LIQUIDITY RISK MANAGEMENT. (1) Within thirty (30) days of the date of this Agreement, the Board shall adopt a revised written Liquidity Risk Management Program (“Liquidity Program”) for the Bank. The Liquidity Program shall provide for the identification, measurement, monitoring, and control of the Bank’s liquidity risk exposure, and shall emphasize the importance of cash flow projections, diversified funding sources, a cushion of highly liquid assets, robust liquidity stress testing scenario analyses, and a formal, well-developed contingency funding plan as primary tools for measuring and managing liquidity risk. Refer to the “Interagency Policy Statement on Funding and Liquidity Risk Management,” dated March 22, 2010, (OCC Bulletin 2010-13); the “Addendum to the Interagency Policy Statement on Funding and Liquidity Risk Management: Importance of Contingency Funding Plans,” dated July 28, 2023; and the “Liquidity,” booklet of the Comptroller’s Handbook, for guidance. (2) In addition to the general requirements set forth above, the Bank’s Liquidity Program shall, at a minimum: (a) provide specific assigned accountability for development, execution, and oversight of liquidity risk management, including oversight by both the Board, or committee thereof, and Bank management; (b) include appropriate policies and procedures for identifying, measuring, monitoring, and controlling liquidity risk exposures, that include at a minimum: (i) assignment of accountability and processes for monitoring and managing intraday liquidity; (ii) procedures and reporting to assess the risks related to deposit runoff, rollovers, wholesale, and alternative funding sources; and (iii) reasonable limits to manage and control liquidity risk that are commensurate with the Bank’s complexity, business activities, and the Board’s risk appetite, that include at a minimum: (1) minimum levels of highly liquid assets; (2) limits or triggers on the structure of short-term and long- term funding of the Bank’s asset base; (3) limitations on funding concentrations and other strategies to ensure diversification of funding sources; and (4) limitations on contingent liabilities in aggregate and by individual category. (c) include a no less than monthly generated sources and uses report to identify appropriate funding sources to meet projected funding needs over a short- and intermediate-term horizon (i.e., 30-, 60-, 90-, and 180-days); and (d) include a no less than quarterly contingency funding plan that projects the Bank’s funding needs, including the development of cash flow projections under expected, adverse, moderately adverse, and severely adverse conditions, that at a minimum: (i) includes the identification of plausible stress events relating to internal and external events or circumstances, including systemic or market events, that could lead to a Bank liquidity crisis; (ii) determines how each identified stress event will affect the Bank’s ability to obtain funding needs under different levels of severity; (iii) has quantitative projections of expected funding needs and funding capacity based on realistic assessments of the behaviors of funding providers during stress events; and (iv) includes a provision for management processes, reporting, and internal as well as external communication throughout the stress event. (3) The Board shall review the effectiveness of the Liquidity Program at least annually, no later than April 15th of each year, and more frequently if necessary or if required by the OCC in writing, and amend the Liquidity Program as needed or directed by the ADC in writing.
Appears in 2 contracts
Samples: Banking Compliance Agreement, Compliance Agreement (Kentucky First Federal Bancorp)
LIQUIDITY RISK MANAGEMENT. (1) Within thirty (30) days of the date of this Agreementdays, the Board shall adopt develop, adopt, and thereafter ensure compliance with a revised written Liquidity Risk Management Program comprehensive liquidity risk management policy (“Liquidity ProgramPolicy”) for that incorporates prudent risk management standards as set forth in the Bank“Liquidity” booklet of the Comptroller’s Handbook (June 2012) and OCC Bulletin 2010-13, Interagency Policy Statement on Funding and Liquidity Risk Management, dated March 22, 2010. The Liquidity Program shall provide for the identification, measurement, monitoring, and control of the Bank’s liquidity risk exposure, and Policy shall emphasize the importance of cash flow sources and uses projections, diversified funding sources, stress testing, a cushion of highly liquid assets, robust liquidity stress testing scenario analyses, and a formal, well-developed contingency funding plan as primary tools for measuring and managing liquidity risk. Refer to the “Interagency Policy Statement on Funding and Liquidity Risk Management,” dated March 22, 2010, (OCC Bulletin 2010-13); the “Addendum to the Interagency Policy Statement on Funding and Liquidity Risk Management: Importance of Contingency Funding Plans,” dated July 28, 2023; and the “Liquidity,” booklet of the Comptroller’s Handbook, for guidance.
(2) In addition to the general requirements set forth above, the Liquidity Policy shall address the weaknesses in the Bank’s Liquidity Program shallliquidity risk management identified in the most recent XXX and, at a minimum, shall:
(a) provide specific assigned accountability for development, execution, and oversight of set liquidity risk managementpolicy parameters for, including oversight by both the Board, or committee thereof, and Bank management;
(b) include appropriate policies and procedures for identifying, measuring, monitoring, and controlling liquidity risk exposures, that include at a minimum:
(i) assignment of accountability and processes for monitoring and managing intraday liquidityminimum on-hand liquid assets;
(ii) procedures and reporting to assess the risks related to deposit runoff, rollovers, wholesale, and alternative funding sourcesmaximum loans-to-deposits ratios; and
(iii) reasonable limits to manage maximum dependency on wholesale funding source;
(b) require quarterly Board reports that include relevant, complete and control liquidity risk that are commensurate with accurate information:
(i) on the Bank’s complexity, business activities, and liquidity position against the Board’s risk appetite, that include at a minimum:
policy limits set pursuant to paragraph (11)(a) minimum levels of highly liquid assetsthis Article;
(2ii) limits or triggers on the structure sources and uses of short-term and long- term funding of the Bank’s asset basefunds;
(3iii) limitations on funding concentrations and other strategies to ensure diversification certificate of funding sourcesdeposits rollover risk; and
(4iv) limitations on contingent liabilities in aggregate and by individual category.liquidity stress tests;
(c) include a no less than monthly generated sources and uses report to identify appropriate funding sources to meet projected funding needs over a short- and intermediate-term horizon (i.e., 30-, 60-, 90-, and 180-days); and
(d) include a no less than quarterly contingency funding plan that projects the Bank’s funding needsincorporates, including the development of cash flow projections under expected, adverse, moderately adverse, and severely adverse conditions, that at a minimum:
(i) includes the identification of plausible stress events relating to internal and external events or circumstances, including systemic or market events, that could lead to a Bank liquidity crisis;
(ii) determines how each identified stress event will affect the Bank’s ability to obtain funding needs under different levels of severity;
(iii) has quantitative projections and evaluations of expected funding needs and funding capacity based on realistic assessments of the behaviors of funding providers during moderate and severe stress events, and that incorporates, at a minimum:
(i) designation of personnel and assigned responsibilities;
(ii) a range of crisis scenarios, including probability of occurrence and severity;
(iii) clear and reasonable liquidity event triggers and action items for each crisis scenario;
(iv) identification of reliable and accessible continent sources of funding for each scenario tests in subparagraph (iii) above; and
(ivv) includes a provision for management processes, reporting, periodic testing of available funding sources and internal as well as external communication throughout reporting of all results to the stress eventBoard.
