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Commercial Bank Risk Management: an Analysis of the Process
by Anthony M. Santomero 95-11-C
THE WHARTON FINANCIAL INSTITUTIONS CENTER
The Wharton Financial Institutions Center provides a multi-disciplinary research approach to the problems and opportunities facing the financial services industry in its search for competitive excellence. The Center's research focuses on the issues related to managing risk at the firm level as well as ways to improve productivity and performance. The Center fosters the development of a community of faculty, visiting scholars and Ph.D. candidates whose research interests complement and support the mission of the Center. The Center works closely with industry executives and practitioners to ensure that its research is informed by the operating realities and competitive demands facing industry participants as they pursue competitive excellence. Copies of the working papers summarized here are available from the Center. If you would like to learn more about the Center or become a member of our research community, please let us know of your interest.
Anthony M. Santomero Director
The Working Paper Series is made possible by a generous grant from the Alfred P. Sloan Foundation
Commercial Bank Risk Management: An Analysis of the Process 1 This Version: February 28, 1997
Abstract: Throughout the past year, on-site visits to financial service firms were conducted to review and evaluate their financial risk management systems. The commercial banking analysis covered a number of North American super-regionals and quasi-money center institutions as well as several firms outside the U.S. The information obtained covered both the philosophy and practice of financial risk management. This paper outlines the results of this investigation. It reports the state of risk management techniques in the industry. It reports the standard of practice and evaluates how and why it is conducted in the particular way chosen. In addition, critiques are offered where appropriate. We discuss the problems which the industry finds most difficult to address, shortcomings of the current methodology used to analyze risk, and the elements that are missing in the current procedures of risk management. JEL Classification codes : G2, G1, L2 Key words : risk management, financial risk, banking
Anthony M. Santomero is the Richard K. Mellon Professor of Finance at the Wharton School.
This paper was presented at the Wharton Financial Institutions Center Conference on Risk Management in Banking, October 13-15, 1996. The author acknowledges helpful comments and suggestions received at workshops at INSEAD, Universita Bocconi, University of Karlsruhe, Stockholm School of Economics, and the Federal Reserve. Specific thanks to R. Eisenbeis, D. Babbel, G. Oldfield and R. Herring.
I. Introduction The past decade has seen dramatic losses in the banking industry. Firms that had been performing well suddenly announced large losses due to credit exposures that turned sour, interest rate positions taken, or derivative exposures that may or may not have been assumed to hedge balance sheet risk. In response to this, commercial banks have almost universally embarked upon an upgrading of their risk management and control systems. Coincidental to this activity, and in part because of our recognition of the industry's vulnerability to financial risk, the Wharton Financial Institutions Center, with the support of the Sloan Foundation, has been involved in an analysis of financial risk management processes in the financial sector. Through the past academic year, on-site visits were conducted to review and evaluate the risk management systems and the process of risk evaluation that is in place. In the banking sector, system evaluation was conducted covering many of North America's super-regionals and quasi-money center commercial banks, as well as a number of major investment banking firms. These results were then presented to a much wider array of banking firms for reaction and verification. The purpose of the present paper is to outline the findings of this investigation. It reports the state of risk management techniques in the industry -- questions asked, questions answered and questions left unaddressed by respondents.1 This report can not recite a litany of the approaches used within the industry, nor can it offer an evaluation of each and every approach. Rather, it reports the standard of practice and evaluates how and why it is conducted in the particular way chosen. But, even the best practice employed within the industry is not good enough in some areas. Accordingly, critiques also will be offered where appropriate. The paper concludes with a list of questions that are currently unanswered, or answered imprecisely in the current practice employed by this group of relatively sophisticated banks. Here, we discuss the problems which the industry finds most difficult to address, shortcomings of the current methodology used
A companion paper reports on risk management practices for insurance firms. See Babbel and Santomero (1997).
or more recently Allen and Santomero (1997). they use their own balance sheet to facilitate the transaction and to absorb the risks associated with it. Suffice it to say that market participants seek the services of these financial institutions because of their ability to provide market knowledge. Over the last decade our understanding of the place of commercial banks within the financial sector has improved substantially. II. To be sure. much has been written on the role of commercial banks in the financial sector. Salomon Brothers and Goldman Sachs Equity Research Reports on the banking sector. transaction efficiency and funding capability. As such. the overwhelming majority of the risks facing the banking firm is in on-balance-sheet businesses. Over this time. Nonetheless. distributing and servicing of loans in the areas of consumer and real estate debt primarily. Risk As a Central Ingredient To the Industry's Franchise What Type of Risk Is Being Considered ? Commercial banks are in the risk business. for example. or (iv) the packaging. (iii) standard underwriting through Section 20 Subsidiaries of the holding company. Santomero (1984). they assume various kinds of financial risks. (ii) private and public placements through "best efforts" or facilitating contracts. A. securitizing. Bhattacharya and Thakor (1993). Economist (1993). There are many surveys and articles here. In the process of providing financial services. In performing these roles they generally act as a principal in the transaction.to analyze risk and the elements that are missing in the current procedures of risk management and risk control. It is in this area that the discussion of risk There are amply reviews of the role of banks within the financial sector. See. See. These items are absent from the traditional financial statement because the latter rely on generally accepted accounting procedures rather than a true economic balance sheet. there are activities performed by banking firms which do not have direct balance sheet implications. for example. These services include agency and advisory activities such as (i) trust and investment management. These arguments will be neither reviewed nor enumerated here. both in the academic literature2 and in the financial press3. 3 2 2 ..
