ABA Toolbox on Liquidity Appendix A CFP Stress Testing Assumptions and Results The purpose of a stress test is to evaluate the potential effect of liquidity stress events on a financial institution’s ability to fund its balance sheet. XYZ management has elected to run a short-term and longterm stress test on its business plan. The stress test is made up of the following key component parts. Base Business Plan Cash Flow Analysis This analysis evaluates the cash flow impact of the XYZ business plan on available liquidity as measured by the 1 year Cumulative Liquidity Gap/Asset Ratio. The business plan being evaluated is the XYZ business plan beginning as of 12/31/2009 and extending out over a three year horizon. Stress Tests The tests include the following: o The Base Business Plan Cash Flow Analysis is stressed by modifying cash flows based on a scenario where XYZ fails PCA well-capitalized standards. The purpose of this test is to determine whether XYZ has sufficient sources of liquidity to meet funding outflow needs caused by this stress. In addition, the objective is to develop a sequence of steps that would be taken by XYZ to meet cash flow needs. o A liquidity coverage ratio (LCR) test is run on the beginning balance sheet to determine whether sufficient asset-based liquidity existed to cover stressed funding outflows. That same test may also be run on the balance sheet that exists one year into the plan to determine whether the plan has an undesirable adverse effect on asset-based liquidity. Base Business Plan Sources and Uses and Twelve-Month Liquidity Gap/Assets Ratio The business plan was developed by XYZ management to be used in setting performance targets and evaluating continuing performance for the next year. While the plan looks forward three years, it is a rolling plan that is updated on an annual basis. Years 1 and 2 of each plan forecast are used to evaluate longer term effects of the plan being placed into execution from the standpoint of financial performance, interest rate risk analysis, capital planning, and liquidity risk analysis. All three years of the plan are designed to move XYZ in the direction of the strategic financial goals set in its capital planning process by attempting to reach the annual goals laid out in the capital plan. XYZ set goals to move investments from 6.5% to 9.0% of assets in Year 1 of the plan. That means the business plan will need to incorporate levels of investment purchases sufficient to cover cash flows from the investment portfolio in Year 1, plus those investment purchases needed to reach the investment portfolio mix goals set forth in the business plan. As a result, uses of funds for investments (purchases) would exceed sources (maturities and cash flows) by an amount sufficient to reach the investment goals at the end of Year 1. Figure 1 shows that XYZ plans to grow highly liquid unencumbered marketable (HLUM) securities in its investment portfolio by $2 million in the first quarter of its business plan, another $4 million in the second quarter, an additional $5 million in the 5th quarter and a final $4 million in the 9th quarter of the plan. ABA Toolbox on Liquidity – Appendix A | 1 Figure 1 Liquidity Report Total Investments Inflow Outflow Net Cumulative by Year Total Loans Inflow Outflow Net Cumulative by Year Non-Earning Assets Inflow Outflow Net Cumulative by Year TOTAL ASSETS Inflow Outflow Net Cumulative by Year Mar-2010 (Q) Jun-2010 (Q) Sep-2010 (Q) 611,942 2,611,942 (2,000,000) 2,695,965 6,695,965 (4,000,000) 892,971 892,971 (0) 33,917,376 25,564,993 8,352,383 33,653,818 26,371,358 7,282,460 18,610,665 11,544,495 7,066,170 610,318 610,318 857,362 857,362 1,374,288 1,374,288 35,139,636 28,176,935 6,962,701 37,207,145 33,067,323 4,139,822 20,877,923 12,437,466 8,440,458 XYZ Bank Forecast Cash Flow Liquidity Report - Assets Base Forecast - Capital Plan [Flat rates] Dec-2010 (Q) Mar-2011 (Q) Jun-2011 (Q) Sep-2011 (Q) (Dollars in Thousands) 1,011,679 1,227,006 1,295,368 1,412,701 1,011,679 6,227,006 1,295,368 1,412,701 0 (5,000,000) (0) (0) (6,000,000) 28,752,329 28,178,424 35,243,455 19,636,360 21,896,029 25,946,004 33,033,285 17,448,220 6,856,300 2,232,420 2,210,170 2,188,140 29,557,314 1,426,105 1,450,984 1,461,973 1,515,049 271,115 432,221 455,510 520,526 1,154,990 1,018,763 1,006,463 994,523 3,996,957 31,190,113 30,856,414 38,000,796 22,564,110 23,178,822 32,605,231 34,784,163 19,381,447 8,011,290 (1,748,817) 3,216,633 3,182,663 27,554,271 Dec-2011 (Q) 1,453,797 1,453,797 0 (5,000,000) 31,910,144 29,743,814 2,166,330 8,797,060 1,573,471 590,538 982,934 4,002,682 34,937,412 31,788,148 3,149,264 7,799,742 Mar-2012 (Q) Jun-2012 (Q) Sep-2012 (Q) 1,565,805 5,565,805 (4,000,000) 1,741,536 1,741,536 0 1,782,416 1,782,416 (0) 32,384,283 35,166,466 (1,077,740) 34,078,720 36,517,452 (1,083,150) 20,069,053 21,567,195 (1,088,570) 699,924 699,924 784,964 63,436 721,528 812,529 108,407 704,122 34,650,012 40,732,271 (4,377,815) 36,605,220 38,322,424 (361,622) 22,663,998 23,458,018 (384,448) Dec-2012 (Q) 1,754,762 1,754,762 (0) (4,000,000) 27,066,217 28,712,610 (1,094,020) (4,343,480) 804,093 104,266 699,827 2,825,401 29,625,072 30,571,639 (394,194) (5,518,078) XYZ’s capital plan calls for it to reduce the size of the loan portfolio by 12% in 2010. That means that in 2010, cash flows from the loan portfolio (liability sources) should exceed loan originations (liability uses) by an amount sufficient to reduce the loan portfolio by 12%. Cumulative loan sources exceed uses by $29.6 million in Year 1 of the plan, and another $8.8 million in Year 2. The major portion of the loan portfolio reduction is used to build HLUM securities in the investment portfolio and to shrink assets, which drop from $300 million to $271 million by the end of the 8th quarter of the plan. On the other hand, in the last four quarters of the plan, loans on a net basis turn into a use of funds, exceeding sources by $4.3 million. It is in Year 3 that loan growth goes from negative to positive as called for in the capital plan. Non-earning assets that accumulate as a result of XYZ’s asset quality problem are