(3) The Board shall review the effectiveness of the Liquidity Program at least annually, no later than April 15th of each year, and more frequently if necessary or if required by the OCC in writing, and amend the Liquidity Program as needed or directed by the ADC in writing.
Appears in 1 contract
Samples: Compliance Agreement
LIQUIDITY RISK MANAGEMENT. (1) Within thirty (30) days of the date of this AgreementBy January 29, 2024, the Board shall adopt a submit to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection an acceptable revised written Liquidity Risk Management Program (“Liquidity Program”) for the Bank. The This Liquidity Program shall provide for the identification, measurement, monitoring, and control of the Bank’s liquidity risk exposure, and shall emphasize the importance of cash flow projections, diversified funding sources including establishing additional funding sources, a cushion of highly liquid assets, robust liquidity stress testing scenario analyses, and a formal, well-developed contingency funding plan as primary tools for measuring and managing liquidity risk. Refer to the “Interagency Policy Statement on Funding and Liquidity Risk Management,” dated March 22, 2010, (OCC Bulletin 2010-13); the “Addendum to the Interagency Policy Statement on Funding and Liquidity Risk Management: Importance of Contingency Funding Plans,” dated July 28, 2023; and the “Liquidity,” booklet of the Comptroller’s Handbook, for guidance.
(2) . In addition to the general requirements set forth above, the Bank’s Liquidity Program shall, at a minimum:
(a) provide specific assigned accountability for developmentidentify, executionestablish, and oversight of liquidity risk management, including oversight by both the Board, or committee thereof, and Bank managementtest additional contingent funding lines;
(b) include identify appropriate policies triggers and procedures for identifyinglimits to manage liquidity risk, measuring, monitoring, commensurate with the Bank’s complexity and controlling liquidity risk exposures, that include at a minimum:
(i) assignment of accountability and processes for monitoring and managing intraday liquiditybusiness activities;
(iic) procedures and reporting to assess the risks related to deposit runoff, runoff or rollovers, wholesale, ;
(d) detail action plans to identify and alternative funding sourcesobtain sources of liquidity to meet projected shortfalls from existing sources under both expected and adverse conditions; and
(iiie) reasonable limits to manage and control liquidity risk include a Contingency Funding Plan that are commensurate with the Bank’s complexityincorporates, business activities, and the Board’s risk appetite, that include at a minimum:
(1) minimum levels of highly liquid assets;
(2) limits or triggers on the structure of short-term , a quantitative projection and long- term funding of the Bank’s asset base;
(3) limitations on funding concentrations and other strategies to ensure diversification of funding sources; and
(4) limitations on contingent liabilities in aggregate and by individual category.
(c) include a no less than monthly generated sources and uses report to identify appropriate funding sources to meet projected funding needs over a short- and intermediate-term horizon (i.e., 30-, 60-, 90-, and 180-days); and
(d) include a no less than quarterly contingency funding plan that projects the Bank’s funding needs, including the development of cash flow projections under expected, adverse, moderately adverse, and severely adverse conditions, that at a minimum:
(i) includes the identification of plausible stress events relating to internal and external events or circumstances, including systemic or market events, that could lead to a Bank liquidity crisis;
(ii) determines how each identified stress event will affect the Bank’s ability to obtain funding needs under different levels of severity;
(iii) has quantitative projections evaluation of expected funding needs and funding capacity based on realistic assessments of the behaviors of funding providers during stress events; and
(iv) includes a provision definition of a liquidity crisis for management processesthe Bank; definition and prioritization of contingent liquidity sources; and periodic stress testing, reporting, and internal as well as external communication throughout the stress event.
(3) The Board shall review the effectiveness of the Liquidity Program at least annually, no later than April 15th of each year, and more frequently if necessary or if required by the OCC in writing.
(2) Within thirty (30) days following receipt of the Assistant Deputy Comptroller’s written determination of no supervisory objection to the Liquidity Program, the Board shall adopt and amend Bank management, subject to Board review and ongoing monitoring, shall immediately implement and adhere to the Liquidity Program as needed and any amendments or directed revisions thereto.
(3) The Board shall review and update the Liquidity Program, at least annually, and more frequently if necessary or if required by the ADC Assistant Deputy Comptroller in writing. The Board shall submit the revised Liquidity Program to the Assistant Deputy Comptroller for prior written determination of no supervisory objection. At the next Board meeting following receipt of the Assistant Deputy Comptroller’s written determination of no supervisory objection, the Board shall adopt and Bank management shall immediately implement and adhere to the revised Liquidity Program and any amendments or revisions thereto.
Appears in 1 contract
Samples: Compliance Agreement
LIQUIDITY RISK MANAGEMENT. (1) Within thirty sixty (3060) days of the date of this Agreement, the Board shall adopt a revised submit to the ADC for review and prior written determination of no supervisory objection an acceptable written Liquidity Risk Management Program (“Liquidity Program”) for the Bank. The Liquidity Program shall provide for the identification, measurement, monitoring, and control of the Bank’s liquidity risk exposure, and shall emphasize the importance of cash flow projections, diversified funding sources, a cushion of highly liquid assets, robust liquidity stress testing scenario analyses, and a formal, well-developed contingency funding plan as primary tools for measuring and managing liquidity risk. Refer to the “Interagency Policy Statement on Funding and Liquidity Risk Management,” dated March 22, 2010, (OCC Bulletin 2010-13); the “Addendum to the Interagency Policy Statement on Funding and Liquidity Risk Management: Importance of Contingency Funding Plans,” dated July 28, 2023; , and the “Liquidity,” booklet of the Comptroller’s Handbook, for guidance.
(2) In addition to the general requirements set forth above, the Bank’s Liquidity Program shall, at a minimum:
(a) provide specific assigned accountability for development, execution, and oversight of liquidity risk management, including oversight by both the Board, or committee thereof, and Bank management;
(b) include appropriate policies and procedures for identifying, measuring, monitoring, and controlling liquidity risk exposures, that include includes at a minimum:
(i) assignment of accountability procedures to ensure that sufficient funds or access to funds exist to meet such cash flow needs under both expected and processes for monitoring and managing intraday liquidityadverse conditions, including an adequate cushion to meet any unanticipated cash flow needs;
(ii) procedures and reporting to assess the risks related to deposit runoff, rollovers, wholesale, and alternative funding sources; and
(iii) reasonable limits assignment of accountability and procedures to manage monitor, escalate, and control address any breaches of established liquidity limits.
(b) provide adequate risk that are commensurate with measurement and monitoring systems, including processes and reporting to assess, on an ongoing basis, the Bank’s complexity, business activities, current and the Board’s risk appetite, that include at a minimum:
(1) minimum levels of highly liquid assets;
(2) limits or triggers on the structure of short-term and long- term funding of the Bank’s asset base;
(3) limitations on funding concentrations and other strategies to ensure diversification of funding sources; and
(4) limitations on contingent liabilities in aggregate and by individual category.