e. those involving its own balance sheet and its basic business of lending and borrowing. In the first of these cases. it has been argued that risks facing all financial institutions can be segmented into three separable types. Oldfield and Santomero (1997). it is here that our review of risk management procedures will concentrate. Rather. the practice of risk avoidance involves actions to reduce the chances of idiosyncratic losses from standard banking activity by eliminating risks that are superfluous to the institution's business purpose. it will shift the risk to other parties through a combination of pricing and product design. i. it should accept only those risks that are uniquely a part of the bank's array of services. risks that can be transferred to other participants.. risks that must be actively managed at the firm level. In many instances the institution will eliminate or mitigate the financial risk associated with a transaction by proper business practices. B. and. in others.management and the necessary procedures for risk management and control has centered. the implementation of incentive-compatible contracts with the institution's management to require that employees be held accountable is the third. In short. from a management perspective. nor should it absorb risk that can be efficiently transferred to other participants. Elsewhere. contracts and procedures to prevent inefficient or incorrect financial decisions is the first of these. Common risk avoidance practices here include at least three types of actions. it should only manage risks at the firm level that are more efficiently managed there than by the market itself or by their owners in their own portfolios. Accordingly. What Kinds Of Risks Are Being Absorbed ? The risks contained in the bank's principal activities. The construction of portfolios that benefit from diversification across borrowers and that reduce the effects of any one loss experience is another. Finally. The standardization of process. are not all borne by the bank itself. In each 3 . These are: (i) (ii) (iii) risks that can be eliminated or avoided by simple business practices. The banking industry recognizes that an institution need not engage in business in a manner that unnecessarily imposes risk upon it.
The first of these includes financial assets or activities where the nature of the embedded risk may be complex and difficult to communicate to third parties. Credit risk inherent in the lending activity is a clear case in point. Interest rate risk can be transferred by interest rate products such as swaps or other derivatives. and their expected return. good reasons exist for using firm resources to manage bank level risk. the bank can buy or sell financial claims to diversify or concentrate the risks that result in from servicing its client base. Markets exist for many of the risks borne by the banking firm. or at least substantially reduced through the technique of risk transfer. In all such circumstances. or to absorb only an optimal quantity of a particular kind of risk. if not non-existent. This is the case when the bank holds complex and proprietary assets that have thin. However. The second case included proprietary positions that are accepted because of their risks.case the goal is to rid the firm of risks that are not essential to the financial service provided. there is no reason for the bank to absorb such risks.4 Moreover. secondary markets. Finally. There are also some risks that can be eliminated. risk is absorbed and needs to be monitored and managed efficiently by the institution. Communication in such cases may be more difficult or expensive than hedging the underlying risk. This point has been made in a different context by both Santomero and Trester (1997) and Berger and Udell (1993). In these cases. To the extent that the financial risks of the assets created by the firm are understood by the market. revealing information about the customer may give competitors an undue advantage. there are two classes of assets or activities where the risk inherent in the activity must and should be absorbed at the bank level. Here. rather than transfer them. as is market risk for the trading desk of banks active in certain markets. risk positions that are central to the bank's business purpose are absorbed because they are the raison d'etre of the firm. these assets can be sold at their fair value. Unless the institution has a comparative advantage in managing the attendant risk and/or a desire for the embedded risk they contain. Borrowing terms can be altered to effect a change in their duration. Only then will the firm systematically achieve its financial performance goal. 4 4 .
managers of value maximizing firms ought to maximize expected profit without regard to the variability around its expected value. According to standard economic theory. the costs of financial distress and the existence of capital market imperfections. Smith. there is now a growing literature on the reasons for active risk management including the work of Stulz (1984).C. The management of the banking firm relies on a sequence of steps to implement a risk management system. what techniques are employed to both limit and manage the different types of risk. However. These include managerial selfinterest. In fact. and how are they implemented in each area of risk control? It is to these questions that we now turn. How Are These Risks Managed ? In light of the above. Smithson and Wolford (1990). as the above-cited authors demonstrate. D. Any one of these justify the firms' concern over return variability. These can be seen as containing the following four parts: 5 . the recent review of risk management reported in Santomero (1995) lists dozens of contributions to the area and at least four distinct rationales offered for active risk management. After reviewing the procedures employed by leading firms. Why Do Banks Manage These Risks At All ? It seems appropriate for any discussion of risk management procedures to begin with why these firms manage risk. the non-linearity of the tax structure. what are the necessary procedures that must be in place to carry out adequate risk management? In essence. an approach emerges from an examination of large-scale risk management systems. and Froot. Sharfstein and Stein (1993) to name but a few of the more notable contributions.
Obviously outside audits. and rating agency evaluations are essential for investors to gauge asset quality and firm level risk. even for those investments that are eligible. They are listed together because they are the sine qua non of any risk system. investment guidelines or strategies. and the extent to which these risks must be mitigated or absorbed. position limits or rules. these tools are established to measure exposure.e. and standards of review are all traditional tools of risk management and control. The standardization of financial reporting is the next ingredient. However. credits. and encourage decision makers to manage risk in a manner that is consistent with the firm's goals and objectives. the need here goes beyond public reports and audited statements to the need for management information on asset quality and risk posture. To see how each of these four parts of basic risk management techniques achieves these ends. (ii) Position Limits and Rules A second technique for internal control of active management is the use of position limits. and overall 6 . In Section IV we illustrate how these techniques are applied to manage each of the specific risks facing the banking community. In terms of the latter. standard setting and financial reporting. These reports have long been standardized. Underwriting standards. and/or minimum standards for participation. regulatory reports. incentive contracts and compensation.. In general. Consistent evaluation and rating of exposures of various types are essential to understand the risks in the portfolio. (i) Standards and Reports The first of these risk management techniques involves two different conceptual activities. i. we elaborate on each part of the process below. with daily or weekly reports substituting for the quarterly GAAP periodicity. define procedures to manage these exposures. Then. limit individual positions to acceptable levels.(i) (ii) (iii) (iv) standards and reports. Such internal reports need similar standardization and much more frequent reporting intervals. the domain of risk taking is restricted to only those assets or counterparties that pass some prespecified quality standard. limits are imposed to cover exposures to counterparties. risk categorizations. for better or worse.