converted back to earning assets under its plan. In Figure 1, non-earning assets as a source of funds start in the range of $4 million per year in the first two years of the plan and decrease to $3 million in Year 3. Overall, asset sources exceed asset uses by $27.6 million in 2010 and $7.8 million in 2011, providing the cash to retire liabilities, which will allow XYZ to shrink its balance sheet. In 2012, asset sources fall short of asset uses of funds by $5.5 million, the difference driving the growth of the asset side of the balance sheet. The analysis of the asset side of the balance sheet fails to consider changes in overnight investments and cash and due. They will be taken into consideration a bit later. On the funding side of its balance sheet, as part of its capital plan, XYZ set a number of goals. One of the goals was to grow Core Funding by 2% in 2010, followed with a 5% growth in 2011 and a 7% growth in 2012. At the same time, XYZ planned to reduce its reliance on Near-Core and Non-Core Funding from its current 35.9% level to 28.4% in 2010, 23.3% in 2011, and 20.1% in 2012. That reduction is consistent with its Near-Core and Non-Core Funding plan which sets the goal to reach a position where approximately half of its Near-Core and Non-Core Funding limit is utilized as part of its base business strategy with the other half available as a source of funding to deal with liquidity stress events. Customer deposits remain relatively flat in the first year of the forecast, increasing from $582 to $583 million in the first 12 months of the plan (Non-Core plus Near-Core). From that point, deposits grow, reaching $618 million by the end of the plan. Deposit sources and uses of funds for the first 8 quarters are shown in Figure 2. ABA Toolbox on Liquidity – Appendix A | 2 Figure 2 Liquidity Report Mar-2010 (Q) Jun-2010 (Q) Sep-2010 (Q) Core Funding Inflow Outflow Net Cumulative by Year Near-Core Funding Inflow Outflow Net Cumulative by Year Non-Core Funding Inflow Outflow Net Cumulative by Year Other Liab Inflow Outflow Net Cumulative by Year Capital Inflow Outflow Net 16,597,475 15,771,201 826,274 29,179,130 28,348,719 830,412 23,759,908 22,925,338 834,571 Total Liab & Capital Inflow Outflow Net 1,313,659 1,699,948 (386,289) 5,420,518 6,583,405 (1,162,887) 2,053,506 2,749,961 (696,454) 6,966,473 8,907,026 (1,940,554) 14,384,826 23,889,231 (9,504,405) 10,158,890 13,130,896 (2,972,007) 9,776 (9,776) 13,909 (13,909) 13,909 (13,909) 689,653 (689,653) 752,928 (752,928) 826,644 (826,644) 24,877,606 27,077,605 (2,199,999) 48,984,475 59,588,192 (10,603,717) 35,972,305 39,646,748 (3,674,443) XYZ Bank Forecast Cash Flow Liquidity Report - Liabilities & Capital Base Forecast - Capital Plan [Flat rates] Dec-2010 (Q) Mar-2011 (Q) Jun-2011 (Q) Sep-2011 (Q) (Dollars in Thousands) 15,539,710 14,700,959 838,751 3,330,007 2,266,005 2,809,915 (543,909) (2,789,540) 5,631,989 10,888,153 (5,256,164) (19,673,130) 13,909 (13,909) (51,503) 841,560 (841,560) (3,110,785) 23,437,704 29,254,496 (5,816,792) (22,294,951) 20,064,158 17,526,869 2,537,288 32,453,485 29,877,947 2,575,538 33,933,798 31,319,433 2,614,365 1,403,900 1,754,597 (350,697) 3,051,534 5,172,609 (2,121,075) 5,482,753 5,862,276 (379,523) 10,285,272 14,846,947 (4,561,675) 8,938,388 11,530,583 (2,592,195) 8,616,906 10,178,962 (1,562,056) 4,000 (4,000) 4,000 (4,000) 4,000 (4,000) 235,456 (235,456) 291,715 (291,715) 132,162 (132,162) 31,753,329 34,367,869 (2,614,540) 44,443,407 46,876,854 (2,433,448) 48,033,457 47,496,833 536,624 Dec-2011 (Q) 17,495,182 14,841,405 2,653,777 10,380,968 1,944,750 2,225,447 (280,697) (3,131,992) 5,007,097 9,402,255 (4,395,158) (13,111,084) 4,000 (4,000) (16,000) 124,553 (124,553) (783,887) 24,447,029 26,597,660 (2,150,632) (6,661,995) Mar-2012 (Q) Jun-2012 (Q) Sep-2012 (Q) 22,013,301 18,415,611 3,597,690 29,415,857 25,745,732 3,670,124 33,985,467 30,241,449 3,744,017 879,334 1,159,084 (279,750) 1,422,385 1,570,289 (147,904) 3,894,445 4,599,058 (704,614) 12,197,125 13,703,538 (1,506,413) 11,447,464 13,145,813 (1,698,349) 11,895,453 13,088,302 (1,192,849) 3,000 3,000 3,000 3,000 3,000 3,000 156,008 156,008 135,470 135,470 351,707 351,707 35,248,767 33,278,233 1,970,534 42,424,175 40,461,834 1,962,341 50,130,071 47,928,810 2,201,262 Dec-2012 (Q) 21,379,209 17,559,811 3,819,398 14,831,230 1,799,676 1,981,692 (182,016) (1,314,284) 3,396,590 4,187,499 (790,909) (5,188,520) 3,000 3,000 12,000 235,680 182,552 53,128 696,313 26,814,155 23,911,554 2,902,602 9,036,738 Non-core funding shrinks by $19.6 million in the first year, $13.1 million in the second year, and $5.2 million of the third year of the plan as a result of deposit growth and asset reductions being used to pay off maturing FHLB Advances and brokered CDs. On an overall basis, Figure 2 shows that the business plan reduces XYZ’s liability and capital funding by $22.3 million in 2010 (a net use of funds), and $6.7 million in 2011. Once the growth rate turns around in 2012, the liability and capital side of the XYZ balance sheet becomes a net source of funds of $9.0 million, providing the funding to grow the XYZ balance sheet. Note that any overnight borrowings on the balance sheet are ignored in Figure 2. The top portion of Figure 3 looks at the net cash flows coming from the balance sheet, ignoring cash and due from, overnight investments, and overnight borrowings. Totals appear on the top line of Figure 3. Line 2 shows the sources on a cumulative basis. Uses of funds (asset and liability sources) are summed and appear on Line 3 of the analysis. Cumulative uses of funds appear on Line 4. Sources are subtracted from uses on Line 5, which shows the cash flow surplus or deficit for the quarter. Cash flow surpluses or deficits are shown on a cumulative basis on Line 6. XYZ shows a cumulative cash flow surplus (sources less uses) of $5.89 million over the three years of its business plan. Figure 3 Liquidity Report Mar-2010 (Q) XYZ Bank Forecast Cash Flow Liquidity Report - Liquidity Gaps and Ratios Base Forecast - Capital Plan [Flat rates] Jun-2010 (Q) Sep-2010 (Q) Dec-2010 (Q) Mar-2011 (Q) Jun-2011 (Q) Sep-2011 (Q) (Dollars