(c) include a no less than monthly generated sources and uses report to identify appropriate funding sources to meet projected funding needs over a short- and intermediate-term horizon (i.e., 30-, 60-, 90-, and 180-days); and
(d) include a no less than quarterly contingency funding plan that projects the Bank’s funding needs, including the development of cash flow projections under expected, adverse, moderately adverse, both expected and severely adverse conditions, and considering the changes in depositor behavior, interest rates and capital levels;
(c) detailed identification of sources of liquidity to meet projected shortfalls from existing sources under both expected and adverse conditions; and
(d) include a Contingency Funding Plan that incorporates, at a minimum:
(i) includes the identification of plausible stress events relating to internal and external events or circumstances, including systemic or market events, that could lead to a Bank liquidity crisis;
(ii) determines determinations of how each identified stress event will affect the Bank’s ability to obtain funding needs under different levels of severity;; and
(iii) has a quantitative projections projection and evaluation of expected funding needs and funding capacity based on realistic assessments of the behaviors of funding providers during stress events; and
(iv) includes a provision for management processes, reporting, and internal as well as external communication throughout the stress event.
(3) Within thirty (30) days following receipt of the ADC’s written determination of no supervisory objection to the Liquidity Program, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and adhere to the Liquidity Program and any amendments or revisions thereto.
(4) The Board shall review the effectiveness of the Liquidity Program at least annually, no later than April 15th of each year, and more frequently if necessary or if required by the OCC in writing, and amend the Liquidity Program as needed or directed by the ADC in writing. The Bank shall submit the revised Liquidity Program to ADC for prior written determination of no supervisory objection. At the next Board meeting following receipt of the ADC’s written determination of no supervisory objection, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and adhere to the revised Liquidity Program and any amendments or revisions thereto.
Appears in 1 contract
Samples: Compliance Agreement
LIQUIDITY RISK MANAGEMENT. (1) Within thirty ninety (3090) days of the date of this Agreement, the Board shall adopt a revised submit to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection an acceptable written Liquidity Risk Management Program (“Liquidity Program”) for the Bank. The Liquidity Program shall provide for the identification, measurement, monitoring, and control of the Bank’s liquidity risk exposure, and shall emphasize the importance of cash flow projections, diversified funding sources, a cushion of highly liquid assets, robust liquidity stress testing scenario analyses, and a formal, well-developed contingency funding plan as primary tools for measuring and managing liquidity risk. Refer to the “Interagency Policy Statement on Funding and Liquidity Risk Management,” dated March 22, 2010, (OCC Bulletin 2010-13); the “Addendum to the Interagency Policy Statement on Funding and Liquidity Risk Management: Importance of Contingency Funding Plans,” dated July 28, 2023; , and the “Liquidity,” booklet of the Comptroller’s Handbook, for guidance.
(2) In addition to the general requirements set forth above, the Bank’s Liquidity Program shall, at a minimum:
(a) provide specific assigned accountability for development, execution, execution and oversight of liquidity risk management, including oversight by both the Board, or committee thereof, Board and Bank senior management;
(b) include appropriate policies and procedures for identifying, measuring, monitoring, and controlling liquidity risk exposures, that include includes at a minimum:
(i) assignment of accountability and processes for monitoring and managing intraday liquidity;
(ii) procedures to ensure that sufficient funds or access to funds exist to meet such cash flow needs under both expected and adverse conditions, including an adequate cushion to meet any unanticipated cash flow needs; and
(iii) procedures and reporting to assess the risks related to deposit runoff, rollovers, wholesale, and alternative funding sources; and;
(iiic) reasonable identify appropriate funding strategies and provide limits to manage and control liquidity risk that are commensurate with the Bank’s complexity, complexity and business activities, activities that considers internal and external factors that could affect the BoardBank’s risk appetiteliquidity, that include at a minimum:
(1i) limits or triggers placed on projected net cash flow positions over specified timeframes under both expected and adverse business conditions that are based on realistic assumptions supported by sound historical economic data;
(ii) limits or triggers on funding mismatches and guidelines for minimum and maximum average maturity of the Bank’s assets and liabilities (by category);
(iii) minimum levels of highly liquid assets;
(2iv) minimum levels of committed and collateralized contingent funding sources to meet funding needs in both expected and adverse conditions, which are periodically tested to verify availability and operational capabilities;
(v) limits or triggers on the structure of short-term and long- long-term funding of the Bank’s asset base, under both normal and stressed conditions;
(3vi) limitations on funding concentrations and other strategies to ensure diversification of funding sources; and
(4vii) limitations on contingent liabilities in aggregate and by individual category.
(c) include a no less than monthly generated sources and uses report to identify appropriate funding sources to meet projected funding needs over a short- and intermediate-term horizon (i.e., 30-, 60-, 90-, and 180-days); and;
(d) include a no less than quarterly contingency funding plan that projects provide adequate risk measurement and monitoring systems, including processes and reporting to assess, on an ongoing basis, the Bank’s current and projected funding needs, including the development of cash flow projections under expected, adverse, moderately adverse, both expected and severely adverse conditions, and considering the changes in depositor behavior, interest rates and capital levels;
(e) detailed identification of sources of liquidity to meet projected shortfalls from existing sources under both expected and adverse conditions; and
(f) include a Contingency Funding Plan that incorporates, at a minimum:
(i) includes the identification of plausible stress events relating to internal and external events or circumstances, including systemic or market events, that could lead to a Bank liquidity crisis;
(ii) determines determinations of how each identified stress event will affect the Bank’s ability to obtain funding needs under different levels of severity;
(iii) has a quantitative projections projection and evaluation of expected funding needs and funding capacity based on realistic assessments of the behaviors of funding providers during stress events; and
(iv) includes a provision for management processes, reporting, and internal as well as external communication throughout the stress event.
(3) Within thirty (30) days following receipt of the Assistant Deputy Comptroller’s written determination of no supervisory objection to the Liquidity Program, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and adhere to the Liquidity Program and any amendments or revisions thereto.
(4) The Board shall review the effectiveness of the Liquidity Program at least annually, annually but no later than April 15th January 31 of each year, and more frequently if necessary or if required by the OCC in writing, writing and amend the Liquidity Program as needed or directed by the ADC Assistant Deputy Comptroller in writing. The Bank shall submit the revised Liquidity Program to the Assistant Deputy Comptroller for prior written determination of no supervisory objection. At the next Board meeting following receipt of the Assistant Deputy Comptroller’s written determination of no supervisory objection, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and adhere to the revised Liquidity Program and any amendments or revisions thereto.
Appears in 1 contract
Samples: Compliance Agreement (Generations Bancorp NY, Inc.)