but even more essential. and setting 5 The recent fiasco at Barings is an illustration of this point .5 Such tools which include position posting. strategies are outlined in terms of concentrations and commitments to particular areas of the market. Summary reports show limits as well as current exposure by business unit on a periodic basis. the allocation of costs. In large organizations with thousands of positions maintained. and portfolio managers. each person who can commit capital will have a well-defined limit. Here. and therefore by the organization as a whole. In addition. such incentive contracts require accurate position valuation and proper internal control systems. accurate and timely reporting is difficult. This applies to traders. (iv) Incentive Schemes To the extent that management can enter incentive compatible contracts with line managers and make compensation related to the risks borne by these individuals. the extent of desired asset-liability mismatching or exposure. Beyond this.position concentrations relative to various types of risks. In general. lenders. their imposition restricts the risk that can be assumed by any one individual. and the need to hedge against systematic risk of a particular type. because managers generally operate within position limits and prescribed rules. given the state of the market and the willingness of senior management to absorb the risks implied by the aggregate portfolio. risk analysis. While such limits are costly to establish and administer. However. securitization and even derivative activity are rapidly growing techniques of position management open to participants looking to reduce their exposure to be in line with management's guidelines. Such guidelines lead to firm level hedging and asset-liability matching. 7 . guidelines offer firm level advice as to the appropriate level of active management. then the need for elaborate and costly controls is lessened. (iii) Investment Guidelines and Strategies Investment guidelines and recommended positions for the immediate future are the third technique commonly in use. The limits described above lead to passive risk avoidance and/or diversification.
and in Section IV we will indicate how they are managed. as the cases of the deposit insurance and maverick traders so clearly illustrate. In fact.of required returns to various parts of the organization are not trivial. and Santomero (1984) for discussions of the shortcomings in simple linear risk sharing incentive contracts for assuring incentive compatibility between principals and agents. Accordingly. liquidity risk. They measure See Jensen and Meckling (1976). Notwithstanding the difficulty. Systematic risk is the risk of asset value change associated with systematic factors. most try to estimate the impact of these particular systematic risks on performance. attempt to hedge against them and thus limit the sensitivity to variations in undiversifiable factors. most financial debacles can be traced to the absence of incentive compatibility. two are of greatest concern. and legal risks. which is in fact a somewhat imprecise term. however the risks can be broken into six generic types: systematic or market risk. The risks associated with the provision of banking services differ by the type of service rendered. namely variations in the general level of interest rates and the relative value of currencies. this risk can be hedged. III. most will track interest rate risk closely. By its nature. Because of the bank's dependence on these systematic factors. It is sometimes referred to as market risk. All investors assume this type of risk. we will discuss each of the risks facing the banking institution. systematic risk can be thought of as undiversifiable risk. Risks In Providing Banking Services How are these techniques of risk management employed by the commercial banking sector? To explain this. As such. systematic risk comes in many different forms. Here. counterparty risk. credit risk. For the banking sector.6 In fact. whenever assets owned or claims issued can change in value as a result of broad economic factors. For the sector as a whole. however. but cannot be diversified completely away. 6 8 . operational risk. welldesigned systems align the goals of managers with other stakeholders in a most desirable way. one must begin by enumerating the risks which the banking industry has chosen to manage and illustrate how the four-step procedure outlined is applied in each area.
in fact. through their lending activity or geographical franchise. or from some other political or legal constraint that was not anticipated by the principals.and manage the firm's vulnerability to interest rate variation. their exposure to it. In addition. but difficult to eliminate completely. It may arise from either an inability or an unwillingness to perform in the pre-committed contracted manner. This can affect the lender holding the loan contract. The real risk from credit is the deviation of portfolio performance from its expected value. Credit risk arises from non-performance by a borrower. the idiosyncratic nature of some portion of these losses remains a problem for creditors in spite of the beneficial effect of diversification on total uncertainty. Counterparty risk comes from non-performance of a trading partner. This is particularly true for banks that lend in local markets and ones that take on highly illiquid assets. result from the systematic risk outlined above. international banks with large currency positions closely monitor their foreign exchange risk and try to manage. In addition. Therefore. some institutions with significant investments in one commodity such as oil. but it is generally viewed as a more transient financial risk associated with trading than standard creditor default risk. In such cases. Others with high single-industry concentrations may monitor specific industry concentration risk as well as the forces that affect the fortunes of the industry involved. the credit risk is not easily transferred. This is because a portion of the default risk may. concern themselves with commodity price risk. as well as limit. a counterparty's failure to settle a trade 9 . even though they can not do so perfectly. The non-performance may arise from a counterparty's refusal to perform due to an adverse price movement caused by systematic factors. Diversification is the major tool for controlling nonsystematic counterparty risk. Counterparty risk is like credit risk. Accordingly. as well as other lenders to the creditor. and accurate estimates of loss are difficult to obtain. At the same time. credit risk is diversifiable. In a similar fashion. the financial condition of the borrower as well as the current value of any underlying collateral is of considerable interest to its bank.
Fraud. tax legislation. court opinions and regulations can put formerly well-established transactions into contention even when all parties have previously performed adequately and are fully able to perform in the future. Non-principal. All financial institutions face all these risks to some extent. legal recourse against an agent is often attempted. Operational risk is associated with the problems of accurately processing. If the latter experiences a financial loss. counterparty. In any case. systematic. processing system failures and compliance with various regulations. such as a large charge off. credit and counterparty risk accrues directly to the asset holder. risk management here centers on liquidity facilities and portfolio structure. Therefore. and operational risks. A second type of legal risk arises from the activities of an institution's management or employees. institutions engaged in 10 . Recognizing liquidity risk leads the bank to recognize liquidity itself as an asset. New statutes. however. It also arises in record keeping. environmental regulations have radically affected real estate values for older properties and imposed serious risks to lending institutions in this area. the risk here is seen more correctly as the potential for a funding crisis. violations of regulations or laws. As such. as recent examples in the thrift industry have demonstrated. settling. and taking or making delivery on trades in exchange for cash. For example. Such a situation would inevitably be associated with an unexpected event. individual operating problems are small probability events for well-run organizations but they expose a firm to outcomes that may be quite costly. loss of confidence. While some would include the need to plan for growth and unexpected expansion of credit. or a crisis of national proportion such as a currency crisis. and portfolio design in the face of illiquidity concerns as a challenge.can arise from other factors beyond a credit problem. and other actions can lead to catastrophic loss. Since institutions in this case do not own the underlying assets in which they trade. Liquidity risk can best be described as the risk of a funding crisis. Legal risks are endemic in financial contracting and are separate from the legal ramifications of credit. or agency activity involves operational risk primarily.
