Managing Required Reserves Copyright 2014 by Diane Scott Docking 1 Reg D – Deposit Reporting Categories Deposit Reporting Categories, Sept 2014 – Sept 2015 Nonexempt Institutions Exempt Institutions (Detailed Reporting) (Reduced Reporting) Net transaction accts > Exemption amount1 OR Total deposits ≥ Reduced reporting limit2 Net transaction accts ≤ Exemption amount AND Total deposits < Reduced reporting limit Total deposits ≥ Nonexempt deposit cutoff3 Total deposits < Nonexempt deposit cutoff Total deposits > Exemption amount Total deposits ≤ Exemption amount Category 1 Category 2 Category 3 Category 4 • Weekly reports • FR2900 1 Exemption amount = $13.3 million as of 12/24/13 2 Reduced 3 • Quarterly reports • FR2900 • Annual reports • FR2910a each June 30 • No reports Reg D requirements effective through 12/31/15.html reporting limit = $1.719 billion as of 12/24/13 Nonexempt deposit cutoff = $ 306.7 million as of 12/24/13 Copyright 2014 by Diane Scott Docking 2 Reg D - Determining Legal Reserves Summary of Reg D Requirements (as of 11/5/13) is effective for maintenance period beginning 1/23/14: All depository institutions with reservable deposits above $13.3 million must file FR2900 This dollar cut-off is known as the “reserve requirement amount.” FR2900 must be filed weekly (Tues. – Mon.) by all commercial banks with total reservable deposits at or above $306.7 million. This dollar cut-off is known as the “ deposit cutoff level.” Copyright 2014 by Diane Scott Docking 3 . Reg D - Determining Legal Reserves (cont.) Summary of Reg D Requirements (cont.): The 2-Week “Reserve . period” goes from Tuesday to following second Monday (day 1 – 14) for transaction deposits and for or vault cash Look at deposit balances during this period on which to base reserve requirements Form FR2900.html Copyright 2014 by Diane Scott Docking 4 Reg D - Determining Legal Reserves (cont.) Summary of Reg D Requirements (cont.): “Reserve period” is 2 weeks and begins 30 days (on a Thursday) after the 1st Tuesday in the Reserve Computation period (days 31 – 44). Reserves include: vault cash, balances at Fed (Due from Fed) Copyright 2014 by Diane Scott Docking 5 Reserve Maintenance and Computation Periods Sun Mon 6 13 20 27 34 41 Tues 7 14 21 28 35 42 Wed Thurs 1 8 15 22 29 36 43 2 9 16 23 30 37 44 Fri 3 10 17 24 31 38 45 Sat 4 11 18 25 32 39 46 5 12 19 26 33 40 47 Lagged Reserve Computation Period: Used for computing required reserves on transaction deposits and vault cash (Days 1-14) (Use data from FR2900 #1 and #2) FR2900: #1 filed weekly for days: 1-7 #2 filed weekly for days: 8-14 Lagged Reserve Computation Period: Reserve Maintenance Period: 6 Copyright 2014 by Diane Scott Docking Reserve Maintenance and Computation Periods Oct 2014 Nov 2014 Sat Fri Thurs Wed Tues Mon Sun 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Sept 2014 Lagged Reserve Computation Period: Used for computing required reserves on transaction deposits and vault cash: (Days 1-14: Sept. 16, 2014 - Sept. 29, 2014) Reserve Maintenance Period: Used for computing Federal reserve balance available to meet required reserves (Days 31-44: Oct.16, 2014 - Oct. 29, 2014) 7 Copyright 2014 by Diane Scott Docking Reg D - Determining Legal Reserves (cont.) Summary of Reg D Requirements: No more carry overs. Two penalty free bands: If maintained balance at Fed is between bands, then in compliance If maintained balance at Fed > Top band, then have an “excess balance”. Top band = RBR + (maximum of $50,000 or 10% of RBR) Bottom band = RBR – (maximum of $50,000 or 10% of RBR) RBR = Reserve balance requirement Fed pays interest on average balance maintained at the Fed. If maintained balance at Fed < Bottom band, then have an “reserve deficiency amount”. Penalty of 1% + primary credit rate on the deficiency amount. Copyright 2014 by Diane Scott Docking 8 Legal Reserve Requirements