LIQUIDITY RISK MANAGEMENT. (1) Within thirty sixty (3060) days of the date of this Agreement, the Board shall adopt a revised submit to the ADC for review and prior written determination of no supervisory objection an acceptable written Liquidity Risk Management Program (“Liquidity Program”) for the Bank. The Liquidity Program shall provide for the identification, measurement, monitoring, and control of the Bank’s liquidity risk exposure, and shall emphasize the importance of cash flow projections, diversified funding sources, a cushion of highly liquid assets, robust liquidity stress testing scenario analyses, and a formal, well-developed contingency funding plan as primary tools for measuring and managing liquidity risk. Refer For guidance, refer to the OCC Bulletin 2010-13, “Interagency Policy Statement on Funding and Liquidity Risk Management,” dated March 22, (Mar. 2010, (OCC Bulletin 2010-13); the “Addendum to the Interagency Policy Statement on Funding and Liquidity Risk Management: Importance of Contingency Funding Plans,” dated July 28, 2023; and the “Liquidity,” booklet of the Comptroller’s Handbook, for guidance.the
(2) In addition to the general requirements set forth above, the Bank’s Liquidity Program shall, at a minimum:
(a) provide specific assigned accountability for development, execution, and oversight of liquidity risk management, including oversight by both the Board, or committee thereof, Board and Bank senior management;
(b) include appropriate policies and procedures for identifying, measuring, monitoring, and controlling liquidity risk exposures, that include includes at a minimum:
(i) assignment of accountability and processes for monitoring and managing intraday liquidity;
(ii) procedures to ensure that sufficient funds or access to funds exist to meet such cash flow needs under both expected and adverse conditions, including an adequate cushion to meet any unanticipated cash flow needs; and
(iii) procedures and reporting to assess the risks related to deposit runoff, rollovers, wholesale, and alternative funding sources; and;
(iiic) reasonable identify appropriate funding strategies and provide limits to manage and control liquidity risk that are commensurate with the Bank’s complexity, complexity and business activities, activities that considers internal and external factors that could affect the BoardBank’s risk appetiteliquidity, that include at a minimum:
(1i) limits or triggers placed on projected net cash flow positions over specified time frames under both expected and adverse business conditions that are based on realistic assumptions supported by sound historical economic data;
(ii) limits or triggers on funding mismatches and guidelines for minimum and maximum average maturity of the Bank’s assets and liabilities (by category);
(iii) minimum levels of highly liquid assets;
(2iv) minimum levels of committed and collateralized contingent funding sources to meet funding needs in both expected and adverse conditions, which are periodically tested to verify availability and operational capabilities;
(v) limits or triggers on the structure of short-term and long- long-term funding of the Bank’s asset base, under both normal and stressed conditions;
(3vi) limitations on funding concentrations and other strategies to ensure diversification of funding sources; and
(4vii) limitations on contingent liabilities in aggregate and by individual category.
(c) include a no less than monthly generated sources and uses report to identify appropriate funding sources to meet projected funding needs over a short- and intermediate-term horizon (i.e., 30-, 60-, 90-, and 180-days); and
(d) include a no less than quarterly contingency funding plan that projects provide adequate risk measurement and monitoring systems, including processes and reporting to assess, on an ongoing basis, the Bank’s current and projected funding needs, including the development of cash flow projections under expected, adverse, moderately adverse, both expected and severely adverse conditions, that at a minimum:
(i) includes and considering the identification of plausible stress events relating to internal and external events or circumstanceschanges in depositor behavior, including systemic or market events, that could lead to a Bank liquidity crisis;
(ii) determines how each identified stress event will affect the Bank’s ability to obtain funding needs under different levels of severity;
(iii) has quantitative projections of expected funding needs and funding capacity based on realistic assessments of the behaviors of funding providers during stress events; and
(iv) includes a provision for management processes, reportinginterest rates, and internal as well as external communication throughout the stress eventcapital levels.
(3) Within thirty (30) days following receipt of the ADC’s written determination of no supervisory objection to the Liquidity Program, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and adhere to the Liquidity Program and any amendments or revisions thereto.
(4) Within thirty (30) days of the beginning of each calendar quarter, Bank management shall prepare, subject to review and approval by the Board and the Compliance Committee, a report identifying current liquidity requirements and sources for the quarter and projecting liquidity requirements and sources for the upcoming quarter period (“Periodic Liquidity Report”) to enable the Board and the Compliance Committee to recognize longer-term liquidity needs. Copies of each Periodic Liquidity Report, and any Board comments, shall be forwarded to ADC within sixty (60) days of the beginning of each calendar quarter.
(5) The Board shall review the effectiveness of the Liquidity Program at least annually, no later than April 15th of each year, and more frequently if necessary or if required by the OCC in writing, and amend the Liquidity Program as needed or directed by the ADC in writing. The Bank shall submit the revised Liquidity Program to the ADC for prior written determination of no supervisory objection. At the next Board meeting following receipt of the ADC’s written determination of no supervisory objection, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and adhere to the revised Liquidity Program and any amendments or revisions thereto.
Appears in 1 contract
Samples: Compliance Agreement
LIQUIDITY RISK MANAGEMENT. (1) Within thirty (By November 30) days of the date of this Agreement, 2023, the Board shall adopt a submit to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection an acceptable revised and updated written Liquidity Risk Management Program (“Liquidity Program”) for the Bank. The This Liquidity Program shall provide for the identification, measurement, monitoring, and control of the Bank’s liquidity risk exposure, and shall emphasize the importance of cash flow projections, diversified funding sources, a cushion of highly liquid assets, robust liquidity stress testing scenario analyses, and a formal, well-well- developed contingency funding plan as primary tools for measuring and managing liquidity risk. Refer to the “Interagency Policy Statement on Funding and Liquidity Risk Management,” dated March 22, 2010, (OCC Bulletin 2010-13); the “Addendum to the Interagency Policy Statement on Funding and Liquidity Risk Management: Importance of Contingency Funding Plans,” dated July 28, 2023; and the “Liquidity,” booklet of the Comptroller’s Handbook, for guidance.
(2) In addition to the general requirements set forth above, the Bank’s Liquidity Program shall, at a minimum:
(a) provide specific assigned accountability for developmentidentify strategies, executionpolicies, procedures, and oversight of limits to manage liquidity risk managementrisk, including oversight by both commensurate with the Board, or committee thereof, Bank’s complexity and Bank managementbusiness activities;
(b) include appropriate policies and procedures for identifyingassess, measuringon an ongoing basis, monitoring, and controlling liquidity risk exposures, that include at a minimum:
(i) assignment of accountability and processes for monitoring and managing intraday liquidity;
(ii) procedures and reporting to assess the risks related to deposit runoff, rollovers, wholesale, and alternative funding sources; and
(iii) reasonable limits to manage and control liquidity risk that are commensurate with the Bank’s complexity, business activities, current and the Board’s risk appetite, that include at a minimum:
(1) minimum levels of highly liquid assets;
(2) limits or triggers on the structure of short-term and long- term funding of the Bank’s asset base;
(3) limitations on funding concentrations and other strategies to ensure diversification of funding sources; and
(4) limitations on contingent liabilities in aggregate and by individual category.