Bank Risk Management Systems The banking industry has long viewed the problem of risk management as the need to control four of the above risks which make up most. however. Likewise. Our main interest. all would recognize the first four as key. interest rate.only agency transactions bear some legal risk. viz. as an intermediary. they view them as less central to their concerns. if only indirectly. it is evaluated using standard credit risk procedures. i.. Accordingly. more likely. and all would devote most of their risk management resources to constraining these key areas of exposure. and how much to contract to agents.e. To illustrate how this is achieved. The more difficult issue of summing over these risks and adding still other. this review of firm-level risk management begins with a discussion of risk management controls in each area. While they recognize counterparty and legal risks. ones such as legal. more amorphous. most bankers would view legal risks as arising from their credit decisions or. In each case. Credit Risk Management Procedures In presenting the approach employed to manage credit risk. measure. regulatory or reputational risk. how much to sell. and often within the credit department itself. principals must decide how much business to originate. will be left to the end. credit. In so doing. constrain and manage each of these risks. In these activities.7 Where counterparty risk is significant. the procedure outlined above is adapted to the risk considered so as to standardize. IV. how much to finance. they must weigh both the return and the risk embedded in the portfolio. Principals must measure the expected profit and evaluate the prudence of the various risks enumerated to be sure that the result achieves the stated goal of maximizing shareholder value. of their risk exposure. A. Nonetheless. foreign exchange and liquidity risk.. we refer to the four-step process outlined Some banking firms would also list regulatory and reputational risk in their set of concerns. if not all. 7 11 . the study of bank risk management processes is essentially an investigation of how they manage these four risks. proper process not employed in financial contracting. centers around the businesses in which the bank participates as a principal.
the bank can report the quality of its loan portfolio at any time. the general credit worthiness of the borrower is measured. through training and apprenticeship to achieve a standardization of ratings throughout the bank. others have 12. Such an approach. whether it is a single or a dual rating system allows the credit committee some comfort in its knowledge of loan asset quality at any moment of time. but are selected because of the representative nature of their documentation of the process. which relates to the borrower's underlying credit quality. Some have 8. 8 12 .8 For each numerical category. drawing different pieces from different organizations. along the lines There is nothing unique about 10 grades. At some institutions. the reader will note that in the reported system all loans are rated using a single numerical scale ranging between 1 and 10. This has lead to standardized ratings across borrowers and a credit portfolio report that presents meaningful information on the overall quality of the credit portfolio. while in the former. Some banks prefer such a dual system. a qualitative definition of the borrower and the loan's quality is offered and an analytic representation of the underlying financials of the borrower is presented. a dual system is in place where both the borrower and the credit facility are rated. or a portfolio of loans. To facilitate this. In the latter. It requires only that new loan officers be introduced to the system of loan ratings. attention centers on collateral and covenants. We begin with standards and reports. In any case. Given these standards. a substantial degree of standardization of process and documentation is required. As noted above. each bank must apply a consistent evaluation and rating scheme to all its investment opportunities in order for credit decisions to be made in a consistent manner and for the resultant aggregate reporting of credit risk exposure to be meaningful. The most important thing here is that there are sufficient gradations to permit accurate characterization of the underlying risk profile of a loan. a credit-rating procedure is presented that is typical of those employed within the commercial banking industry.in Section II D above. The institutions are not named. while others argue that it obscures the issue of recovery to separate the facility from the borrower in such a manner. The form reported here is a single rating system where a single value is given to each loan. In Table 1.
credit quality reports should signal changes in expected loan losses. are reported in a single format. in fact. This process. 9 13 . such as a change in the value of collateral. Variations over time indicate changes in loan quality and expected loan losses from the credit portfolio. results in a periodic but timely report card on the quality of the credit portfolio and its change from month to month. The second cause for a change in the credit quality report is more substantive. and reviewed periodically. leases and commitments and derivatives. It is. if the rating system is meaningful. a material change in the conditions associated either with the borrower or the facility itself. or the rating of individual loans has changed over the intervening time interval. Generally accepted accounting principles require this monitoring. Assuming the adherence to standards. including loans. In addition. Notice that total receivables. which have recently been tightened by The Financial Accounting Standards Board (FASB).9 A similar result should be expected from internal bank-rating schemes of this type as well. Studies by Moody's on their rating system have illustrated the relationship between credit rating and ex post default rates. therefore.of the report presented in Table 2. The credit portfolio is subject to fair value accounting standards. In fact. Loans are repaid and new loans are made. Changes in this report from one period to another occur for two reasons. For this type of credit quality report to be meaningful. the entirety of the firm's credit quality is reported to senior management monthly via this reporting mechanism. loans have entered or exited the system.. the lack of available industry data to do an appropriate aggregate migration study does not permit the industry the same degree of confidence in their expected loss calculations. The first reason is associated with standard loan turnover. viz. standard for all credits above some dollar volume to be reviewed on a quarterly or annual basis to ensure the accuracy of the rating associated with the lending facility. Commercial banks are required to have a loan loss reserve account ( a contra-asset) which See Moody's (1996) and Santomero and Babbel (1997) for evidence of the relationship between credit rating and default rates. will trigger a re-evaluation. However. all credits must be monitored.