in Thousands) 86,191,620 56,850,228 54,627,817 62,609,744 82,444,203 70,597,567 146,208,862 203,059,090 257,686,908 320,296,651 402,740,854 473,338,421 92,655,515 52,084,214 52,433,319 66,973,100 81,661,017 66,878,280 147,910,055 199,994,268 252,427,587 319,400,688 401,061,705 467,939,985 (6,463,894) 4,766,014 2,194,498 (4,363,357) 783,185 3,719,287 (1,701,193) 3,064,822 5,259,320 895,964 1,679,149 5,398,436 Total Inflows Cumulative Inflows Total Outflows Cumulative Outflows Cash Flow Surplus (Deficit) Cum Cash Flow Surplus (Deficit) 60,017,242 60,017,242 55,254,540 55,254,540 4,762,702 4,762,702 Total Inflows Change in Overnight Position Avail HLUM Sec, Cash, Overnite Unused Borrowing Capacity Total Available for Liquidity Total Outflows Total Liquidity Gap Total Liquidity Sources/Uses Total Liquidity Gap/Assets 60,017,242 (4,762,702) 15,872,820 13,717,820 84,845,180 55,254,540 29,590,640 153.55% 9.94% 86,191,620 6,463,894 13,408,925 20,143,612 126,208,052 92,655,515 33,552,537 136.21% 11.68% 56,850,228 (4,766,014) 18,174,940 22,342,316 92,601,469 52,084,214 40,517,256 177.79% 14.29% 54,627,817 (2,194,498) 20,369,438 25,815,670 98,618,427 52,433,319 46,185,108 188.08% 16.63% 62,609,744 4,363,357 21,006,081 29,682,234 117,661,415 66,973,100 50,688,315 175.68% 18.43% 82,444,203 (783,185) 21,789,266 33,422,104 136,872,388 81,661,017 55,211,370 167.61% 20.25% Cumulative Inflows Cum Change In Overnight Pos Avail HLUM Sec, Cash, Overnite Cumulative Available for Liquidity Cumulative Outflows Cumulative Liquidity Gap Cum Liquidity Sources/Uses Cumulative Liquidity Gap/Assets 60,017,242 (4,762,702) 15,872,820 13,717,820 84,845,180 55,254,540 29,590,640 153.55% 9.94% 146,208,862 1,701,193 13,408,925 20,143,612 181,462,592 147,910,055 33,552,537 122.68% 11.68% 203,059,090 (3,064,822) 18,174,940 22,342,316 240,511,524 199,994,268 40,517,256 120.26% 14.29% 257,686,908 (5,259,320) 20,369,438 25,815,670 298,612,695 252,427,587 46,185,108 118.30% 16.63% 320,296,651 (895,964) 21,006,081 29,682,234 370,089,003 319,400,688 50,688,315 115.87% 18.43% 402,740,854 (1,679,149) 21,789,266 33,422,104 456,273,076 401,061,705 55,211,370 113.77% 20.25% Dec-2011 (Q) Jun-2012 (Q) Sep-2012 (Q) Dec-2012 (Q) 59,384,441 532,722,862 58,385,809 526,325,794 998,632 6,397,068 Mar-2012 (Q) 69,898,780 602,621,642 74,010,504 600,336,298 (4,111,725) 2,285,344 79,029,396 681,651,037 78,784,258 679,120,556 245,137 2,530,481 72,794,069 754,445,106 71,386,828 750,507,384 1,407,241 3,937,722 56,439,227 810,884,333 54,483,192 804,990,577 1,956,035 5,893,757 70,597,567 (3,719,287) 25,508,554 35,578,346 127,965,179 66,878,280 61,086,900 191.34% 22.36% 59,384,441 (998,632) 26,507,185 39,383,940 124,276,934 58,385,809 65,891,125 212.85% 24.31% 69,898,780 4,111,725 26,395,460 42,468,326 142,874,291 74,010,504 68,863,786 193.05% 25.22% 79,029,396 (245,137) 26,640,598 44,599,502 150,024,358 78,784,258 71,240,100 190.42% 25.91% 72,794,069 (1,407,241) 28,047,839 47,377,476 146,812,143 71,386,828 75,425,315 205.66% 27.21% 56,439,227 (1,956,035) 30,003,874 49,511,436 133,998,502 54,483,192 79,515,310 245.94% 28.39% 473,338,421 (5,398,436) 25,508,554 35,578,346 529,026,885 467,939,985 61,086,900 113.05% 22.36% 532,722,862 (6,397,068) 26,507,185 39,383,940 592,216,919 526,325,794 65,891,125 112.52% 24.31% 602,621,642 (2,285,344) 26,395,460 42,468,326 669,200,085 600,336,298 68,863,786 111.47% 25.22% 681,651,037 (2,530,481) 26,640,598 44,599,502 750,360,656 679,120,556 71,240,100 110.49% 25.91% 754,445,106 (3,937,722) 28,047,839 47,377,476 825,932,699 750,507,384 75,425,315 110.05% 27.21% 810,884,333 (5,893,757) 30,003,874 49,511,436 884,505,886 804,990,577 79,515,310 109.88% 28.39% ABA Toolbox on Liquidity – Appendix A | 3 Figure 3 shows a cash flow surplus of $4.763 million for the first quarter of 2010. The surplus increases Cash & Due From and Overnight Investments by $4.763 million (Figure 3 section 2 line 2). The $4.763 million increase in Cash, Due From, and Overnight Investments is the offsetting use of funds that keeps the balance sheet in balance. The second quarter shows a cash flow deficit of $6.464 million (section 1, last line). Cash, Due From, and Overnight Investments decreases by $6.464 million providing the funds needed to cover the cash flow deficit. However a portion of the cash flow deficit is due to the purchase of $4 million of securities in the second quarter (Figure 1) so only a portion of the deficit is a true reduction in asset-based liquidity. That net reduction in asset-based liquidity of $2.464 million can be seen can in Figure 3 section 2, line 3 as a reduction in Available HLUM Securities, Cash and Overnight Funding from $15.873 million at the end of the first quarter to $13.409 million at the end of the second. From the end of the second quarter through the end of the 12-quarter forecast, available HLUM securities, cash and overnight funding continue to build to a total of $30.003 million due to a combination of cash flow surpluses adding to the Fed Funds Sold position and additional purchases of HLUM securities, adding to XYZ’s asset-based liquidity Figure 3 Section 2 arrives at the total funds available for liquidity needs by bringing down the total sources from Section 1, adding changes in the overnight position, adding HLUM securities (net of cash flows occurring in the quarter), and adding unused borrowing capacity. In XYZ’s case, there is a cash flow surplus for all months of the forecast, except in the quarters in which XYZ takes a portion of its Fed Funds Sold position and deploys it into the investment portfolio. At the same time, the business plan gradually reduces XYZ’s reliance on Non-Core and near Core Funding, building its unused borrowing capacity. You can see that occurring on Lines 4 and 5 of Section 2 of Figure 3. The XYZ cumulative liquidity gap/asset ratio begins at the end of the first quarter at 9.9%. That ratio is consistent with the fact that XYZ has little asset-based liquidity to deal with short-term stresses like the one-month stress test delivered by the LCR. XYZ also has very little Near-Core and Non-Core borrowing capacity