(c) include a no less than monthly generated sources and uses report to identify appropriate funding sources to meet projected funding needs over a short- and intermediate-term horizon (i.e., 30-, 60-, 90-, and 180-days); and
(d) include a no less than quarterly contingency funding plan that projects the Bank’s funding needs, including the development of cash flow projections under expected, adverse, moderately adverse, both expected and severely adverse conditions;
(c) ensure that sufficient funds or access to funds exist to meet those needs under both expected and adverse conditions;
(d) assess the risks related to brokered deposit restrictions, deposit runoff, or rollovers;
(e) detail action plans to identify and obtain sources of liquidity to meet projected shortfalls from existing sources under both expected and adverse conditions; and
(f) include an updated Contingency Funding Plan that incorporates, at a minimum:
(i) includes the identification of plausible stress events relating to internal , a quantitative projection and external events or circumstances, including systemic or market events, that could lead to a Bank liquidity crisis;
(ii) determines how each identified stress event will affect the Bank’s ability to obtain funding needs under different levels of severity;
(iii) has quantitative projections evaluation of expected funding needs and funding capacity based on realistic assessments of the behaviors of funding providers during stress events; and
(iv) includes a definition of a liquidity crisis for the Bank; an identification of early warning liquidity triggers; and provision for management processes, reporting, and internal as well as external communication throughout the stress event.
(32) The Within thirty (30) days following receipt of the Assistant Deputy Comptroller’s written determination of no supervisory objection to the Liquidity Program, the Board shall adopt and Bank management, subject to Board review the effectiveness of and ongoing monitoring, shall immediately implement and adhere to the Liquidity Program at least annually, no later than April 15th of each year, and more frequently if necessary any amendments or if required by the OCC in writing, and amend the Liquidity Program as needed or directed by the ADC in writingrevisions thereto.
Appears in 1 contract
Samples: Compliance Agreement
LIQUIDITY RISK MANAGEMENT. (1) Within thirty sixty (3060) days of the date of this Agreement, the Board shall adopt develop and submit for a revised prior written Liquidity Risk Management Program (“Liquidity Program”) for determination of no supervisory objection, a written liquidity program to ensure the Bank. The Liquidity Program shall provide for the identification, measurement, monitoring, and control of Bank maintains liquidity at a level that is sufficient to sustain the Bank’s liquidity risk exposurecurrent operations and to withstand any anticipated or extraordinary demand against its funding base, and shall emphasize the importance of cash flow projections, diversified funding sources, a cushion of highly liquid assets, robust liquidity stress testing scenario analyses, and a formal, well-developed contingency funding plan as primary tools for measuring and managing liquidity risk. Refer to the “Interagency Policy Statement on Funding and Liquidity Risk Management,” dated March 22, 2010, (OCC Bulletin 2010-13); the “Addendum to the Interagency Policy Statement on Funding and Liquidity Risk Management: Importance of Contingency Funding Plans,” dated July 28, 2023; and the “Liquidity,” booklet of the Comptroller’s Handbook, for guidance.
(2) In addition to the general requirements set forth above, the Bank’s Liquidity Program shall, include at a minimum:
(a) provide specific assigned accountability for development, execution, and oversight of liquidity risk management, including oversight by both the Board, or committee thereof, and Bank managementMeasures to maintain sufficient on-balance sheet liquidity;
(b) include appropriate Measures to ensure limited reliance upon non-core funding sources, including brokered deposits and credit-sensitive wholesale borrowings;
(c) The establishment of additional back-up funding sources;
(d) Policies and procedures to ensure the implementation of adequate liquidity planning tools, to include:
(i) A review of administrative policies and procedures for identifying, measuring, monitoring, to ensure they are consistent with the Board’s guidance and controlling risk tolerances;
(ii) Specific balance sheet liquidity targets that are consistent with the tools used to measure performance;
(iii) Reasonable risk limits to control the level of liquidity risk exposuresthat incorporate forward-looking risk measurements and liability concentration limits such as limits on the amount of funds that may be sourced from any individual customer or groups of customers, or liability concentration limits by instrument; and
(e) A contingency funding plan that include ensures the Bank can remain liquidity solvent through stressed environments and that includes, at a minimum:
(i) assignment Management’s best estimate of accountability and processes for monitoring and managing intraday liquiditybalance sheet changes that may result from a liquidity or credit event;
(ii) procedures and reporting to assess the risks related to deposit runoff, rollovers, wholesale, and alternative funding sources; and
(iii) reasonable limits to manage and control liquidity risk Specific terms or events that are commensurate with the Bank’s complexity, business activities, and the Board’s risk appetite, that include at a minimum:
(1) minimum levels of highly liquid assets;
(2) limits or triggers on the structure of short-term and long- term funding trigger enactment of the Bank’s asset base;
(3) limitations on funding concentrations and other strategies to ensure diversification of funding sources; and
(4) limitations on contingent liabilities in aggregate and by individual category.
(c) include a no less than monthly generated sources and uses report to identify appropriate funding sources to meet projected funding needs over a short- and intermediate-term horizon (i.e., 30-, 60-, 90-, and 180-days); and
(d) include a no less than quarterly contingency funding plan that projects the Bank’s funding needs, including the development of cash flow projections under expected, adverse, moderately adverse, and severely adverse conditions, that at a minimum:
(i) includes the identification of plausible stress events relating to internal and external events or circumstances, including systemic or market events, that could lead to a Bank liquidity crisis;
(ii) determines how each identified stress event will affect the Bank’s ability to obtain funding needs under different levels of severityplan;
(iii) has quantitative projections of expected funding needs Necessary management information systems and funding capacity based on realistic assessments of reporting criteria for use in crises situations;
(iv) Management responsibilities for enacting the behaviors of funding providers during stress eventsplan and for taking specific actions once enacted; and
(ivv) includes a provision Prioritization of all sources of funding for management processesthe various scenarios including asset side funding, reportingliability side funding, and internal as well as external communication throughout the stress eventoff-balance sheet funding.
(32) The After the OCC has advised the Bank that it does not take supervisory objection to the liquidity program developed and submitted as required by paragraph (1) of this Article, the Board shall review the effectiveness of the Liquidity Program at least annuallyimmediately adopt, no later than April 15th of each yearimplement, and more frequently if necessary or if required by shall thereafter ensure adherence to the OCC in writing, and amend the Liquidity Program as needed or directed by the ADC in writingliquidity program.