As an industry. Moody's has developed a system of 34 industry groups that may be used to report concentrations. indicating industry composition of the loan portfolio. and an estimate of loss given default. and internal studies of loan migration through various quality ratings. however. given the evidence of loss exposure driven directly from the credit quality report. For the investment management community. SIC codes were employed at some institutions. including default probability. 11 10 14 . and mutual funds will generally report not only the absolute percentage of their industry See Altman (1993) for a discussion of both the FASB standards and the methods employed to evaluate the level of the reserve account. but the commercial banking sector has not. concentrations are generally benchmarked against some market indexes. For the real estate portfolio. it is a beginning. banks have generally sought estimates of expected loss using a two-step process. This approach parallels the work of Moody's referred to above. many banks are beginning to develop concentration reports. Accordingly. geography is also reported. Accurately estimating loan losses from a loan quality report is. but most found them unsatisfactory. This appears to be changing in light of the recent substantial losses in real estate and similar losses in the not-too-distant past in petrochemicals. as well as commitments to various industries. Recently. the level of the reserve account is re-assessed. in fact. Traditionally mutual funds and merchant banks have concerned themselves with such risk exposure. as Table 4 suggests. quite difficult because of the limited information available to the bank on future loan losses and the change in loan quality over time. While this may be insufficient to capture total geographic concentration.10 At least quarterly. Table 3 reports such an industry grouping to illustrate the kind of concentration reports that are emerging as standard in the banking industry. This process was initially hampered by the lack of a simple industry index. To see how the statistical properties of the time series of loan ratings can be used to obtain loan loss estimates. Notice that the report indicates the portfolio percentages by sector. see Kim and Santomero (1993).accurately represents the diminution in market value from known or estimated credit losses.11 Absent from the discussion thus far is any analysis of systematic risk contained in the portfolio.
we are seeing the emergence of a portfolio manager to watch over the loan portfolio's degree of concentration and exposure to both types of risk concentration discussed above. Here. Unfortunately. Interest Rate Management Procedures The area of interest rate risk is the second area of major concern and on-going risk monitoring and management. The latter. this type of credit risk exposure or concentration report has both an upper and lower cut-off value so that only concentrations above a minimum size are recorded. and no one credit exposure exceeds its predetermined limit. need to be reported as well. the tradition has been for the banking industry to diverge somewhat from other 15 . firms must weigh the pros and cons of specialization and concentration by industry group and establish subjective limits on their overall exposure. such a relationship report is required to capture the disparate activity from many parts of the bank. Both of these requirements are not easily satisfied. In addition. particularly across time zones.concentration. however. Nonetheless. both used and open. Each different lending facility is reported. Most organizations also will report concentration by individual counterparty. B. the existing lines of credit. Transaction with affiliated firms need to be aggregated and maintained in close to real time. To be meaningful. an example of the second technique of risk management is monitored and set by the credit committee for the relationship as a whole. a key relationship manager must be appointed to assure that overall bank exposure to a particular client is captured and monitored. however. there is no comparable benchmark for the loan portfolio. An example of this type of report is offered here as Table 5. but rather a subjective evaluation of management's tolerance. This is generally done with both guidelines and limits set by senior management. Accordingly. Generally. For large institutions. In addition. but also their positions relative to the broad market indexes. this exposure must be bankwide and include all related affiliates. based upon rather imprecise recollections of previous downturns. This level of data accumulation is never easy. drawn from one particular client report. Such a report is not the result of any analytical exercise to evaluate the potential downside loss.
fancy value-at-risk models. simple ad hoc limits and close monitoring substitute for elaborate realtime systems. For large commercial banks and European-type universal banks that have an active trading business. In many firms. but similar systems are in place at other firms. Asset cash flows are reported in various repricing schedules along the line of Table 6. This procedure has recently been publicly displayed with the release of Riskmetrics by J. Jorion (1997). or monthly volatility of the market value of fixed-rate assets are incorporated into a measure of total portfolio risk analysis along with equity's market risk. Morgan. commercial banking firms follow a different drummer -. such systems have become a required part of the infrastructure. as well as the close correspondence of asset and liability structures. the absence of adequate trading systems elsewhere in the industry is a bit distressing. Rather. the work of . now known by the acronym VaR.or is it accountant? Given the generally accepted accounting procedures (GAAP) established for bank assets. For institutions that do have active trading businesses. Most commercial banks make a clear distinction between their trading activity and their balance sheet interest rate exposure. P. 16 . In the interim. there is little value to reviewing this technique here. But. and have developed elaborate trading risk management systems to measure and monitor exposure. Fallon (1996). While this may be completely satisfactory for institutions that have little trading activity and work primarily on behalf of clients. these trading risk management systems vary substantially from bank to bank and generally are less real than imagined. they are still in the implementation phase. and that of foreign-denominated assets. For balance sheet exposure to interest rate risk. and Phelan (1997). In that much exists in the public record about these systems12. But. This 12 See. Marshall and Siegel (1996). Investment banks generally have viewed interest rate risk as a classic part of market risk. their approach relies on cash flow and book values. weekly. for example. commercial banks tend not to use market value reports. at the expense of market values. Suffice it to say that the daily. in fact. in many more cases. value-at-risk has become the standard approach. guidelines or limits. are up and running.parts of the financial sector in their treatment of interest rate risk.
