159x Filetype PPT File size 0.30 MB Source: www.cdfifund.gov
Discussion Points • Outline the responsibilities of an asset liability committee (ALCO). • Discuss commonly observed ALCO best practices in community banks. • Review areas of the ALCO policy and/or ALCO activities that could be enhanced. • Discuss liquidity risk management. • Review new IRR guidance. • Discuss regulatory ALM modeling tips. • Introduce upcoming guidance on credit risk analysis of investment securities. 2 Asset-Liability Committee (ALCO) Responsibilities ALCO Composition • Senior management committee in a financial institution responsible for coordinating the institution's borrowing and lending strategy, and funds acquisition to meet profitability objectives as interest rates change. ALCO Responsibilities – Liquidity Risk Exposure • The ALCO should actively monitor the institution’s liquidity profile and should have sufficiently broad representation across major institutional functions that can directly influence the institution’s liquidity risk profile (e.g., lending, investment securities, wholesale and retail funding). • For example, the ALCO will have responsibility for setting limits on the arbitrage of short-term borrowing, while lending long-term instruments. Among the factors considered are liquidity risk, interest rate risk, operational risk and external events that may affect the bank's forecast and strategic balance-sheet allocations. ALCO Responsibilities – Interest Rate Risk Exposure • The ALCO should ensure that the risk measurement system adequately identifies and quantifies risk exposure. Reporting • The ALCO will generally report to the board of directors and will also have regulatory reporting responsibilities. Reporting process should communicate accurate, timely, and relevant information about the level and sources of risk exposure. 3 Asset-Liability Management • Typically, asset-liability management (ALM) is associated with reporting a financial institution’s historical Gap, EVE, and net interest income sensitivity results. • Ideally, ALM should involve an integrated process between interest rate risk, liquidity risk management, budgeting, and strategic planning that includes the entire bank; and develops future dynamic strategies that balance risk and profitability. 4 ALCO Best Practices Observed in Community Banks • Although there is no official written guidance that outlines regulatory expectations of the ALCO, the following are ALCO best practices observed by examiners of community banks: o Liquidity that is readily available, including the availability of collateral to be pledged. o Credit lines accessible with material adverse change clauses readily accessible to determine circumstances that would disallow use of the lines. o Limitations on particular types of deposits that can be accumulated, for example, municipal deposits. o ALCO package that includes a 1-page summary covering all key model assumptions including any recent changes to the assumptions. o Funding diversification guidelines. o Establishing targets and composition mix of the investment portfolio. o IRR and liquidity limits that require action vs. additional discussion (e.g., Red, Yellow, Green). o ALCO packages that show level and trends vs. just showing the level specifically for risk limits. o Cash flow coverage for runoff of collateralized deposits. o Testing credit lines at least annually. 5 ALCO Best Practices Observed in Community Banks (con’d) • Although there is no official written guidance that outlines regulatory expectations of the ALCO policy, the following are ALCO policy best practices observed by examiners of community banks: o Has substance, structure and focus. o Ties-in other policy parameters, e.g., Investment Policy guidelines and the impact on liquidity. o Includes description of how key assumptions are determined, and the source documents used to make the assumptions. o Includes minimum risk limits for maintaining liquid, unencumbered assets. o Includes a definition of liquidity assets. o Outlines expectations for independent review. o Includes funding risk limits by maturity, e.g., limits on short-term, wholesale funding). 6
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