CONTINGENCY FUNDING PLAN. (1) Within sixty (60) days, the Board shall expand the Bank’s Contingency Funding Plan to ensure the Bank operates with adequate backup sources of liquidity in relation to the Bank’s needs. The formalized written Contingency Funding plan should address the responsibilities of senior management during a funding crisis and include at a minimum:
(a) liquidity crisis triggers relating to regulatory matters (e.g., formal enforcement action, drop in capital category, reduction in composite rating) and asset quality deterioration;
(b) determination of the appropriate frequency for meetings of the Liquidity Emergency Team to address a potential liquidity crisis;
(c) determination of an appropriate communication strategy to the Bank’s wholesale funds providers and bank customers;
(d) establishment of guidelines for paying premiums on deposits to ensure regulatory compliance if the Bank drops to “Adequately Capitalized” under bank regulations; and
(e) development and implementation of a testing schedule to validate the Bank’s Contingency Funding Plan.
(2) Within sixty (60) days, the Bank shall develop, implement, and adhere to a plan to improve the Bank’s asset-based liquidity and reduce the Bank’s reliance on noncore liabilities to fund long term assets as those terms are defined in the Federal Deposit Insurance Corporation Uniform Bank Performance Report. Such actions shall include, but not be limited to:
(a) measures to maintain sufficient asset based liquidity;
(b) reduction of wholesale or credit sensitive liabilities; and
(c) revision of the Bank's risk limits for reliance on wholesale or credit sensitive liabilities from a single provider or in aggregate to fund long- term assets in light of the requirement of this Article.
(3) The Board shall immediately implement, and shall thereafter ensure adherence to its terms of this article. Monthly reports shall set forth liquidity requirements and sources. Copies of these reports shall be forwarded to the Assistant Deputy Comptroller.
CONTINGENCY FUNDING PLAN. (1) Within sixty (60) days, the Board shall adopt a comprehensive Bank-specific Contingency Funding Plan consistent with the guidelines set forth in the “Liquidity” booklet of the Comptroller’s Handbook and the Interagency Policy Statement on Funding and Liquidity Risk Management, OCC Bulletin 2010-13, March 22, 2010. The plan shall be written and shall, at a minimum, include:
(a) a statement of the Board’s strategy for maintaining adequate sources of stable funding given the Bank’s anticipated liquidity and funding needs;
(b) a definition of a liquidity crisis for the Bank;
(c) an identification of early warning liquidity triggers;
(d) an explicit quantification of the sources and uses of liquidity in stressed scenarios that correspond to the early warning liquidity triggers;
(e) detailed action plans to identify and obtain sources of liquidity to meet projected shortfalls;
(f) an identification of responsible bank personnel to declare, manage, and resolve a liquidity crisis;
(g) an internal and external communication process, including a process for reporting to the Board, for disseminating relevant information; and
(h) a process of regular testing to ensure that the plan is operationally sound, including periodic testing of unused funding sources.
(2) Upon adoption, the Board shall submit a copy of the Contingency Funding Plan, or any subsequent amendments or changes to that Plan, to the Assistant Deputy Comptroller for determination of no supervisory objection. Upon receiving a determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall implement and thereafter ensure adherence to the program.
CONTINGENCY FUNDING PLAN. (1) Within ninety (90) days, the Board shall adopt and the Bank shall implement and thereafter ensure adherence to a revised Contingency Funding Plan consistent with the guidance in the Interagency Policy on Funding and Liquidity Risk Management contained in OCC Bulletin 2010-13 (March 22, 2010) that at a minimum:
(a) identifies Bank specific stress events (e.g., deterioration in asset quality, negative press coverage, etc.) and delineates various levels of severity for each event;
(b) requires the Bank to consistently perform and document scenario analyses that quantify expected funding needs and sources during stress events;
(c) incorporates triggers beyond the regulatory-directed liquidity limits, and
(d) identifies responsible personnel and establishes a reporting structure in the event the plan is enacted.
(2) Upon adoption, the Board shall promptly forward a copy of the Contingency Funding Plan to the ADC for review.
CONTINGENCY FUNDING PLAN. (1) Within sixty (60) days, the Board shall review and revise the Bank’s Contingency Funding Plan (CFP) to address matters in the XXX. The Board shall conform to the Comptroller’s Handbook, Liquidity, dated February 2001, and to OCC Bulletin 2010-13 Liquidity: Final Interagency Policy Statement on Funding and Liquidity Risk Management. The CFP shall be enhanced, at a minimum, to address:
(a) defining triggers, including asset quality indicators, for enacting the plan;
(b) quantifying the impact and available sources of funds under various crisis scenarios;
(c) developing action plans to address any significant funding shortfalls and provide mitigating factors where necessary;
(d) developing action plans for reducing risk under each scenario;
(e) defining responsibilities and decision-making authority for all personnel in a crisis situation;
(f) defining specific frequency for testing of correspondent lines.
(2) Within sixty (60) days, the Board shall ensure that appropriate and prudent risk limits are established and incorporated into the Bank’s ALCO policy. Upon adoption, a copy of the enhanced CFP and ALCO policy shall be forwarded to the Assistant Deputy Comptroller for review.