In fact. Accordingly. have attempted to move beyond this gap methodology. as well as estimates of prepayments and cash flows. as well as standard See Saunders (1996) or Hempel. This has classically been measured in ratio or percentage mismatch terms over a standardized interval such as a 30-day or one-year period. Asset categories that do not have fixed maturities. and include both on. are a bit of science and a bit of art.13 Most banks. the industry has added the next level of analysis to their balance sheet interest rate risk management procedures.system has been labelled traditionally a "gap reporting system". such as prime rate loans. Simonson and Coleman (1994) for a discussion of duration gap. However. The result of this exercise is a rather crude approximation of the duration gap. They recognize that the gap and duration reports are static. Nonetheless. three. In terms of the first issue. the industry attempts to measure these estimates accurately. of course.and five-year horizons. its construction and its usefulness. such as retail demand and savings balances. These simulations. many assumptions are necessary to move from cash flows to duration. A similar problem exists for core liabilities. This is sometimes supplemented with a duration analysis of the portfolio.and off-balance sheet exposures in this type of reporting procedure. the simulations require precise prepayment models for proprietary products. in which bank pricing decisions in both their local and national franchises are simulated for each rate environment. In terms of the second area. 13 17 . many banks are using balance sheet simulation models to investigate the effect of interest rate variation on reported earnings over one-. as the asymmetry of the repricing of assets and liabilities results in a gap. They require relatively informed repricing schedules. and do not fit well with the dynamic nature of the banking market. Currently. however. must be assigned a duration measure based upon actual repricing flexibility. where assets and liabilities change over time and spreads fluctuate. as seen in Table 7. such as middle market loans. the variability of spreads is largely responsible for the highly profitable performance of the industry over the last two years. such an analysis requires an assumed response function on the part of the bank to rate movement.
the simulation reports the resultant deviations in earnings associated with the rate scenarios considered. Table 9. Reports of these simulations. Some are willing to accept derivative activity. However. is emerging as a common benchmark for interest rate risk. EaR. Most banking institutions view activity in the foreign exchange market beyond their franchise. the results are viewed as indicative of the effect of underlying interest rate mismatch contained in the balance sheet. This can be explained by the different franchises that coexist in the banking industry. these simulations require yield curve simulation over a presumed relevant range of rate movements and yield curve shifts. such as contained in Table 8. every institution has an investment policy in place which defines the set of allowable assets and limits to the bank's participation in any one area. which are usually couched in terms of deviations of earnings from the expected or most likely outcome. such markets contain their own set of risks. for example. see. however. and/or the bank's response mechanism contained in the simulation is accurate and feasible. as has become increasingly evident. Nonetheless. investment guidelines are becoming increasingly circumspect concerning allowable investment and hedging alternatives. Foreign Exchange Risk Mananagement Procedures In this area there is considerable difference in current practice. C. In addition. are now commonplace in the industry. while others are active participants. Because of concerns over the potential earnings outcomes of the simulations. treasury officials often make use of the cash. All institutions restrict the activity of the treasury to some extent by defining the set of activities it can employ to change the bank's interest rate position in both the cash and forward markets. Accordingly. The former will take virtually no principal 18 . but all restrict their positions in the swap caps and floors market to some degree to prevent unfortunate surprises. As reported losses by some institutions mount in this area. Once completed. it is of limited value as it presumes that the range of rates considered is correct. Whether or not this is acceptable depends upon the limits imposed by management.products such as residential mortgages or traditional consumer debt. This notion of Earnings At Risk. futures and swap markets to reduce the implied earnings risk contained in the bank's embedded rate exposure. However.
Limits are the key elements of the risk management systems in foreign exchange trading as they are for all trading businesses. 19 . In the latter case. no forward open positions. stress tests are done to evaluate the potential loss associated with changes in the exchange rate. or in the aggregating exposure across multiple correlated currencies. there is a clear distinction between those that restrict themselves to acting as agents for corporate and/or retail clients and those that have active trading positions. Either historical events are captured. As Table 10 illustrates by example. At many institutions. or the historical events are used to estimate a distribution from which the disturbances are drawn.risk. with spot and forward positions marked-to-market. with monitoring occurring in real time by some banks. until recently most did not use covariability in setting individual currency limits. Currencies are kept in real time. While some use these methods to estimate volatility. risk limits are set currency-by-currency by subjective variance tolerance. Limits are set by desk and by individual trader. As a general characterization. it is fairly standard for limits to be set by currency for both the spot and forward positions in the set of trading currencies. but it also may be investigated for historical maximum movements. and have no expectations of trading volume. Even for banks without a VaR system in place. reporting is rather straightforward. The most active banks in this area have large trading accounts and multiple trading locations. And. Within the latter group. Others. The latter is investigated in two ways. Here. This is done for small deviations in exchange rates as shown in Table 10. reporting positions is easier than measuring and limiting risk. As is well known. do attempt to derive the limits using a method that is analytically similar to the approach used in the area of interest rate risk. a one or two standard deviation change in the exchange rate is considered. but there are exceptions. however. and daily closing at other institutions. For these institutions. those banks with more active trading positions tend to have invested in the real-time VaR systems discussed above. and worse-case scenario simulated. the derivation of exposure limits has tended to be an imprecise and inexact science. however. for these. the latter is more common than the former.
and a crisis that is system-wide. this liquidity need is forecastable and easily analyzed. attempts to analyze liquidity risk as a need for resources to facilitate growth.Incentive systems for foreign exchange traders are another area of significant differences between the average commercial bank and its investment banking counterpart. many argue that there is absolutely none. While some admit to significant correlation between trader income and trading profits. and tries to estimate the speed with which the shock will result in a funding crisis. this is less true in the banking industry. Other institutions attempt to measure the speed with 20 . Standard reports on liquid assets and open lines of credit. In each case. to their way of thinking. Each has some validity. This latter group tends to see such linkages leading to excess risk taking by traders who gain from successes but do not suffer from losses. what is required is an analysis of funding demands under a series of "worst case" scenarios. These include the liquidity needs associated with a bank-specific shock. Reports center on both features of the crisis with Table 11 illustrating one bank's attempt to estimate the immediate funding shortfall associated with a downgrade. The counterpart of standard cash management. D. Accordingly. and the easiest in most regards. such as a severe loss. In this case. The first. or honor outstanding credit lines are of little relevance to the risk management agenda pursued here. which are germane to the first type of liquidity need. Rather. Yet. Liquidity Risk Management Procedures Two different notions of liquidity risk have evolved in the banking sector. Accordingly. The liquidity risk that does present a real challenge is the need for funding when and if a sudden crisis arises. the bank examines the extent to which it can be self-supporting in the event of a crisis. risk is reduced by separating foreign exchange profitability and trader compensation. While. in the investment banking community trader performance is directly linked to compensation. the issues are very different from those addressed above. In today's capital market banks of the sort considered here have ample resources for growth and recourse to additional liabilities for unexpectedly high asset growth. is a notion of liquidity risk as a need for continued funding. the result is not worth much. are substantially less relevant to the second.