available, with a Near-Core and Non-Core utilization equal to 35.9% of assets against a 40% overall policy limit. XYZ is just below the border between red and yellow on their policy statement threat level guidelines. By the end of the second quarter the cumulative liquidity gap/assets is low in the yellow range at 11.68%. By the end of the fourth quarter, the one-year cumulative liquidity gap/asset ratio is in the green range at 16.6%. From there, the liquidity gap/asset ratio continues to build, hitting 28.4% by the end of the threeyear forecast. With the primary focus of the Liquidity Gap/Asset ratio being on the one-year cumulative gap, XYZ will find itself in the green range, assuming they effectively execute on their business plan. Of course one of the primary objectives in the business plan was to address XYZ’s weak liquidity position. It appears as though this business plan meets that objective. ABA Toolbox on Liquidity – Appendix A | 4 Short-Term Stress Test Using Modified Basel Liquidity Coverage Ratio The first stress test applied to XYZ’s business plan is a test designed to evaluate the effect of a shortterm liquidity crisis brought on by stress events like a freeze up of the securitization markets or disasters that may lock up the payment systems or cause customers to withdraw funds to meet short-term liquidity needs. The purpose of the LCR test is to insure the institution has sufficient asset-based liquidity to meet short-term needs. The LCR test makes the following assumptions: The institution is cut off from all access to new non-core funding for 30 days. A significant deposit runoff occurs in the 30 day period. Incoming amortization and prepayment cash flows from loans and investments slow. A portion of unused credit lines are drawn down by customers. The most liquid investments can be converted into cash subject to haircuts specific to the investment type. XYZ management made the following assumptions in performing the LCR test. Sources of funds o Bank CDs, FHLB Stock, and FRB Stock were not available to meet liquidity needs under this stress test as they are neither Level 1 nor Level 2 assets. o Overnight investments were 100% available to meet liquidity needs. o Treasuries and fully guaranteed Agencies are 100% available to meet liquidity needs. o All other unpledged securities meeting the Level 2 test were subject to a 15% haircut. o 100% of cash and NIB Deposits in other banks were available to meet liquidity needs. o Investment amortization and prepayments – 100% of amortization and 50% of anticipated prepayments are used as funding sources o Loan amortization and prepayments – 50% of amortization and 0% of anticipated prepayments are used as incoming cash flows. Uses of Funds o Deposits – 5% outflow in 30 days on highly stable deposits o Deposits – 10% outflow in 30 days of less stable deposits o Borrowings – Cash flows of all maturities and amortization must be funded without additional borrowings. o Firm commitments to originate – 100% utilization o Unused credit facilities – 5% utilization Figure 4 shows the summary results of this test. Outflows of funds total $14.204 million net of incoming loan and investment cash flows. Total sources of funds from cash and HLUM securities are $11.177 million. The LCR is 78.7%. XYZ Green Light minimum on the LCR is 105%. Red light minimum is 100%. XYZ is well short of its LCR policy limits. Figure 4 Liquidity Coverage Ratio Numerator (Net High Quality Liquid Assets) Denominator (Net Cash Outflows) 78.7% 11,177,770 14,204,399 Target Ratio Excess(Short) 100.0% (3,026,629) This deficiency is addressed in the XYZ business plan in a number of ways: Investment purchases growing the investment portfolio by $6 million in the first year of the plan (Figure 1) will focus on HLUM securities increasing the LCR numerator by $6 million. ABA Toolbox on Liquidity – Appendix A | 5 XYZ’s overnight investments position grows by $5.2 million in the first year of the plan. (Figure 3 section 3). XYZ is reducing its reliance on non-core funding by paying down brokered CDs and FHLB advances. Over time this will reduce the LCR denominator, as there will be less outgoing cash flows to fund under the LCR test. It is anticipated that XYZ will pass the LCR test in the second or third quarter under this plan. Given the strategies in the business plan it is anticipated that the LCR ratio will continue to grow throughout the plan. XYZ Market Dislocation Scenario The Market Dislocation Scenario considers an inability to sell loans originated for sale in the secondary markets, because the securitization markets freeze up, forcing XYZ to hold the loans in its portfolio. The Market Dislocation Scenario is a low probability/high impact event and should normally be dealt with as a stress scenario. In the XYZ case, normal levels of loans in the pipeline in any given month pending sale are $3-5 million. Assuming XYZ chooses to honor verbal commitments to customers where there is not a firm commitment, honor those written commitments to originate that have not yet closed, and deal with loans in the pipeline that are already closed, XYZ’s maximum exposure would be in the range of $15 million or 5% of its balance sheet. But in calculating its LCR, XYZ management has already run a much more severe 30-day stress test, so a stress test is superfluous. The impact of the Market Dislocation Scenario is much less severe than the LCR test for the following reasons: XYZ is likely to have full access to its Non-Core Funding sources. Under the LCR, it is cut off from all Non-Core sources. XYZ is unlikely to see the deposit runoff, since lack of access to securitization markets is unlikely to trigger a deposit run. Even though XYZ does not currently pass the LCR test, XYZ has more than enough asset-based liquidity to handle its maximum exposure. The following describes how XYZ would bring the funding on line to handle this stress event. Event Securitization Markets freeze up making it impossible for XYZ to sell loans originated for sale in the secondary markets. Action 1. Immediately suspend committing to originate loans