CONTINGENCY FUNDING PLAN. (1) Within sixty (60) days, the Board shall establish a plan that ensures the Bank operate with a robust liquidity monitoring program and maintain adequate sources of liquidity in relation to the Bank’s needs. The formalized written liquidity plan should address the responsibilities of senior management during a funding crisis and include at a minimum:
(a) a contingency funding plan that forecasts funding needs and funding sources under a stressed scenario;
(b) establishment of triggers for initiating the plan;
(c) identification of available sources of funding including quantity and order of preference;
(d) identify specific scenarios that may limit the availability of certain funding sources; and
(e) actions that management will take to ensure funding is obtained at a reasonable cost.
(2) Monthly reports shall set forth liquidity requirements and sources. Copies of these reports shall be forwarded to the Assistant Deputy Comptroller.
CONTINGENCY FUNDING PLAN. (1) Within sixty (60) days, the Board shall review and revise the Bank’s Contingency Funding Plan (CFP). The Board shall refer to the “Liquidity” booklet of the Comptroller’s Handbook as well as other current regulatory materials for guidance. The CFP shall be expanded, at a minimum, to address:
(a) defining responsibilities and decision-making authority for all personnel in a crisis situation;
(b) defining and quantifying a liquidity crisis, including early warning indicators to monitor large changes in sources and uses of funds;
(c) developing early warning liquidity triggers applicable to the bank. Examples of warning triggers include but are not limited to: reduced ability to access wholesale funding, a run on deposits, credit deterioration, or a decline in your composite CAMELS ratings; and
(d) documenting and analyzing the amount, availability and timeliness of obtaining funding sources available to the Bank (i.e., Federal Home Loan Bank borrowings, Fed discount window, and holding company capacity) in relation to the various levels of a liquidity crisis.
(2) Upon adoption, a copy of the enhanced CFP shall be forwarded to the Assistant Deputy Comptroller for review.
CONTINGENCY FUNDING PLAN. (1) Within sixty (60) days the Board shall revise, implement, and ensure adherence to a comprehensive Contingency Funding Plan consistent with the guidelines set forth in Liquidity, L-L, of the Comptroller’s Handbook. The plan shall, among other things, address ways to improve the Bank’s liquidity position and maintain adequate sources of stable funding given the Bank’ s anticipated liquidity and funding needs.
(2) Upon adoption, a copy of the plan shall be promptly forwarded to the Assistant Deputy Comptroller for review and determination of no supervisory objection.
CONTINGENCY FUNDING PLAN. (1) Within sixty (60) days of this Agreement, the Board shall prepare and submit to the Assistant Deputy Comptroller for a prior written determination of no supervisory objection, a contingency funding plan that forecasts funding needs and funding sources under a stressed scenario, and that should:
(a) establish measurable triggers to alert management to potential problems, and assign management responsibilities during stressed liquidity scenarios;
(b) identify, quantify, establish, and rank all sources of funding by preference for the various scenarios including asset side funding, liability side funding and off-balance sheet funding, and provide management’s likely response in each stress scenario;
(c) represent management’s best estimate of balance sheet and cash flow changes that may result from a liquidity or credit event;
(d) ensure that administrative policies and procedures are consistent with the Board’s guidance and risk tolerances; and
(e) provide for Board review and approval as contingencies change, but in no event, less than annually.
(2) After the OCC has advised the Bank that it does not take supervisory objection to the program required by this Article, the Board shall immediately implement, and shall thereafter ensure adherence to, the terms of the program.
CONTINGENCY FUNDING PLAN. (1) Within sixty (60) days of the date, the Board shall expand and document the bank’s contingency funding plan (CFP). The plan shall provide for a coordinated strategy and, at a minimum, address:
(a) identification of liquidity event triggers for CFP purposes;
(b) crisis liquidity scenarios, including which funding sources would be available under various circumstances;
(c) projected sources and uses under stressed scenarios. Management should identify and rank all prospective funding sources, both asset and liabilities, including all rate sensitive and insensitive funding as well as credit sensitive funding; and
(d) estimated timeframes for accessing funds.
(2) Upon adoption, a copy of the written plan shall be forwarded to the Assistant Deputy Comptroller for review.
(3) The Board, or a committee thereof, shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the plan developed pursuant to this Article.
CONTINGENCY FUNDING PLAN. (1) Within ninety (90) days, the Board shall adopt, implement, and ensure adherence to a comprehensive Contingency Funding Plan that, on a monthly basis, forecasts funding needs and funding sources under different stress scenarios which represent management’s best estimate of balance sheet changes that may result from a liquidity or credit event. Each scenario should include a minimum of twelve months of projected cash flows. The contingency funding plan shall include:
(a) specific plans detailing how the Bank will comply with restrictions or requirements set forth in this Agreement and 12 U.S.C. § 1831o, including the restrictions against brokered deposits in 12 C.F.R. § 337.6;
(b) the preparation of reports which identify and quantify all sources of funding and funding obligations under best case and worst case scenarios, including asset funding, liability funding, and off-balance sheet funding; and
(c) procedures which ensure that the Bank’s contingency funding practices are consistent with the Board’s guidance and risk tolerances.
