ASSET/LIABILITY MANAGEMENT. For purposes of these policies the Foundation’s adherence to this policy regarding Asset/Liability Management shall be the same inside and outside of the United States, except as otherwise required by applicable law. Where there is a conflict, the spirit of the Foundation Policy must still be observed.
ASSET/LIABILITY MANAGEMENT. During the term of this Agreement, the Investment Manager shall provide asset-liability services with respect to the Investments designed to assist the Company in managing the relationship between its assets and liabilities. In connection therewith, the Investment Manager shall:
a. measure, monitor and recommend strategies to manage interest-rate risk through strategies that fit within the Company's overall objectives described in the Investment Guidelines (defined below); and
b. prepare and deliver such asset/liability reports, and responses to other reasonable requests for specific recommendations and input, as the Company or the Committee may reasonably request from time to time.
ASSET/LIABILITY MANAGEMENT. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written interest rate risk policy. In formulating this policy, the Board shall refer to the “Interest Rate Risk” booklet of the Comptroller’s Handbook, OCC Bulletin 2010-1, and OCC Bulletin 2004-29. The policy shall provide for a coordinated interest rate risk strategy and, at a minimum, address:
(a) the establishment of adequate management reports on which to base sound interest rate risk management decisions;
(b) establishment and guidance of the Bank’s strategic direction and tolerance for interest rate risk;
(c) implementation of effective tools to measure and monitor the Bank’s performance and overall interest rate risk profile;
(d) employment of competent personnel to manage interest rate risk;
(e) prudent limits on the nature and amount of interest rate risk that can be taken; and
(f) periodic review of the Bank's adherence to the policy.
(2) Within sixty (60) days, the Board shall review and revise the Bank's investment policy and implement the revised policy, and thereafter ensure Bank adherence to the policy. The policy shall contain the basic elements of a sound investment policy consistent with regulatory guidance provided in An Examiner’s Guide to Investment Products and Practices (December 1992), 12 C.F.R. Part 1, and OCC Bulletin 98-20 (April 27, 1998), OCC Bulletin 2009-15, OCC Bulletin 2002-19; and shall include:
(a) an investment portfolio strategy that is consistent with Board approved Bank asset and liability management policies and interest rate risk tolerances;
(b) approval procedures that will include dollar size limits, quality limitations, maturity limitations, price depreciation guidelines, and concentration guidelines as a percentage of capital; and,
(c) requirements to perform appropriate due diligence, including annual and ongoing credit review of the municipal holdings; and appropriate prepurchase and internal credit risk assessments of corporate securities.
(d) The Board shall strengthen the Bank’s Contingency Funding Plan by developing and incorporating
(3) The Board shall strengthen the Bank’s Contingency Funding Plan consistent with regulatory guidance provided in OCC Bulletin 2010-13. Updates shall include, but not be limited to, the following:
(a) liquidity stress scenarios to sufficiently identify and quantify sources of potential liquidity strain and to analyze possible impacts on the institution’s cash flows, liquid...
ASSET/LIABILITY MANAGEMENT. (1) Within ninety (90) days of the date of this Agreement, the Board shall adopt and the Bank, subject to Board review and ongoing monitoring, shall implement and thereafter adhere to a revised asset liability management program that includes at a minimum:
(a) controls to ensure the Board and management evaluate and quantitatively assess, prior to execution, how loan funding commitments will impact the Bank's interest rate risk exposure;
(b) controls to ensure the Bank does not exceed Board approved risk limits when executing such commitments;
(c) an interest rate risk reduction strategy that includes quantitative and qualitative objectives consistent with the Strategic Plan required to be developed under Article IV, assigned responsibilities and accountability, and regular progress reporting to the Board; and
(d) standards for validating the Bank's interest rate risk model and model validation consistent with OCC Bulletin 2011-12, Sound Practices for Model Risk Management; Supervisory Guidance on Model Risk Management (April 4, 2011).
(2) Upon adoption, the Board shall submit a copy of the revised asset liability management program to the Assistant Deputy Comptroller for review.
ASSET/LIABILITY MANAGEMENT. (1) Within sixty (60) days of the date of this Agreement, the Board shall adopt, implement, and thereafter ensure Bank adherence to a written, coordinated asset/liability management strategy. This strategy should:
(a) provide for adequate management reports that enable the Board and management to monitor the Bank’s liquidity position and maintain liquidity at an adequate level. These reports should:
(i) include compliance with all policy limits;
(ii) be presented to the Board monthly;
(iii) include a prospective, rolling 30, 60, 90, 120, 150 and 180 days Sources and Uses Report that reflects anticipated shortfalls and probable funding sources;
(iv) include a rollover risk analysis;
(v) identify and quantify funding concentrations and collateral positions; and
(vi) identify key, early warning indicators that would trigger a more in- depth analysis.
(b) quantify growth plans;
(c) identify and prioritize funding sources, including the use of brokered deposits;
(d) establish limits for the amount of retail deposits, asset growth, and brokered deposits as a percent of total assets;
(e) revise the Asset Liability Management policy to include:
(i) guidance on monitoring and reporting the items in (a) through (d) of this Article;
(ii) limits for rollover risk and collateral positions; and
(iii) minimum net liquid assets to liabilities ratios.