Appears in 1 contract
Samples: Banking Agreement
LIQUIDITY RISK MANAGEMENT. (1) Within thirty (30) days of the date of this AgreementBy May 31, 2024, the Board shall adopt a revised submit to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection an acceptable revised, written Liquidity Risk Management Program (“Liquidity Program”) for the Bank. The Liquidity Program shall provide for the identification, measurement, monitoring, and control of the Bank’s liquidity risk exposure, and shall emphasize the importance of cash flow projections, diversified funding sources, a cushion of highly liquid assets, robust liquidity stress testing scenario analyses, and a formal, well-developed contingency funding plan as primary tools for measuring and managing liquidity risk. Refer to the “Interagency Policy Statement on Funding and Liquidity Risk Management,” dated March 22, 2010, (OCC Bulletin 2010-13); the “Addendum to the Interagency Policy Statement on Funding and Liquidity Risk Management: Importance of Contingency Funding Plans,” dated July 28, 2023; , and the “Liquidity,” booklet of the Comptroller’s Handbook, for guidance.the
(2) In addition to the general requirements set forth above, the Bank’s Liquidity Program shall, at a minimum:
(a) provide specific assigned accountability for development, execution, execution and oversight of liquidity risk management, including oversight by both the Board, or committee thereof, Board and Bank senior management;
(b) requirements for identification and retention of Asset-Liability Committee members with sufficient knowledge and independence to manage and monitor the Bank’s liquidity;
(c) include appropriate policies and procedures for identifying, measuring, monitoring, and controlling liquidity risk exposures, that include includes at a minimum:
(i) assignment of accountability and processes for monitoring and managing intraday liquidity;
(ii) procedures to ensure that sufficient funds or access to funds exist to meet such cash flow needs under both expected and adverse conditions, including an adequate cushion to meet any unanticipated cash flow needs;
(iii) procedures and reporting to assess the risks related to deposit runoff, rollovers, wholesale, and alternative funding sources; and
(iiiiv) reasonable development of liquidity risk tolerances and limits that are appropriate for the Bank’s size, complexity, and risk profile;
(d) identify appropriate funding strategies and provide limits to manage and control liquidity risk that are commensurate with the Bank’s complexity, complexity and business activities, activities that considers internal and external factors that could affect the BoardBank’s risk appetiteliquidity, that include at a minimum:
(1i) limits or triggers placed on projected net cash flow positions over specified time frames under both expected and adverse business conditions that are based on realistic assumptions supported by sound historical economic data;
(ii) limits or triggers on funding mismatches and guidelines for minimum and maximum average maturity of the Bank’s assets and liabilities (by category);
(iii) minimum levels of highly liquid assets;
(2iv) minimum levels of committed and collateralized contingent funding sources to meet funding needs in both expected and adverse conditions, which are periodically tested to verify availability and operational capabilities;
(v) limits or triggers on the structure of short-term and long- long-term funding of the Bank’s asset base, under both normal and stressed conditions;
(3vi) documented strategies to increase the Bank’s level of non-maturity deposits, as well as reduce the Bank’s cost of funds;
(vii) limitations on funding concentrations and other strategies to ensure diversification of funding sources; and
(4e) limitations provide adequate risk measurement and monitoring systems, including processes and reporting to assess, on contingent liabilities in aggregate and by individual category.
(c) include a no less than monthly generated sources and uses report to identify appropriate funding sources to meet projected funding needs over a short- and intermediate-term horizon (i.e.an ongoing basis, 30-, 60-, 90-, and 180-days); and
(d) include a no less than quarterly contingency funding plan that projects the Bank’s current and projected funding needs, including the development of cash flow projections under expected, adverse, moderately adverse, both expected and severely adverse conditions, and considering the changes in depositor behavior, interest rates and capital levels;
(f) detailed identification of sources of liquidity to meet projected shortfalls from existing sources under both expected and adverse conditions.
(3) By June 30, 2024, the Board shall submit to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection an acceptable revised Contingency Funding Plan that incorporates, at a minimum:
(ia) includes the identification of plausible stress events relating to internal and external events or circumstances, including systemic or market eventsevents and Bank specific scenarios, such as the loss of contingent funding sources that could lead to a Bank liquidity crisis;
(iib) determines determinations of how each identified stress event will affect the Bank’s ability to obtain funding needs under different levels of severity;
(iiic) has a quantitative projections projection and evaluation of expected funding needs and funding capacity based on realistic assessments of the behaviors of funding providers during stress events;
(d) action plans for each stress event, to include roles and responsibilities of the Board and management, frequency and types of reporting to monitor liquidity, steps to raise additional primary sources of liquidity, the use, monitoring of, and prioritization of contingency funding sources, as well as the timing and ability to unpledged and sell assets; and
(ive) includes a provision for management processes, reporting, quarterly modeling of the plausible stress events based on the Bank’s current balance sheet and internal as well as external communication throughout the stress eventavailable funding alternatives.
(34) Within thirty (30) days following receipt of the Assistant Deputy Comptroller’s written determination of no supervisory objection to the Liquidity Program, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, immediately implement and adhere to the Liquidity Program and any amendments or revisions thereto.
(5) Within thirty (30) days of the beginning of each calendar quarter, Bank management shall prepare, subject to Board review and approval, a report identifying current liquidity requirements and sources for the quarter and projecting liquidity requirements and sources for the upcoming quarter (“Periodic Liquidity Report”) to enable the Board and Asset- Liability Committee to recognize longer-term liquidity needs. Copies of each Periodic Liquidity Report, and any Board comments, shall be forwarded to Assistant Deputy Comptroller within thirty (30) days of the beginning of each calendar quarter.
(6) The Board shall review the effectiveness of the Liquidity Program at least annually, no later than April 15th of each year, and more frequently if necessary or if required by the OCC in writing, and amend the Liquidity Program as needed or directed by the ADC Assistant Deputy Comptroller in writing. The Bank shall submit the revised Liquidity Program to the Assistant Deputy Comptroller for prior written determination of no supervisory objection. At the next Board meeting following receipt of the Assistant Deputy Comptroller’s written determination of no supervisory objection, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and adhere to the revised Liquidity Program and any amendments or revisions thereto.
Appears in 1 contract
Samples: Compliance Agreement
LIQUIDITY RISK MANAGEMENT. (1) Within thirty (30) days of the date of this AgreementBy March 31, 2020, the Board shall adopt develop and submit to the Assistant Deputy Comptroller for review and prior written determination of no supervisory objection, a revised written Liquidity Risk Management Program (“Liquidity Program”) for the Bank. The Liquidity Program shall provide for the identification, measurement, monitoring, and control of program to improve the Bank’s liquidity risk exposure, management. The program must include effective methods to achieve and shall emphasize the importance of cash flow projections, diversified funding sources, a cushion of highly liquid assets, robust maintain sufficient liquidity stress testing scenario analyses, and a formal, well-developed contingency funding plan as primary tools for measuring to measure and managing monitor liquidity risk. Refer to “Liquidity” booklet of the “Comptroller’s Handbook and Interagency Policy Statement on Funding and Liquidity Risk Management,” dated March 22, 2010, (OCC Bulletin 2010-13); the “Addendum to the Interagency Policy Statement on Funding and Liquidity Risk Management: Importance of Contingency Funding Plans,” dated July 28, 2023; and the “Liquidity,” booklet of the Comptroller’s Handbook, ) for guidance.