Sec. 204.4 Reserve requirement ratios. (effective 8/20/14) The following reserve requirement ratios are prescribed for all depository institutions, banking Edge and agreement corporations, and United States branches and agencies of foreign banks: Category Reserve Requirement Net transaction accounts: $0 to $13.3 million 0 percent of amount. Over $13.3 million and up to $89.0 million 3 percent of amount Over $89.0 million $2,271,000 plus 10 percent of amount over $89.0 million. Nonpersonal time deposits 0 percent. Eurocurrency liabilities 0 percent $13.3 million is the exemption amount. $89.0 million is the amount of the low reserve tranche Copyright 2014 by Diane Scott Docking 9 Example in Appx 13 E: Calculating Reserve Requirement CALCULATING RESERVE REQUIREMENTS FOR COMMERCIAL BANKS (Total Net Transaction Deposits = $1,350.70 million) Table in text redone with current regs Type of Deposit and Deposit Interval Average Dollar Amount (in millions) in Computation Period Percentage Reserve Requirement Average Dollar Reserves Required (in millions) in Maintenance Period Net transactions accounts: Exempt up to $13.3 mill. $ 13.3 0% $ 0.0 Over $13.3 up to $89.0 mill. $ 75.7 3% $ 2.271 Over $89.0 million $1,261.70 10% $126.170 Total $1,350.70 Gross reserves requirement $128.441 Less vault cash ( 25.357 ) Reserve balance requirement (RBR) $103.084 * The first $13.3 million of transactions accounts are exempt from reserve requirements. This cutoff and the 3% reserve requirement cutoff are amended by the Federal Reserve System from time to time. For an update, see http://www.federalreserve.gov/newsevents.htm. Copyright 2014 by Diane Scott Docking 10 Example in Appx 13 E: Calculating Reserve Requirement (cont.) The following information is available: Reserve Balances at Fed During Maintance Period (in m illions) Reserve Balances for: Day Closing Date Bal. w / Fed Thurs. 30-Jul-13 $ Fri. 31-Jul-13 100 Sat. 01-Aug-13 100 Sun. 02-Aug-13 100 Mon. 03-Aug-13 98 Tues. 04-Aug-13 91 Wed. 05-Aug-13 102 Thurs. 06-Aug-13 101 Fri. 07-Aug-13 99 Sat. 08-Aug-13 99 Sun. 09-Jan-00 99 Mon. 10-Aug-13 107 Tues. 11-Aug-13 154 Wed. 12-Aug-13 129.140 Total 14 = DAB Copyright 2014 by Diane Scott Docking (in millions) RBR $103.084 Top penalty-free band $113.3924* Bottom penalty-free band $92.7756** 98 DAB at Fed during reserve mtnce period $105.510 Balance maintained to satisfy RBR $105.510 Excess balance $ - Reserve deficiency amount $ - *103.084 + (.1 x 103.084) = 103.084 + 10.3084 = $113.3924 **103.084 - (.1 x 103.084) = 103.084 -10.3084 = $92.7756 1,477.140 $ 105.510 11 Example: Calculating Reserve Requirement At the close of Business on Tuesday, October 28, 2014, Garden National Bank is concerned if it will meet its legal reserve requirements. The following information is available: Daily Average Balances during 2-week Reserve Computation period from September 16 – 29, 2014 (in thousands): Gross Transaction accounts $416,500 Demand deposits due from U.S. depository institutions 15,145 Cash items in the process of collection 5,600 Vault cash 3,552 Copyright 2014 by Diane Scott Docking 12 Example: Calculating Reserve Requirement (cont.) The following information is available: Reserve Balances at Fed During Maintance Period (in thousands) Reserve Balances for: Day Closing Date Bal. w / Fed Thurs. 16-Oct-14 $ 25,000 Fri. 17-Oct-14 22,500 Sat. 18-Oct-14 22,500 Sun. 19-Oct-14 22,500 Mon. 20-Oct-14 14,000 Tues. 21-Oct-14 16,000 Wed. 22-Oct-14 38,000 Thurs. 