for sale in the secondary market 2. Determine whether sufficient asset and liability-based liquidity exists to honor verbal non-binding commitments 3. In a manner consistent with maintaining key customer relationships, reduce origination of other loans until this short-term event is resolved 4. To the extent asset growth might cause an undesirable decline in the capital ratio, fund the retained loans using asset-based liquidity 5. To the extent asset growth does not cause a decline in the capital/asset ratio, fund the loans from XYZ non-core and near-Core Funding sources ABA Toolbox on Liquidity – Appendix A | 6 XYZ Payment System Disruption Scenario The Payment System Disruption Scenario is a low probability/high impact scenario brought on by the failure of a processing partner or a local disaster. The duration is limited to a few days. It should normally be dealt with in a stress test; however, the LCR test is much more severe and occurs over a longer duration (30 days). The XYZ Payment System Scenario is less severe for the following reasons: While the event could cause a minor deposit outflow as individuals tap into liquidity, the outflow is likely to be much less than in the LCR test. XYZ would likely have all of its Near-Core and Non-Core Funding available. The level of asset-based liquidity called for in the LCR test is likely to be well above that needed to deal with the Payment System Disruption Scenario without tapping into liability-based liquidity. XYZ would bring the funding on line to handle this stress event in the following manner. Event Short-term payment system disruption occurs causing XYZ to be unable to clear incoming deposit transactions and payments on loans Action 1. To the extent short-term asset growth creates capital concerns, tap into assetbased liquidity to meet liquidity needs during this stress event 2. To the extent short-term asset growth does not create a capital concern, use a combination of unused borrowing capacity and asset-based liquidity to meet liquidity needs during this stress event ABA Toolbox on Liquidity – Appendix A | 7 Long-Term Stress Test – PCA Well-Capitalized Capital Failure This stress test assesses the effect of a failure of PCA well-capitalized minimums. The following is a potential sequence of events and effects in this stress test scenario: Cause Effect Horizon Economic Downturn and Lax Underwriting Asset Quality Problem Increased Line Utilization Market Dislocations 3 Months Asset Quality Problem Net Operating Losses Adverse Press PCA and CAMELS Downgrades 3 Months Failure of Well Capitalized Status Increased FHLB Haircuts Loss of Access to Brokered CDs Loss of Brokered Deposits Adverse Press PCA and CAMELS Downgrades Rating Agency Downgrades Limits on Deposit Offering Rates 3 Months Loss of Large Depositors Loss of Core Funding Increased Line Utilization Inability to Raise New Deposit Funding 3 Months Adverse Press The primary objective in running changes in the assumptions is to test the effect of the PCA capital failure on sources and uses of funds and available liquidity. The following changes are made to cash flow assumptions in the Capital Stress Scenario to reflect the impact of the above sequence on XYZ business plan cash flows. Loans – Immediate o Incoming cash flows due to amortization and prepayment reduced to 80% of plan levels o Management response – loan originations reduced to 80% of plan levels Investments - Immediate o No new bond purchases. Cash flow from investments go to overnight position. Deposits o Year 1 – deposit growth continues based on business plan o Year 2 – rather than deposit growth in business plan, a 5% deposit shrinkage is anticipated o Year 3 – rather than deposit growth in business plan, an additional 5% shrinkage is anticipated. Borrowings o No change to term borrowings assumptions o Overnight borrowings used as needed to balance the balance sheet. Figure 5 shows a modified sources and uses of funds statement that reflects these changes in assumptions over the first two years of the plan. ABA Toolbox on Liquidity – Appendix A | 8 Figure 5 Liquidity Report Mar-2010 (Q) Jun-2010 (Q) Total Investments Inflow Outflow - Hold Investments Net 611,942 2,611,942 (2,000,000) 2,695,965 2,695,965 - Total Loans Inflow (85%) Outflow (80%, 80%, 70%) Net 28,829,770 20,451,994 8,377,775 28,605,746 21,097,086 7,508,659 610,318 610,318 30,052,030 23,063,937 6,988,093 Non-Earning Assets Inflow Outflow Net Total Assets Inflow Outflow Net Cumulative Sep-2010 (Q) 892,971 892,971 (0) XYZ Bank Forecast Cash Flow Liquidity Report - Assets Capital Scenario Stress Test Dec-2010 (Q) Mar-2011 (Q) Jun-2011 (Q) Sep-2011 (Q) (Dollars in Thousands) Dec-2011 (Q) Mar-2012 (Q) Jun-2012 (Q) 1,453,797 1,453,797 0 1,565,805 1,565,805 - 1,741,536 1,741,536 0 16,690,906 13,958,576 2,732,330 27,123,622 23,795,051 3,328,571 27,526,641 24,616,527 2,910,114 28,966,912 25,562,216 3,404,696 17,058,695 15,097,037 1,961,658 23,006,284 20,098,827 2,907,457 1,461,973 455,510 1,006,463 1,515,049 520,526 994,523 1,573,471 590,538 982,934 699,924 699,924 784,964 63,436 721,528 812,529 108,407 704,122 804,093 104,266 699,827 32,714,278 28,177,506 4,536,771 19,618,656 15,891,803 3,726,853 30,150,891 25,839,386 4,311,505 16,788,749 29,792,370 26,182,332 3,610,038 31,493,412 27,367,189 4,126,224 19,653,640 16,987,860 2,665,780 25,565,139 21,957,856 3,607,284 14,009,326 1,011,679 1,011,679 0 1,227,006 1,227,006 - 1,295,368 1,295,368 (0) 15,819,065 9,235,596 6,583,469 24,439,480 17,516,823 6,922,657 23,951,660 20,756,803 3,194,857 29,956,937 26,426,628 3,530,309 857,362 857,362 1,374,288 1,374,288 1,426,105 271,115 1,154,990 1,450,984 432,221 1,018,763 32,159,072 23,793,051 8,366,021 18,086,324 10,128,567 7,957,757 26,877,264 18,799,617 8,077,647 31,389,517 26,629,651 22,416,031 4,213,620 1,412,701 1,412,701 (0) Sep-2012 (Q) Dec-2012 (Q) 1,782,416 1,782,416 (0) 1,754,762 1,754,762 (0) After the first quarter, purchases that increase the size of the investment portfolio are deferred. Instead, the funds will end up in the more liquid Fed Funds Sold account, net of the results of other actions. Existing