(2) In addition to the general requirements set forth above, the Bank’s Liquidity Program shall. The program shall include, at a minimum, provisions for the following:
(a) provide specific assigned accountability for developmentstrategies to maintain sufficient liquidity at a reasonable cost including, executionbut not limited, to the following:
(i) improving diversification of funding sources and reducing reliance on high cost providers;
(ii) identifying and reducing rollover risk;
(iii) increasing liquidity through such action as obtaining additional capital, placing limits on asset growth, aggressive collection of problem loans and recovery of charged-off assets, and oversight of liquidity risk managementasset sales; and
(iv) monitoring the projected impact on reputation, including oversight by both economic and credit conditions in the Board, or committee thereof, and Bank managementBank’s market(s);
(b) include appropriate policies and procedures for identifying, measuring, monitoringBoard-established liquidity limits, and controlling requirements for the regular monitoring of compliance with Board-approved limits;
(c) the preparation of liquidity risk exposuresreports which shall be reviewed by the Board on at least a monthly basis;:
(d) a contingency funding plan that, on a monthly basis, forecasts funding needs, and funding sources under different stress scenarios which represents management’s best estimate of balance sheet changes that include may result from a liquidity or credit event. The contingency funding plan shall include, at a minimum:
(i) assignment a statement on the Board’s strategy for maintaining adequate sources of accountability stable funding given the Bank’s anticipated liquidity and processes for monitoring and managing intraday liquidityfunding needs;
(ii) procedures and reporting to assess a definition of a liquidity crisis for the risks related to deposit runoff, rollovers, wholesale, and alternative funding sources; andBank;
(iii) reasonable limits to manage and control identification of early warning liquidity risk that are commensurate with the Bank’s complexity, business activities, and the Board’s risk appetite, that include at a minimum:
(1) minimum levels of highly liquid assetstriggers;
(2iv) limits or triggers on an explicit quantification of those sources and uses of liquidity in stressed scenarios that correspond to the structure of short-term and long- term funding of the Bank’s asset baseearly warning liquidity triggers;
(3v) limitations on funding concentrations and other strategies to ensure diversification of funding sources; and
(4) limitations on contingent liabilities in aggregate and by individual category.
(c) include a no less than monthly generated sources and uses report detailed action plans to identify appropriate funding and obtain sources of liquidity to meet projected funding needs over a short- and intermediate-term horizon shortfalls;
(i.e.vi) identification of responsible bank personnel to declare, 30-, 60-, 90-manage, and 180-days); and
(d) include resolve a no less than quarterly contingency funding plan that projects the Bank’s funding needs, including the development of cash flow projections under expected, adverse, moderately adverse, and severely adverse conditions, that at a minimum:
(i) includes the identification of plausible stress events relating to internal and external events or circumstances, including systemic or market events, that could lead to a Bank liquidity crisis;
(iivii) determines how each identified stress event will affect a process for regular testing to ensure that the Bank’s ability to obtain plan is operationally sound, including periodic testing of unused funding needs under different levels of severitysources;
(iiiviii) has quantitative projections specific plans detailing how the Bank will comply with restrictions or requirements set forth in this Agreement and the restrictions regarding brokered deposits in 12 C.F.R. § 337.6;
(ix) expanded stress scenarios for worse case scenarios reflecting asset quality and financial condition deterioration including a less than “well capitalized” designation;
(x) the preparation of expected reports which identify and quantify all sources of funding needs and funding capacity based on realistic assessments of the behaviors of obligations under best case and worse case scenarios, including asset funding, liability funding providers during stress eventsand off- balance sheet funding; and
(ivxi) includes a provision for management processes, reporting, procedures which ensure that the Bank’s contingency funding practices are consistent with the Board’s guidance and internal as well as external communication throughout the stress eventrisk tolerances.
(32) The Within thirty (30) days of receipt of the Assistant Deputy Comptroller’s written determination of no supervisory objection, the Board shall adopt and Bank management, subject to Board review and ongoing monitoring, shall immediately implement and ensure adherence to the effectiveness of the Liquidity Program at least annually, no later than April 15th of each year, written liquidity risk management program and more frequently if necessary any amendments or if required by the OCC in writing, and amend the Liquidity Program as needed or directed by the ADC in writingrevisions thereto.
Appears in 1 contract
Samples: Compliance Agreement
LIQUIDITY RISK MANAGEMENT. (1) Within thirty sixty (3060) days of the date of this Agreementdays, the Board shall adopt develop, adopt, and thereafter ensure compliance with a revised written Liquidity Risk Management Program comprehensive liquidity risk management policy (“Liquidity ProgramPolicy”) for that incorporates prudent risk management standards as set forth in the Bank“Liquidity” booklet of the Comptroller’s Handbook (June 2012) and OCC Bulletin 2010-13, Interagency Policy Statement on Funding and Liquidity Risk Management, dated March 22, 2010. The Liquidity Program shall provide for the identification, measurement, monitoring, and control of the Bank’s liquidity risk exposure, and Policy shall emphasize the importance of cash flow projections, diversified funding sources, stress testing, a cushion of highly liquid assets, robust liquidity stress testing scenario analyses, and a formal, well-developed contingency funding plan as primary tools for measuring and managing liquidity risk. Refer to the “Interagency Policy Statement on Funding and Liquidity Risk Management,” dated March 22, 2010, (OCC Bulletin 2010-13); the “Addendum to the Interagency Policy Statement on Funding and Liquidity Risk Management: Importance of Contingency Funding Plans,” dated July 28, 2023; and the “Liquidity,” booklet of the Comptroller’s Handbook, for guidance.
(2) In addition to the general requirements set forth above, the Liquidity Policy shall address the weaknesses in the Bank’s Liquidity Program shallliquidity risk management identified in the most recent XXX and, at a minimum, shall:
(a) provide specific assigned accountability for development, execution, and oversight of set liquidity risk managementpolicy limits for, including oversight by both the Board, or committee thereof, and Bank management;
(b) include appropriate policies and procedures for identifying, measuring, monitoring, and controlling liquidity risk exposures, that include at a minimum:
(i) assignment of accountability and processes for monitoring and managing intraday on-hand asset based liquidity;
(ii) procedures and reporting to assess the risks related to deposit runoff, rollovers, wholesale, and alternative funding sourcesloans-to-deposits;
(iii) level of unfunded HELOC commitments; and
(iiiiv) reasonable limits to manage and control liquidity risk that are commensurate with dependency on wholesale funds;
(b) require quarterly Board reports on the Bank’s complexity, business activities, and liquidity position against the Board’s risk appetite, that include at a minimum:
policy limits set pursuant to paragraph (11)(a) minimum levels of highly liquid assetsthis Article;
(2) limits or triggers on the structure of short-term and long- term funding of the Bank’s asset base;
(3) limitations on funding concentrations and other strategies to ensure diversification of funding sources; and
(4) limitations on contingent liabilities in aggregate and by individual category.
(c) include a no less than monthly generated sources and uses report to identify appropriate funding sources to meet projected funding needs over a short- and intermediate-term horizon (i.e., 30-, 60-, 90-, and 180-days); and
(d) include a no less than quarterly contingency funding plan that projects the Bank’s funding needsincorporates, including the development of cash flow projections under expected, adverse, moderately adverse, and severely adverse conditions, that at a minimum:
(i) includes the identification of plausible stress events relating to internal and external events or circumstances, including systemic or market events, that could lead to a Bank liquidity crisis;
(ii) determines how each identified stress event will affect the Bank’s ability to obtain funding needs under different levels of severity;
(iii) has quantitative projections and evaluations of expected funding needs and funding capacity based on realistic assessments of the behaviors of funding providers during moderate and severe stress events, and that incorporates, at a minimum:
(i) the potential funding needs related to unfunded commitments in the HELOC portfolio;
(ii) the impact of regulatory CAMELS ratings downgrades and the loss of Prompt Corrective Action (PCA) Well Capitalized status;
(iii) the potential impact from losing credit sensitive deposits, wholesale funding sources, and other volatile source of funding such as the ability to sell HELOC loan pools; and
(iv) includes assumptions of a provision for management processes, reporting, and internal as well as external communication throughout the stress eventroll-off rate of core deposits in a severe scenario.
