating these into a common approach;
· 1 did not apply FTP to a significant business unit within the group; and
· 3 had historically applied differing regimes across the group
Therefore an asset, liability or off balance sheet risk could be subject to nonuniform,
diverging treatment, simply on the basis of where it arose in the firm. In turn, this
skewed business incentives and behaviours to the detriment of the firm overall. In
addition, this could convey confusing signals to the market, in turn harming the
firm’s franchise.
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Responsiveness of FTP
Of the firms surveyed, 5 charged FTP by reference to the weighted average cost of
funding either already on balance sheet or projected in an annual budget process. This
cost was expressed as a reference rate plus spread, which was then applied to business
line balance sheets, irrespective of duration. This methodology in isolation lacks
sufficient flexibility for the FTP framework to be used to incentivise or discourage
business behaviour and appropriately charge for the duration of risk. This was
demonstrated in some cases in 2007 with the buildup of large inventory positions in
certain asset classes, where returns were not commensurate with risk taken, and in the
onset of volatile conditions where marginal costs rose sharply and the FTP regime did
not appropriately reflect market conditions to business lines.
In one case a firm charged FTP with reference to the marginal cost of funding but, as
above, expressed this as a weighted average reference rate plus spread, for application
to business line balance sheets. Whilst this captures marginal cost of funding for
marginal assets, this methodology nonetheless entails cross subsidisation of longer
dated risk at the expense of shorter dated risk, as discussed above.
A further firm applied FTP with reference to the marginal cost of funding only in its
investment banking arm, with the rest of the group referencing the projected weighted
average cost of funding.
Therefore, these techniques skewed business incentives and behaviours to the
detriment of the overall firm and, indeed, during the market dislocations many of
these firms had to formally revisit their FTP rates in order to reflect new market
realities to business lines.
Risk handovers & attribution
Of the firms surveyed:
· 1 attributed prepayment risk to central treasury
· 2 attributed basis risk, which was not readily hedgeable, to central treasury
· 1 attributed the cost of carry of the liquidity buffer to central treasury, while 1
performed partial attribution of the liquidity buffer cost of carry
The holding of risk generated by business lines at the centre, together with its
associated earnings impact, served to blunt the communication of the costs, benefits
and risks of liquidity to business lines which in turn compromised the FTP regime’s
impact on business line behaviours and the furtherance of strategic objectives.
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Granularity
Of the firms surveyed, 3 attributed cost of debt and funding to business unit, sector or
divisional level. Similarly 4 firms attributed liquid asset buffer carry costs in respect
of contingent commitments and maturity transformation opportunity costs to business
unit, cluster, and segment or sector level. In our view these levels of granularity are
insufficient to properly incentivise business line behaviours. A further firm was
enhancing deposit granularity by creating vintage views so as to improve the efficacy
of behavioural modelling of deposits.
Stress testing and contingent commitments
Of the firms surveyed, 1 did not perform stress testing to inform contingent
commitment risk appetite or to size liquid asset buffer held for undrawn contingent
commitment exposures. A further firm only had ad hoc stress testing processes,
engendering the risk that the FTP regime was calibrated to an inaccurate assessment
of firm risk appetite. The firm in question had plans to address this shortcoming. 4
firms performed stress testing but this analysis did not address all contingent
commitment types to which the firms were exposed or else applied tariffs which were
not anchored in any underlying scenario analysis – charges levied lacked
substantiation. Therefore there was a risk that contingent commitment exposures were
incorrectly priced, misincentivising business line behaviours.
Behavioural modelling
Of the firms surveyed, 1 conducted no modelling of open maturity flows and
contingent commitments, compromising the accuracy of its FTP. This was
compensated for in the case of contingent commitments by the allocation of capital to
100% of undrawn balances. In addition 4 firms back tested behavioural models only
on an ad hoc basis. This engendered the risk that behavioural models were not
calibrated to market conditions on an ongoing basis, undermining the accurate
application of FTP rates to open maturity flows and contingent commitments. By way
of example, such behavioural model weakness could undermine the ability of a firm
to discriminate between volatile and sticky retail funding balances, and result in
inadequate incentives to business lines for stable funding generation.
Offline systems
Of the firms surveyed, 5 by their own admission relied excessively on offline
infrastructure for the functioning of FTP. This renders the regime vulnerable to
human error and weakens the signalling of costs, benefits and risks of liquidity to
business line transaction decisionmakers. In addition, offline processes make the
FTP system less amenable to effective oversight and less responsive in volatile
markets, due to the time taken to generate information manually.
Funding incentives
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Trading book approaches for stale or illiquid assets
Of the firms surveyed, 1 did not have mechanisms in place to reflect the opportunity
cost of holding stale or illiquid assets on the trading book to business line
transactional decisionmakers. However, this firm did have plans to enhance its funds
transfer pricing regime with an aged inventory management process. Moreover 1 firm
had no trading book and a further firm had small trading asset holdings which were
treated in the same fashion as banking book holdings. Of the remaining firms,
practices split into two broad categories. 4 firms used a cash capital methodology
where haircuts reflecting inherent liquidity of asset classes are applied to the firm’s
assets. The haircut is then charged at an unsecured cash capital rate (usually a blended
unsecured long term funding rate), whilst the rest of the asset is charged at secured
funding rates. 3 firms monitored trading inventory ageing and applied an aged
inventory charge for assets ageing beyond a certain timeframe.
New business
Of the firms surveyed, 8 formally mandated FTP sign off for new business approvals.
For 2 firms this process was informal and could benefit from a more explicit policy
framework, empowering treasury input in new business approvals.
Gaming and arbitrage
Of the firms surveyed, 3 appeared to maintain FTP regimes vulnerable to gaming and
arbitrage. 1 paid an elevated overnight rate for deposits, risking the rewarding of “hot
money” balances as well as stable funding. The rate curve for another firm exhibited a
sharp jump between time buckets, in turn encouraging the bunching of business on the
cusp of the jump in rates. This acted to skew business incentives and suggested that
time buckets should have greater granularity. A further firm used multiple curves and
fragmented pricing for FTP such that it had a heightened risk of pricing inconsistency
and gaming of the system to the detriment of the overall group.
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