investments are replaced as cash flows mature to maintain the size of the investment portfolio at current levels. Loan inflows are cut to 85% of current levels, reflecting a slowdown of prepayment speeds and a slowdown of cash flows from collections of scheduled payments. Loan outflows are trimmed to 80% of current levels in the first two years of the plan and 70% in Year 3. XYZ management had already curtailed lending in the base business plan in order to shrink the balance sheet in Years 1 and 2. These assumptions for the purpose of the stress test reflect a further reduction in loan originations. The business plan had anticipated loan growth in Year 3 of the base plan. Under the stress scenario, further loan portfolio shrinkage is anticipated in Year 3. These reductions in loan originations take into consideration the potential for customers to draw down available credit lines to ensure access to funds. The asset side modifications result in a cumulative total of $31.4 million of net funds inflows in Year 1 (loan cash flows less originations), $16.8 million in Year 2, and $14.0 million in Year 3, compared with net inflows in the base business plan (Figure 5) of $27.6 million in Year 1 and $7.8 million in Year 2. A net outflow of $5.5 million was anticipated in Year 3 of the base strategy. Figure 6 Figure 6 shows the result of stress testing on the liability and capital side of the balance sheet. The numbers for this portion of the balance sheet prior to stress testing appear in Figure 2. Key modifications to cash flow assumptions on the liability and capital portion of the balance sheet include the following: Rather than Core deposit growth, the stress test assumes shrinkage of Core deposits by $17.6 million, a little over 10% over the 36 months of the plan. Funding the deposit outflow results in a $17.6 million use of funds over the three-year forecast. This outflow of Core Funding occurs as a result of negative publicity, but helps accomplish the goal of shrinking assets to maintain higher capital/asset ratios. ABA Toolbox on Liquidity – Appendix A | 9 Liquidity Report Core Funding Inflow (90%) Outflow Net Cumulative Near-Core Funding Inflow - 85% Outflow Net Cumulative Non-Core Funding Inflow Outflow Net Cumulative Other Liab Inflow Outflow Net Capital Inflow Outflow Net Total Liab & Capital Inflow Outflow Net Cumulative Mar-2010 (Q) 16,597,475 15,771,201 826,274 Jun-2010 (Q) Sep-2010 (Q) 25,385,843 28,348,719 (2,962,875) 20,671,120 22,925,338 (2,254,217) 1,116,610 1,699,948 (583,338) 4,607,441 6,583,405 (1,975,965) 1,745,480 2,749,961 (1,004,480) 1,253,000 8,907,026 (7,654,026) 4,148,000 23,889,231 (19,741,231) 13,130,896 (13,130,896) 9,776 (9,776) 13,909 (13,909) 689,653 (689,653) 18,967,085 27,077,605 (8,110,520) XYZ Bank Forecast Cash Flow Liquidity Report - Liabilities & Capital Capital Scenario Stress Test Dec-2010 (Q) Mar-2011 (Q) Jun-2011 (Q) Sep-2011 (Q) (Dollars in Thousands) Dec-2011 (Q) 17,054,534 17,526,869 (472,335) 27,585,462 29,877,947 (2,292,484) 28,843,728 31,319,433 (2,475,705) 1,193,315 1,754,597 (561,282) 2,593,803 5,172,609 (2,578,805) 4,660,340 5,862,276 (1,201,936) 2,410,313 4,289,118 (1,878,805) 1,452,252 3,331,057 (1,878,805) 1,061,784 2,940,589 (1,878,805) 13,909 (13,909) 13,208,753 14,700,959 (1,492,206) (5,883,025) 1,926,105 2,809,915 (883,810) (4,447,593) 1,259,000 10,888,153 (9,629,153) (50,155,307) 13,909 (13,909) 4,000 (4,000) 4,000 (4,000) 4,000 (4,000) 14,870,905 14,841,405 29,499 (5,211,025) 1,653,037 2,225,447 (572,409) (4,914,432) 837,402 2,716,207 (1,878,805) (7,515,220) 4,000 (4,000) 752,928 (752,928) 826,644 (826,644) 841,560 (841,560) 235,456 (235,456) 291,715 (291,715) 132,162 (132,162) 124,553 (124,553) 34,141,284 59,588,192 (25,446,908) 22,416,601 39,646,748 (17,230,147) 16,393,858 29,254,496 (12,860,639) (63,648,213) 20,658,162 23,810,040 (3,151,878) 31,631,518 38,677,328 (7,045,810) 34,565,852 40,258,460 (5,692,607) 17,361,344 19,911,612 (2,550,268) (18,440,564) Mar-2012 (Q) Jun-2012 (Q) Sep-2012 (Q) 17,610,641 18,415,611 (804,970) 23,532,685 25,745,732 (2,213,047) 27,188,373 30,241,449 (3,053,076) 747,434 1,159,084 (411,650) 1,209,027 1,570,289 (361,262) 3,310,278 4,599,058 (1,288,781) 2,079,995 3,958,800 (1,878,805) 1,918,874 3,797,679 (1,878,805) 1,232,650 3,781,065 (2,548,415) 3,000 3,000 3,000 3,000 3,000 3,000 156,008 156,008 135,470 135,470 351,707 351,707 20,597,077 23,533,495 (2,936,418) 26,799,057 31,113,700 (4,314,644) 32,086,008 38,621,573 (6,535,565) Dec-2012 (Q) 17,103,367 17,559,811 (456,444) (6,527,537) 1,529,724 1,981,692 (451,967) (2,513,660) 1,209,722 (1,209,722) (7,515,747) 3,000 3,000 235,680 182,552 53,128 18,871,772 20,933,777 (2,062,005) (15,848,631) XYZ was already planning to reduce Near-Core Funding as part of its business plan. The stress test assumes a reduction to only 85% of Near-Core deposit openings and renewals as compared to the levels projected in the business plan. Projected uses of funds for outflows total $11.8 million over three years. In the Non-Core section of Figure 6, all wholesale brokered CDs are allowed to run off, as a result of regulatory actions barring the use of brokered deposits once risk-based capital failure has occurred. Collateral haircuts will only allow 50% of FHLB advances to be renewed, so, the Non-Core portion of the balance sheet shows a $50.2 million net outflow of funds in Year 1 and an additional $7.5 million runoff in Years 2 and 3. By the end of the three years there are no remaining brokered CDs from a $47.0 million portfolio on 9/31/09. The FHLB advances are reduced to $24.8 million from a $43.3 million portfolio. Cumulative liability and capital outflows (uses of funds) total $63.6 million in Year 1, another $18.4 million in Year 2 and $15.8 million in Year 3. Figure 7 summarizes the results of the stress test, concentrating on the same gaps and ratios shown prestress in Figure 3. The first section of Figure 7 indicates that a very significant cash flow deficit opens up in the stressed scenario, reaching $35.7 million cumulatively, by seven quarters into the stressed version of the business plan. From