others have little faith in their ability to access them in a time of need. Results of such simulated crises are usually expressed in days of exposure. Others view this planning document as little more than a regulatory hurdle. there is a clear distinction among institutions. either from prior experience or attempts at verification. as to the value of this type of exercise. They contend that. Some attempt to develop careful funding plans and estimate their vulnerability to the crisis with considerable precision. While some actually invest in backup lines without "material adverse conditions" clauses. regulatory authorities have increasingly mandated that a liquidity risk plan be developed by members of the industry. Yet. Response strategies considered include the extent to which the bank can accomplish substantial balance sheet shrinkage and estimates are made of the sources of funds that will remain available to the institution in a time of crisis. As a result. imprecise but essential to efficient operation in the event of a substantial change in the financial conditions of the firm. Such studies are. by their nature.which assets can be liquidated to respond to the situation using a report that indicates the speed with which the bank can acquire needed liquidity in a crisis. or days to funding crisis. 21 . they could and would use the proposed plan in a time of crisis.
It results in a rating. using gap. the techniques used to measure. interest rate. While generally referred to as risk management. they are not ignored at the senior management level of the bank. as well as effective duration. In each of these cases. substantial time and resources are devoted to protecting the firm's franchise value from erosion. foreign exchange and liquidity risk. reputational and environmental risk. Standard business judgment is used in this area to measure the costs and benefits of both risk reduction expenditures and system design. and techniques have been deployed to control each of them. In each of these risk areas. using on.E. this activity is substantially different from the management of financial risk addressed here. and/or system failure. Other Risks Considered But Not Modeled Beyond the basic four financial risks. but the real analysis is conducted with the benefit of simulation techniques. The extent of the differences across risks of different types is quite striking. and on-going monitoring of various types or measures of exposure. suitability. somewhat more amorphous. Foreign exchange or general trading risk is monitored in real time with strict limits and 22 . usually weekly. periodic re-evaluation at reasonable intervals through time. In this latter category are legal.. banks have a host of other concerns as was indicated above. As these risks are less financially measurable. there are still other risks. but no less important. The credit risk process is a qualitative review of the performance potential of different borrowers. The position is reported in repricing terms. or at least has evolved. Limits are established and synthetic hedges are taken on the basis of these cash flow earnings forecasts. and manage the risks of various types have been presented. as well as operational redundancy. Yet. they are generally not addressed in any formal. like operating risk. Some of these. Yet. to measure the risk considered. Risk Aggregation and the Knowledge of Total Exposure Thus far.and off-balance sheet exposure. report. viz. Interest rate risk is measured. structured way. credit. limit. are a natural outgrowth of their business and banks employ standard risk avoidance techniques to mitigate them. a process has been developed. regulatory. VI.
23 . however. and determine the best interest of the bank as a whole. The purpose of this institutional response is to empower one individual or group with the responsibility to evaluate overall firm-level risk. The analytical approaches that are subsumed in each of these analyses are complex. At the analytical level." Senior management often is presented with a myriad of reports on individual exposures. this group is holding line officers more accountable for the risks under their control. and/or distributions constructed from historical outcomes. aggregate risk exposure is receiving increased scrutiny. however. In light of recent losses. more often than not. on the other hand. As the organizational level. This is accomplished in two distinct. requires the summation of the different types of risks outlined above. Accordingly. To do so. an appropriate level of risk for the organization as a whole. difficult and not easily communicated to non-specialists in the risk considered. is dealt with as a planning exercise. although some reasonable work is done to analyze the funding effect of adverse news. How is this being done? The simple answer is "not very well. Here again. The bank. The risks are not dimensioned in similar ways. at least articulate. headed by someone designated as the Senior Risk Manager. the managers of specific risks have gained increased authority and autonomy. and management's technical expertise to appreciate the true nature of both the risks themselves and the analyses conducted to illustrate the bank's exposure is limited. things are beginning to change. such as specific credits. and complex summaries of the individual risks. At the same time. as outlined above. however. the effects of adverse rate movements are analyzed by simulation using ad hoc exchange rate variations. but on overall profitability. overall risk management is being centralized into a Risk Management Committee. which is based not on business volume. over time. must select appropriate levels for each risk and select or. and the performance of the institution in that risk area.accountability. Activity and sales incentives are being replaced by performance compensation. Liquidity risk.
the firm restricts its exposure so that. risk is aggregated and priced in one and the same exercise. however.or two standard deviation outcome is considered. The approach. Again. A second approach is similar to the RAROC. See Salomon Brothers (1993) and Wee and Lee (1995) for the most complete public information on Bankers Trust RAROC systems. when employed to analyze interest rate risk. a frequency distribution of returns for any one type of risk can be estimated from historical data. By dimensioning all risk in terms of loss distributions. a frequency distribution of returns is estimated. or a one. and allocating capital by the volatility of the proposed activity. If EaR is used.but related ways. Where possible. it is cash flow based. and the standard deviation of this distribution is estimated. Therefore. risk is measured in terms of variability of outcome. Given the downside outcome associated with any risk position. rather than moving from volatility of value through capital. the risky position is required to carry an expected rate of return on allocated capital which compensates the firm for the associated incremental risk. Extreme outcomes can then be estimated from the tail of the distribution.14 In this approach. This was referred to as the Earnings At Risk methodology above. This method can be used to analyze total firm-level risk in a similar manner to the RAROC system. And. in any case. Rather it depends upon a subjectively prespecified range of the risky environments to drive the worst-case scenario. rather than market value driven. Capital is allocated to activities as a function of this risk or volatility measure. the bank does not lose more than a certain percentage of current income or market value. has two very obvious shortcomings. in the worst-case scenario. pioneered by Bankers Trust. but depends less on a capital allocation scheme and more on cash flow or earnings effects of the implied risky position. is the RAROC system of risk analysis. The first of these. Then. it does not directly measure the total variability of potential outcomes through an a priori distribution specification. 14 24 . from historical data. the approach becomes identical to the VaR methodology employed for trading exposure. When market values are used. Either a worst-case historical example is used for this purpose. this approach goes directly to the current earnings implications from a risky position.
