Crisis Management What Really Happens? 9 A jump from normal conditions to serious crisis is extremely rare. It is more common to see steady or lumpy deterioration. 9 Initial reactions are often denial, minimization and deferral. (And some CYA.) One Key Truth Once a crisis blooms, few management tools are available. The most important aspects of crisis management are, therefore, quick recognition of non-normal conditions and prompt responses. Stages of a Funding Crisis 4 Six Internal Triggers for Identifying the Onset of Bank Specific Non-Normal Conditions Increasing levels of delinquent and non-accrual loans. Adverse trend in overnight and short-term net funds sold/funds borrowed. Adverse trend in liability concentrations from non-sticky sources. Adverse trend in the size of the liquid asset reserve. Approaching the bank’s limit / minimum. Approaching or exceeding limits /minimums for forecasted cash flow. A decline in earnings. 5 Six External Triggers for Identifying the Onset of Bank Specific Non-normal Conditions Widening funding spreads relative to peers. Adverse trend in deposit growth. Adverse trend in renewal of maturing liabilities - especially noninsured, unsecured. Temporary funding difficulties or turn downs of borrowing requests. Decline in stock price relative to peers. Downgrading by a rating agency (lagging indicator.) 6 Six External Triggers for Identifying the Onset of Systemic Non-normal Conditions General signs of a credit crunch such as increased use of commitments by credit worthy counter-parties. Slow downs or weakening in key economic sectors, for example commodity prices or home prices. Slower deposit growth and increased competition for deposits. Adverse change in fiscal policy, monetary policy, banking regulation or other government regulation. Declining stock prices or earnings multiples for financial institutions in your market. Ratings downgrades for one or more competitors. 7 More Triggers for Identifying the Onset of A Need For More Prudential Liquidity An increase in the level of nonperforming assets -particularly, if your bank's problem assets are larger or growing faster than your peers. Significant asset growth or acquisitions. Pressure to buy back liabilities or support market Legal, regulatory or tax changes that make your business more competitive, more restricted or more expensive 8 Crisis Management Remedial actions must be identified. Measurement, management, policies and CFPs must deal with remedial actions consistently and with specificity. Actions that can be taken without clobbering earnings need to be identified and implemented. Intelligent diversification. Opportunistic funding. Change mix of marketable securities to reduce sensitivity to adverse market developments. Improve collateral management Place acceptable collateral with FRB Actions with deleterious earnings impact need to be considered in light of “path to the exit”. 9 The Crisis Management Team Instead of informal and haphazard communications among senior managers and internal risk experts, a crisis management team serves as a forum where members can avoid duplication of assigned responsibilities, make sure that everyone isn’t assuming that someone else is doing a key task, increase the efficiency of decision making and improve communications. When the CFP is invoked, this previously defined group springs to life. The purpose of a crisis management team is to direct the implementation of the CFP. The crisis management team coordinates the implementation of the relevant CFP provisions, keeps people organized, keeps tasks prioritized and follows up to ensure that decisions were implemented properly. “The formation of a crisis management team is vital to the success of any contingency funding plan. Experience has shown that a team of highly skilled staff members is necessary to quickly asses the evolving situation, rapidly decide a course of action, implement the actions, monitor the situation, and take corrective actions as necessary.” Paul A. Decker, The Changing Character of Liquidity and Liquidity Risk Management, The Journal of Lending & Credit Risk Management, May 2000, Page 32. Liquidity Reporting in a Crisis 9 Increase the frequency of liquidity reports. For example, from monthly to weekly in the early stages of a potential crisis and from weekly to daily in a crisis. 9 Increase the amount of detail shown in the bank’s liquidity reports. For example, a cash flow gap report that normally shows expected inflows and outflows grouped by month might be expanded to show weekly forecasts. 9 Add supplemental liquidity reports for selected early warning indicators. For example, the bank may begin daily tracking of the spread between the rates it has to pay for new funds and rates paid by peers. 9 Add supplemental liquidity reports of contingent needs and sources. Example Remedial Actions for a Bank Specific, Heightened Level of Risk 9 Review opportunities to increase the size of the liquidity reserve (perhaps by switching some asset holdings from less liquid instruments or perhaps by obtaining new term borrowings that can be invested in new liquid assets.) 9 Intensify collateral management to free additional collateral. 9 Review opportunities to alter the mix and the terms of either assets or liabilities to increase net cash flow cushions in the overnight, 7-day, 30day, and 90-day buckets. 9 Begin reporting liquidity risk information to senior committees and directors more often and in more detail. managers, risk 9 Update reports, with contact information, listing the bank’s largest funds providers. Example remedial actions for a bank specific problem, medium stress level. 9 Implement pre-crisis plans for daily cash flow forecasts and supplemental reports. 9 Restrict new lending as much as possible without risking further reduction in customer confidence. 9 Cease trading activities. 9 Increase cash held in branches and ATMs merely to avoid a potentially embarrassing shortage. 9 Move collateral to the central bank(s) if required. 9 Tap alternative funding sources (e.g., tri-party repurchase agreements for illiquid securities, MTN-program in local markets, etc.) 9 Intensify efforts, employee incentives and/or customer incentives for deposit retention. 9 Discontinue any financial support for bank obligations trading in the secondary market. 9 Evaluate opportunities to sell illiquid assets or business units if the funding problem worsens. Multiple Currency Challenges Country Risk Transferability • political risk/expropriation • Cash or collateral cannot usually be transferred from one country to another during a liquidity event. • F/X convertibility • Economic/country crisis • In some countries, cash or collateral cannot be transferred between legal entities during a liquidity event. • Some regulators require minimum liquid asset level maintenance. $ € £ ¥ Convertibility • Markets for some currencies are usually thin. • Convertibility can be a problem when markets are distressed. 14