that point it fluctuates mildly, staying in the same general range through the 12th quarter of the forecast. The cash flow deficit builds rapidly at first, as wholesale brokered CDs run off the books in the first 18 months of the forecast, then stabilizes after the wholesale brokered CDs have all matured. ABA Toolbox on Liquidity – Appendix A | 10 Figure 7 Liquidity Report Mar-2010 (Q) Jun-2010 (Q) Sep-2010 (Q) XYZ Bank Forecast Cash Flow Liquidity Report - Liquidity Gap & Ratios Capital Scenario Stress Test Dec-2010 (Q) Mar-2011 (Q) Jun-2011 (Q) Sep-2011 (Q) Dec-2011 (Q) Mar-2012 (Q) Jun-2012 (Q) Sep-2012 (Q) Dec-2012 (Q) (Dollars in Thousands) 43,271,121 47,287,812 64,345,796 54,184,508 47,512,235 50,389,447 58,292,469 51,739,648 44,436,911 199,093,517 246,381,329 310,727,125 364,911,633 412,423,868 462,813,314 521,105,784 572,845,432 617,282,343 48,054,113 46,226,071 66,854,834 56,150,263 45,750,998 49,715,826 58,480,889 55,609,432 42,891,632 231,352,213 277,578,284 344,433,118 400,583,381 446,334,379 496,050,205 554,531,094 610,140,526 653,032,159 (4,782,992) 1,061,742 (2,509,039) (1,965,754) 1,761,237 673,620 (188,420) (3,869,784) 1,545,279 (32,258,696) (31,196,955) (33,705,993) (35,671,748) (33,910,511) (33,236,891) (33,425,310) (37,295,095) (35,749,816) Total Inflows Cumulative Inflows Total Outflows Cumulative Outflows Cash Flow Surplus (Deficit) Cum Cash Flow Surplus (Deficit) 49,019,115 49,019,115 50,141,542 50,141,542 (1,122,427) (1,122,427) 66,300,356 115,319,471 83,381,243 133,522,785 (17,080,887) (18,203,314) 40,502,925 155,822,395 49,775,315 183,298,100 (9,272,390) (27,475,704) Total Inflows Change in Overnight Position Unused Borr Cap Available HLUM Securities Total Available for Liquidity Total Outflows Total Liquidity Gap Total Liquidity Sources/Uses Total Liquidity Gap/Assets 49,019,115 1,122,427 17,264,192 19,993,563 87,399,297 50,141,542 37,257,755 174.31% 12.51% 66,300,356 17,080,887 21,026,538 11,408,925 115,816,707 83,381,243 32,435,463 138.90% 11.29% 40,502,925 9,272,390 22,706,422 14,174,940 86,656,677 49,775,315 36,881,362 174.10% 13.01% 43,271,121 4,782,992 25,205,335 16,369,438 89,628,886 48,054,113 41,574,773 186.52% 14.97% 47,287,812 (1,061,742) 27,021,716 12,006,081 85,253,868 46,226,071 39,027,797 184.43% 14.19% 64,345,796 2,509,039 27,155,579 12,789,266 106,799,680 66,854,834 39,944,846 159.75% 14.65% 54,184,508 1,965,754 26,779,824 16,508,554 99,438,640 56,150,263 43,288,378 177.09% 15.85% 47,512,235 (1,761,237) 29,267,673 17,507,185 92,525,857 45,750,998 46,774,859 202.24% 17.26% 50,389,447 (673,620) 30,787,734 13,395,460 93,899,020 49,715,826 44,183,194 188.87% 16.18% 58,292,469 188,420 31,188,891 13,640,598 103,310,378 58,480,889 44,829,489 176.66% 16.30% 51,739,648 3,869,784 30,089,990 15,047,839 100,747,262 55,609,432 45,137,829 181.17% 16.28% 44,436,911 (1,545,279) 31,854,045 17,003,874 91,749,551 42,891,632 48,857,919 213.91% 17.44% Cumulative Inflows Cum Change in Overnight Pos Unused Borr Cap Avail HLUM Sec, Cash & Ov Inv Cumulative Available for Liquidity Cumulative Outflows Cumulative Liquidity Gap Cum Liquidity Sources/Uses Cumulative Liquidity Gap/Assets 49,019,115 1,122,427 17,264,192 19,993,563 87,399,297 50,141,542 37,257,755 174.31% 12.51% 115,319,471 18,203,314 21,026,538 11,408,925 165,958,249 133,522,785 32,435,463 124.29% 11.29% 155,822,395 27,475,704 22,706,422 14,174,940 220,179,462 183,298,100 36,881,362 120.12% 13.01% 199,093,517 32,258,696 25,205,335 16,369,438 272,926,986 231,352,213 41,574,773 117.97% 14.97% 246,381,329 31,196,955 27,021,716 12,006,081 316,606,081 277,578,284 39,027,797 114.06% 14.19% 310,727,125 33,705,993 27,155,579 12,789,266 384,377,964 344,433,118 39,944,846 111.60% 14.65% 364,911,633 35,671,748 26,779,824 16,508,554 443,871,758 400,583,381 43,288,378 110.81% 15.85% 412,423,868 33,910,511 29,267,673 17,507,185 493,109,237 446,334,379 46,774,859 110.48% 17.26% 462,813,314 33,236,891 30,787,734 13,395,460 540,233,399 496,050,205 44,183,194 108.91% 16.18% 521,105,784 33,425,310 31,188,891 13,640,598 599,360,583 554,531,094 44,829,489 108.08% 16.30% 572,845,432 37,295,095 30,089,990 15,047,839 655,278,356 610,140,526 45,137,829 107.40% 16.28% 617,282,343 35,749,816 31,854,045 17,003,874 701,890,077 653,032,159 48,857,919 107.48% 17.44% Line 2 of Section 2 shows changes in the overnight position needed to balance the cash flow mismatches. As Section 3, Line 2 of Figure 7 indicates, cumulative changes to the overnight position match the cumulative cash flow deficit numbers in the previous paragraph. However, because Non-Core term funding is rolling off the books even faster than the overnight position is changing, unused borrowing capacity (Section 2, Line 3) grows from $17.26 million to $31.854 million by the end of the forecast. Unused borrowing capacity should take into account two factors: Policy limits on use of Non-Core Funding both at the individual source level and overall Actual unused borrowing capacity with the various funding providers For the purpose of these projections, sufficient unused capacity is assumed at the various sources to allow XYZ to reach its overall policy limit of 40% of funding all through the stress scenario. Should that not be the case, Figure 7 may overstate XYZ’s unused borrowing capacity. Available HLUM securities fail to grow, due to the elimination of Fed Funds Sold and due to the fact no additional investments are being purchased after the first quarter in the stress scenario. The total liquidity gap, including unused borrowing capacity, grows from $37.25 million to $48.9 million by the end of the three-year forecast. Because assets shrink throughout the forecast, the cumulative liquidity gap/asset ratio grows from 12.51% at the end of the first quarter to 17.44% by the end of the three-year forecast. The one-year stressed cumulative liquidity gap/asset ratio is 14.92%, well above green light minimum of 5%. Of course to the extent unused borrowing capacity falls below the policy limit of 40%, the stressed 1 year cumulative liquidity gap/asset ratio will also drop. For example should overall borrowing capacity drop