23-Oct-14 36,320 Fri. 24-Oct-14 28,000 Sat. 25-Oct-14 28,000 Sun. 26-Oct-14 28,000 Mon. 27-Oct-14 32,560 Tues. 28-Oct-14 29,901 Wed. 29-Oct-14 Copyright 2014 by Diane Scott Docking Total $ 343,281 14 = DAB to date $ 24,520.07 13 Example: Calculating Reserve Requirement (cont.) Answer the following questions: 1) 2) 3) 4) 5) What is the amount of Net transaction accounts? What is the Gross reserve requirement? What is the Reserve Balance Requirement? As of close of day on Tuesday, October 28, 2014, is the Bank over- or under-reserved? By how much? If the bank is under-reserved, what must it do to remedy the situation on Wednesday, October 29, 2014 to avoid any penalties? Copyright 2014 by Diane Scott Docking 14 Solution to Example: Calculating Reserve Requirement 1) What is the amount of Net transaction accounts? SECTION 2: NET TRANSACTION ACCOUNTS FR 2900 Item s (in thousands) A.3 Total transaction accounts (1) 14-day average (2) A. Gross transaction accounts 416,500 + AA.1Ineligible acceptances and obligations issued by affiliates maturing in less than 7 days = 416,500 Net transaction accounts 0 _ Deductions B.1 Demand balances due from depository institutions in the U.S. B. Total deductions 15,145 + B.2 CIPC (3) = 20,745 5,600 Copyright 2014 by Diane Scott Docking 15 = 395,755 (If negative, set to zero) $395,755,000 or $395.755 million Solution to Example: Calculating Reserve Requirement (cont.) 2) 3) What is the Gross reserve requirement? What is the Reserve Balance Requirement? Type of Deposit and Deposit Interval Average Dollar Amount (in millions) in Computation Period Percentage Reserve Requirement Average Dollar Reserves Required (in millions) in Maintenance Period Net transactions accounts: Exempt up to $13.3 mill. $ 13.300 0% $ 0.0 Over $13.3 up to $89.0 mill. $ 75.700 3% $ 2.271 Over $89.0 million $306.755 10% $30.6755 Total $395.755 Gross reserves requirement $32.9465 Less vault cash ( 3.5520 ) Reserve Balance Requirement Copyright 2014 by Diane Scott Docking $29.3945 16 Solution to Example: Calculating Reserve Requirement (cont.) 4) As of close of day on Tuesday, October 28, 2014, is the Bank over- or underreserved? By how much? (in thousands) RBR Top penalty-free band Bottom penalty-free band $29,394.50 $32,333.95 $26,455.05 DAB at Fed during reserve mtnce period $24,520.07 Balance maintained to satisfy RBR Excess balance Reserve deficiency amount $24,520.07 $ $1,934.98 10% of RBR = Bank has a reserve deficiency of $1,934,980 Copyright 2014 by Diane Scott Docking 17 $2,939.45 > $50,000 Solution to Example: Calculating Reserve Requirement (cont.) 5) If the bank is under-reserved, what must it do to remedy the situation on Wednesday, November 27,2013 to avoid any penalties? • Bank must borrow enough money on Wednesday to bring the closing balance at the Fed on Wednesday = , which will give the bank a DAB at the Fed over the 14 –day maintenance period = $26,455.05 (in thousands), the bottom penalty-free band. • Can use SOLVER or GOAL SEEK in Excel to do this. (See next slide) Copyright 2014 by Diane Scott Docking 18 Solution to Example: Calculating Reserve Requirement (cont.) Reserve Balances at Fed During Maintance Period Reserve Balances at Fed During Maintance Period (in thousands) Reserve Balances for: Day (in thousands) Closing Date Reserve Balances for: Bal. w/ Fed Day Closing Date Bal. w / Fed Thurs. 16-Oct-14 $ 25,000 Thurs. 16-Oct-14 $ 25,000 Fri. 17-Oct-14 22,500 Fri. 17-Oct-14 22,500 Sat. 18-Oct-14 22,500 Sat. 18-Oct-14 22,500 Sun. 19-Oct-14 22,500 Sun. 19-Oct-14 22,500 Mon. 20-Oct-14 14,000 Mon. 20-Oct-14 14,000 Tues. 21-Oct-14 16,000 Tues. 21-Oct-14 16,000 Wed. 22-Oct-14 38,000 Wed. 22-Oct-14 38,000 Thurs. 23-Oct-14 36,320 Thurs. 23-Oct-14 36,320 Fri. 24-Oct-14 28,000 Fri. 24-Oct-14 28,000 Sat. 25-Oct-14 28,000 Sat. 25-Oct-14 28,000 Sun. 26-Oct-14 28,000 Sun. 26-Oct-14 28,000 Mon. 27-Oct-14 32,560 Mon. 27-Oct-14 32,560 Tues. 28-Oct-14 29,901 Tues. 28-Oct-14 29,901 Wed. 29-Oct-14 Wed. 29-Oct-14 27,090 Total $ 343,281 14 = DAB to date $ 24,520.07 Total $ 370,371 14 = DAB to date $ 26,455.05 use solver or goal Bottom penalty-free band $26,455.05 Copyright 2014 by Diane Scott Docking seek to equate use solver or goal Bottom penalty-free band $26,455.05 seek to equate 19