(3) The Board shall review the effectiveness of the Liquidity Program at least annually, no later than April 15th of each year, and more frequently if necessary or if required by the OCC in writing, and amend the Liquidity Program as needed or directed by the ADC in writing.
Appears in 1 contract
Samples: Banking Compliance Agreement
LIQUIDITY RISK MANAGEMENT. (1) Within thirty sixty (3060) days of the date of this Agreement, the Board shall adopt a revised an acceptable revised, written Liquidity Risk Management Program (“Liquidity Program”) for the Bank. The Liquidity Program shall provide for the identification, measurement, monitoring, and control of the Bank’s liquidity risk exposure, and shall emphasize the importance of cash flow projections, diversified funding sources, a cushion of highly liquid assets, robust liquidity stress testing scenario analyses, and a formal, well-developed contingency funding plan as primary tools for measuring and managing liquidity risk. Refer to the “Interagency Policy Statement on Funding and Liquidity Risk Management,” dated March 22, 2010, (OCC Bulletin 2010-13); the “Addendum to the Interagency Policy Statement on Funding and Liquidity Risk Management: Importance of Contingency Funding Plans,” dated July 28, 2023; , and the “Liquidity,” booklet of the Comptroller’s Handbook, for guidance.
(2) In addition to the general requirements set forth above, the Bank’s Liquidity Program shall, at a minimum:
(a) provide specific assigned accountability for development, execution, execution and oversight of liquidity risk management, including oversight by both the Board, or committee thereof, Board and Bank senior management;
(b) include appropriate policies and procedures for identifying, measuring, monitoring, and controlling liquidity risk exposures, that include includes at a minimum:
(i) assignment of accountability and processes for monitoring and managing intraday liquidity;
(ii) procedures to ensure that sufficient funds or access to funds exist to meet such cash flow needs under both expected and adverse conditions, including an adequate cushion to meet any unanticipated cash flow needs;
(iii) procedures and reporting to assess the risks related to deposit runoff, rollovers, wholesale, and alternative funding sources; and
(iiiiv) reasonable development of liquidity risk tolerances and limits that are appropriate for the Bank’s size, complexity, and risk profile;
(c) identify appropriate funding strategies and provide limits to manage and control liquidity risk that are commensurate with the Bank’s complexity, complexity and business activities, activities that considers internal and external factors that could affect the BoardBank’s risk appetiteliquidity, that include at a minimum:
(1i) limits or triggers placed on projected net cash flow positions over specified timeframes under both expected and adverse business conditions that are based on realistic assumptions supported by sound historical economic data;
(ii) limits or triggers on funding mismatches and guidelines for minimum and maximum average maturity of the Bank’s assets and liabilities (by category);
(iii) minimum levels of highly liquid assets;
(2iv) minimum levels of committed and collateralized contingent funding sources to meet funding needs in both expected and adverse conditions, which are periodically tested to verify availability and operational capabilities;
(v) limits or triggers on the structure of short-term and long- long-term funding of the Bank’s asset base, under both normal and stressed conditions;
(3vi) documented strategies to increase the Bank’s level of non-maturity deposits, as well as reduce the Bank’s cost of funds;
(vii) limitations on funding concentrations and other strategies to ensure diversification of funding sources; and
(4viii) limitations on contingent liabilities in aggregate and by individual category.
(c) include a no less than monthly generated sources and uses report to identify appropriate funding sources to meet projected funding needs over a short- and intermediate-term horizon (i.e., 30-, 60-, 90-, and 180-days); and;
(d) include a no less than quarterly contingency funding plan that projects provide adequate risk measurement and monitoring systems, including processes and reporting to assess, on an ongoing basis, the Bank’s current and projected funding needs, including the development of cash flow projections under expected, adverse, moderately adverse, both expected and severely adverse conditions, and considering the changes in depositor behavior, interest rates and capital levels;
(e) detailed identification of sources of liquidity to meet projected shortfalls from existing sources under both expected and adverse conditions; and
(f) include a revised Contingency Funding Plan that incorporates, at a minimum:
(i) includes a definition of a liquidity crisis for the Bank;
(ii) the identification of plausible stress events relating to internal and external events or circumstances, including systemic or market events, that could lead to a Bank liquidity crisis, including but not limited to, continued financial deterioration, loss of primary credit status at the Federal Reserve, and the expiration or loss of any primary or contingent sources of liquidity;
(iiiii) determines determinations of how each identified stress event will affect the Bank’s earnings, capital, and ability to obtain funding needs under different levels of severity;
(iiiiv) has quantitative projections projection and evaluation of expected funding needs under each identified stress event;
(v) the identification of the actions management would take under each stress event to include all potentially viable sources for addressing each identified stress event with a priority listing of preferred funding sources as well as alternative funding sources of incremental liquidity;
(vi) processes that ensure the Bank maintains access and the operational capability to monetize all funding capacity sources that are relied upon for each stress event;
(vii) the identification of timely early warning triggers to alert management to potential liquidity problems;
(viii) development of a detailed plan for addressing each identified early warning trigger and stress event;
(ix) assigned management responsible for implementation of all funding plan phrases as well as the appointment of a qualified liquidity crisis management team and administrative structure;
(x) quarterly modeling of the plausible stress events based on realistic assessments of the behaviors of Bank’s current balance sheet and available funding providers during stress eventsalternatives; and
(ivxi) includes a provision for management processes, reporting, and internal as well as external communication throughout the stress event.
(3) Upon adoption of the Liquidity Program, Bank management, subject to Board review and ongoing monitoring, shall immediately implement and thereafter ensure adherence to the Liquidity Program and any amendments thereto.
(4) Within forty-five (45) days of the beginning of each calendar quarter, Bank management shall prepare, subject to Board review and approval, a report identifying current liquidity requirements and sources for the quarter and projecting liquidity requirements and sources for the upcoming quarter (“Periodic Liquidity Report”) to enable the Board to recognize longer-term liquidity needs. Copies of each Periodic Liquidity Report, and any Board comments, shall be forwarded to Assistant Deputy Comptroller within thirty (30) days of the beginning of each calendar quarter.
(5) The Board shall review the effectiveness of the Liquidity Program at least annually, no later than April 15th of each year, and more frequently if necessary or if required by the OCC in writing, and amend the Liquidity Program as needed or directed by the ADC Assistant Deputy Comptroller in writing. The Board shall forward a copy of the adopted Liquidity Program, and any subsequent amendments thereto, to the Assistant Deputy Comptroller within thirty (30) days of adoption.
Appears in 1 contract
Samples: Compliance Agreement