to 30% of assets, the 1 year stressed cumulative liquidity gap/asset ratio would be 4.92%, just below the 5% green light minimum. Given these stress test results, the XYZ Liquidity policy limits require no action as long as XYZ has access to $33 million of overnight borrowings to make up for daily funding shortfalls. These overnight funds are unlikely to be available from either the FHLB (collateralized source) or from XYZ uncollateralized sources once they have fallen below PCA well capitalized minimums. Management will need a CFP to address this shortfall and any others they have encountered in their stress testing. The following describes the series of actions XYZ would take in dealing with this stress event as it unfolds. ABA Toolbox on Liquidity – Appendix A | 11 Event Triggers indicate development of asset quality problem, declines in performance, and potential for a capital failure event. PCA Well Capitalized failures or regulatory actions remove access to brokered CD network. FHLB increases collateral haircuts. Action 1. Replace maturing brokered CDs with FHLB advances or similar instruments that have maturities of at least 2-3 years. 2. Begin moving jumbo CDs into CDARS network to provide full deposit insurance to those depositors to reduce potential runoff and reduce collateral pledging requirements, freeing up asset-based liquidity. 3. Use Core Funding strategies to grow deposits, replacing non-regulatory Core Funding as it matures. 4. All maturing investments held in fed funds or short-term investments. 5. Loan originations cut back. 6. Begin shrinking the balance sheet to build capital and liquidity using net loan cash flows to pay off maturing funding. 1. Replace renewing brokered CDs and FHLB Advances with Rate Board CDs to the extent needed to fund the balance sheet. Extend terms to 2-3 years. 2. Make further cutbacks in loan originations and potentially liquidate asset-based liquidity to shrink the balance sheet. 3. Package and sell conforming consumer mortgages in the secondary market. 4. Explore the sale of business lines or branches to further shrink the balance sheet. 1. Consider further cutbacks in lending to level needed to sustain key customer relationships. Objective is to allow deposit runoff through shrinkage. 2. Begin using the Fed Window as a collateralized borrowing source to plug any remaining funding gaps. Adverse publicity causes loss of Core Funding Fortunately, XYZ management has already incorporated key portions of the CFP for the Capital Failure Scenario: reductions in investment purchases, some use of asset-based liquidity (Fed Funds Sold), reductions in loan originations, and balance sheet shrinkage. Therefore, XYZ should be able to survive the Capital Failure Scenario for 2-3 years, by closing the $33 million funding gap with some combination of CDARS, Core Funding growth, rate board CDs, and collateralized fed borrowings. XYZ Economic Recovery Scenario The final stress event identified by XYZ management is an economic recovery scenario - a high probability high impact event. Because it is high probability it is best dealt with in the base liquidity ABA Toolbox on Liquidity – Appendix A | 12 strategy rather than with stress testing. The scenario and its potential effects are described in the XYZ Base Liquidity Plan. The business plan anticipates that growth will turn positive in Year 3, but it only looks out three years and never reaches the equilibrium forecast in the fifth year of the capital plan. A stress test is unnecessary; should loan growth exceed deposit growth, the effect will immediately begin to show up in XYZ’s trigger ratios. To the extent loan growth is funded from reductions in investments, the LCR would begin declining, eventually breaking through barriers between green and yellow, alerting management to the threat. The threat level guidelines prescribe changes to the business strategy to counter these threats. A similar movement would occur to the NSFR, with the ratio breaking the green/yellow barrier, and ultimately the yellow/red barrier. Again, the threat level guidelines prescribe changes to the business strategy to counter these threats. The cumulative one-year liquidity gap/asset ratio would begin moving downward, showing the use of liquidity to fund loan growth, eventually breaking through the green/yellow barrier and alerting management. Individual funding sources would begin moving in the direction of limits, and overall use of NearCore and Non-Core Funding would begin moving up away from its goal and in the direction of the policy limit, alerting management to liquidity issues Depending on the relationship between the loan growth rate and the capital growth rate, capital ratios could begin to decline, falling below capital goals which would also alert management of an issue. Should loan growth exceed core funding growth to the extent that it is felt a liquidity or capital threat is developing, the following contingency actions would be considered. Event Declines in LCR with the potential of falling to a higher threat level barrier Declines in NSFR with the potential of falling to a higher threat level barrier Declines in the unstressed cumulative liquidity gap/asset ratio with the potential of falling to a higher threat level barrier Increases in individual borrowing category ratios/assets or overall Near-core and Non-Core Funding/assets with the potential of violating policy limits or using funds needed for contingencies Declines in the capital/asset ratio to management threat level points or with the potential to fall below PCA well capitalized minimums Action A portion of loan production formerly retained is sold in the secondary markets Pricing and/or increased underwriting standards are used to reduce loan demand In severe situations, loan originations are limited to those necessary to maintain key customer relationships A portion of the loan portfolio is packaged and sold or participated Funding growth, but only to the extent that faster overall asset growth does not represent a threat to the overall capital ratio ABA Toolbox on Liquidity – Appendix A | 13