298x Filetype PPT File size 0.30 MB Source: www.cdfifund.gov
Discussion Points
• Outline the responsibilities of an asset
liability committee (ALCO).
• Discuss commonly observed ALCO best
practices in community banks.
• Review areas of the ALCO policy and/or
ALCO activities that could be enhanced.
• Discuss liquidity risk management.
• Review new IRR guidance.
• Discuss regulatory ALM modeling tips.
• Introduce upcoming guidance on credit risk
analysis of investment securities.
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Asset-Liability Committee (ALCO)
Responsibilities
ALCO Composition
• Senior management committee in a financial institution responsible for
coordinating the institution's borrowing and lending strategy, and funds
acquisition to meet profitability objectives as interest rates change.
ALCO Responsibilities – Liquidity Risk Exposure
• The ALCO should actively monitor the institution’s liquidity profile and should
have sufficiently broad representation across major institutional functions
that can directly influence the institution’s liquidity risk profile (e.g., lending,
investment securities, wholesale and retail funding).
• For example, the ALCO will have responsibility for setting limits on the
arbitrage of short-term borrowing, while lending long-term
instruments. Among the factors considered are liquidity risk, interest rate
risk, operational risk and external events that may affect the bank's forecast
and strategic balance-sheet allocations.
ALCO Responsibilities – Interest Rate Risk Exposure
• The ALCO should ensure that the risk measurement system adequately
identifies and quantifies risk exposure.
Reporting
• The ALCO will generally report to the board of directors and will also have
regulatory reporting responsibilities. Reporting process should communicate
accurate, timely, and relevant information about the level and sources of risk
exposure.
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Asset-Liability Management
• Typically, asset-liability management
(ALM) is associated with reporting a
financial institution’s historical Gap, EVE,
and net interest income sensitivity results.
• Ideally, ALM should involve an integrated
process between interest rate risk,
liquidity risk management, budgeting, and
strategic planning that includes the entire
bank; and develops future dynamic
strategies that balance risk and
profitability.
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ALCO Best Practices
Observed in Community Banks
• Although there is no official written guidance that outlines regulatory
expectations of the ALCO, the following are ALCO best practices
observed by examiners of community banks:
o Liquidity that is readily available, including the availability of
collateral to be pledged.
o Credit lines accessible with material adverse change clauses readily
accessible to determine circumstances that would disallow use of the
lines.
o Limitations on particular types of deposits that can be accumulated,
for example, municipal deposits.
o ALCO package that includes a 1-page summary covering all key
model assumptions including any recent changes to the
assumptions.
o Funding diversification guidelines.
o Establishing targets and composition mix of the investment portfolio.
o IRR and liquidity limits that require action vs. additional discussion
(e.g., Red, Yellow, Green).
o ALCO packages that show level and trends vs. just showing the level
specifically for risk limits.
o Cash flow coverage for runoff of collateralized deposits.
o Testing credit lines at least annually.
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ALCO Best Practices
Observed in Community Banks
(con’d)
• Although there is no official written guidance that
outlines regulatory expectations of the ALCO policy,
the following are ALCO policy best practices observed
by examiners of community banks:
o Has substance, structure and focus.
o Ties-in other policy parameters, e.g., Investment
Policy guidelines and the impact on liquidity.
o Includes description of how key assumptions are
determined, and the source documents used to make
the assumptions.
o Includes minimum risk limits for maintaining liquid,
unencumbered assets.
o Includes a definition of liquidity assets.
o Outlines expectations for independent review.
o Includes funding risk limits by maturity, e.g., limits
on short-term, wholesale funding).
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