(f) review the current loan to deposit (LTD) ratio and determine if an adjustment is needed. Any adjustments to the LTD ratio should be included in the Asset Liability Management policy;
(g) ensure Asset Liability Committee (ALCO) participation and concurrence for funding strategy changes; and
(h) revise the Contingency Funding Plan (CFP) to:
(i) identify liquidity crises that are relevant to current balance sheet composition and strategies;
(ii) ensure crisis scenarios identify trigger points for actions that should be taken in advance of reaching the crisis; and
(iii) include severity and duration components and the related impact on funds availability.
(2) Upon adoption, a copy of the written strategy shall be forwarded to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection. Upon receiving a determination of no supervisory objection from the Assistant Deputy Comptroller, the Bank shall implement and adhere to the strategy.
(3) Copies of the liquidity reports outlined in this Article shall be forwarded to the Assistant Deputy Comptroller in the Bank’s quarterly report.
(4)...
ASSET/LIABILITY MANAGEMENT. (1) Within sixty (60) days, the Board shall revise, implement and thereafter ensure Bank adherence to a written liquidity and asset/liability management policy that is consistent with safe and sound standards for liquidity and asset/liability management. Refer to the (i) “Liquidity” booklet, L-L, of the Comptroller’s Handbook (June 2012), and the guidance set forth in (ii) “Interagency Advisory on Interest Rate Risk Management” (OCC Bulletin 2010-1); (iii) “Supervisory Guidance on Model Risk Management” (OCC Bulletin 2011-12); and (iv) “Final Policy Statement: Interagency Policy Statement on Funding and Liquidity Risk Management” (OCC Bulletin 2010-13). The policy should address and require, at a minimum:
ASSET/LIABILITY MANAGEMENT. The Company will provide the Investment Asset Manager with a projection, based on prior trends, of the Company's anticipated liability cash outflows for subsequent years. The Investment Manager will manage asset purchases to provide adequate investment cash flow to meet those anticipated liability cash outflows net of operational cash inflows. The Investment Manager will also utilize the "target asset duration" as previously discussed in the fixed income portfolio section, to assist in managing the cash flow needs for covering the liabilities. An investment action that takes the asset duration beyond the established duration period will require the approval of the Committee. At least annually, the CFO will provide an analysis of asset/liability matching data to the Committee and Investment Managers. The results will be used to assist with the determination of appropriate durations for the future periods.
ASSET/LIABILITY MANAGEMENT. (a) Within 60 days of this Agreement, the Bank shall submit to the Reserve Bank and the Comptroller an acceptable revised written asset/liability management policy designed to improve management of the Bank's liquidity and sensitivity to market risk.
(b) The revised policy regarding liquidity shall, at a minimum, address the following: (1) a minimum level of temporary assets; (2) a maximum level of volatile liabilities; (3) an appropriate level of core deposits; (4) an appropriate level of loans relative to deposits and capital; (5) parameters for off-balance sheet risk; (6) the number and amount of large deposits; (7) the Bank's borrowing availability; and (8) appropriate standards for volume, mix and maturity of the Bank's loans, investments, and deposits.
(c) The revised policy regarding sensitivity to market risk shall, at a minimum, address the following parameters for interest rate risk: (1) appropriate guidelines for "GAP" management; (2) an adequate system to model and control the vulnerability of net interest income to changes in interest rates; and (3) appropriate parameters governing the economic risk to the Bank's capital due to changes in interest rates.
(d) The Asset/Liability Committee (the "ALCO") of the Bank shall be responsible for providing the necessary reports to the board of directors on a monthly basis so that the board of directors can make informed decisions regarding the Bank's management of market risk.
(e) The ALCO shall, at all times, be comprised of at least two outside directors. The ALCO shall be responsible for monitoring compliance with the Bank's asset/liability policies and procedures, and shall review, on a monthly basis, all decisions made by the Bank's management with regard to such policies and procedures, paying particular attention to whether each decision was made in accordance with the established policies and procedures. Any exceptions to the policies and procedures shall be documented by the ALCO as to the reason for the exception, and the continuance of any exception must be approved by a majority of both the ALCO and the Bank's board of directors.
ASSET/LIABILITY MANAGEMENT. Within 60 days of this Agreement, the Bank shall submit to the Reserve Bank and the Division an acceptable written plan designed to improve compliance with the Bank's liquidity and sensitivity to market risk policies. The plan shall, at a minimum, address, consider, and include:
ASSET/LIABILITY MANAGEMENT. (1) Within thirty (30) days, the Board shall adopt, implement, and thereafter ensure Bank adherence to written liquidity, interest rate risk, and asset and liability management policies that conform to regulatory guidance. In formulating these policies, the Board shall refer to the Liquidity and Funds Management booklet of the Comptroller's Handbook, issued February 2001. The policy shall provide for a coordinated asset/liability management strategy and, at a minimum, address:
(a) duties and responsibilities of the Asset Liability Committee (ALCO);
(b) adequate management reports that enable the Board and management to monitor the Bank's liquidity and interest rate risk positions and maintain both at adequate levels;
(c) the liquidity, maturity and pledging requirements of the investment portfolio;
(d) development of a liquidity contingency plan;
(e) limits on concentrations of funding sources; and
(f) periodic review of the Bank's adherence to the policy.
(2) Upon adoption, a copy of the written policies shall be forwarded to the ADC for review.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the policies developed pursuant to this Article.