In addition. Yet. they separately evaluate each risk and aggregate total exposure by simple addition. most. Credit losses. Areas Where Further Work Will Improve the Methodology The banking industry is clearly evolving to a higher level of risk management techniques and approaches than had been in place in the past. CREDIT RISK The evaluation of credit rating continues to be an imprecise process. however. offsetting. By category. As a practical matter. VI. its rating procedures need to be made compatible with rating systems elsewhere in the capital market. Perhaps over time this issue will be addressed. Accordingly. if not all. however. In addition. this approach needs to be standardized across institutions and across borrowers. much is lost in the aggregation. The risk management approaches at smaller institutions. Nonetheless. there is significant room for improvement. However. Over time. however. as well as larger but relatively less sophisticated ones. of these models do not view this array of risks as a standard portfolio problem. it is worthwhile to reiterate an earlier point. currently vaguely related to credit rating. attempt to treat the issue of trade-offs among risks. as this review indicates. our review should be viewed as a glimpse at best practice. or should be viewed as. not average practices. As a result. the industry currently does not have a sufficiently broad data base on which to perform the migration analysis that has been studied in the bond market. are less precise and significantly less analytic. The risk management techniques reviewed here are not the average. As in the bond market. A.Both measures. In some cases they would need substantial upgrading to reach the level of those reported here. recommended areas where additional analytic work would be desirable are listed below. but the techniques used by firms at the higher end of the market. using a common methodology to transform the specific risks to firm-level exposure. need to be closely tracked. Rather. credit rating and expected loss ought to be demonstrably closer. credit pricing. 25 . both can examine the correlation of different risks and the extent to which they can. the techniques employed by those that define the industry standard could use some improvement. Before the areas of potential value added are enumerated.
If liquidity risk is to be managed. This approach can and should be used to a greater degree than it is currently. C. the use of book value accounting measures and cash flow losses continues to be problematic. D. Movements to improve this methodology will require increased emphasis on market-based accounting. LIQUIDITY RISK Crisis models need to be better linked to operational details. the price of illiquidity must be defined and built into illiquid positions. While this logic has been adopted by some institutions. However. and not sufficiently managing their credit concentrations by either industrial or geographic areas. much of the banking industry continues to use rather ad hoc approaches in setting foreign exchange and other trading limits. In addition. OTHER RISKS As banks move more off balance sheet. analysis is needed to evaluate the diversification gains associated with careful portfolio design. and scenario testing rather limited. the usefulness of such exercises is limited by the realism of the environment considered. Yet. these simulations tend to be rather simplistic. The simulations also need to incorporate the advances in dynamic hedging that are used in complex fixed income pricing models. At this time. INTEREST RATE RISK While simulation studies have substantially improved upon gap management. they are ignored when bank risk management is considered. Currently. 26 . banks appear to be too concentrated in idiosyncratic areas. not just the asset portfolio. the implied risk of these activities must be better integrated into overall risk management and strategic decision making. this pricing of liquidity is not commonplace. such a reporting mechanism must be employed on both sides of the balance sheet. As it stands. E. B. In short.The issue of optimal credit portfolio structure warrants further study. FOREIGN EXCHANGE RISK The VaR approach to market risk is a superior tool.
Yet. the decisions to accept risk and the pricing of the risky position are separated from risk analysis. It is inconceivable that Boards of Directors and even most senior managers have the level of expertise necessary to operate the evolving system. Yet. A trading risk is similar to a credit risk. Yet government regulators seem to have no idea of the level of complexity. for example. AGGREGATION OF RISKS There has been much discussion of the RAROC and VaR methodologies as an approach to capture total risk management. Both aggregate risk methodologies presume that the time dimensions of all risks can be viewed as equivalent. thus far no one firm has tried to address this issue adequately. operating such a complex management system requires a significant knowledge of the risks considered and the approaches used to measure them. If aggregate risk is to be controlled. and attempt to increase accountability even as the requisite knowledge to control various parts of the firm increases. This appears problematic when market prices are not readily available for some assets and the time dimensions of different risks are dissimilar. 27 .F. these parts of the process need to be integrated better within the banking firm. Finally. frequently.
and A.D. A. P. Robert Morris Associates. Federal Financial Institutions Examination Council.” Journal of Risk and Insurance.” Journal of Finance. E.” April 10. Risk. August 1993. and Santomero. forthcoming.305-60. Berger. Economist.” Structural Change in Banking. F. E. “Calculating Value-at-Risk. Commercial Loan Portfolio Management .. A. Value at Risk: The New Benchmark for Control Mar ket Risk. and Udell. Babbel. Bhattacharya. Furash. “Theory of the Firm: Managerial B ehavior Agency Costs and Ownership Structure. “Financial Risk Management by Insurers: An Analysis of the Process. “The Theory of Financial Intermediation.References Allen. “ Relationship Lending and Lines of Credit in Small Firm Finance. “Value at Risk: Implementing a R isk Measurement Standard. Marshall. Morsman. Jensen M. Loss Reserves and the Pricing of Corporate Bank Loans. p. G.” Journal of Economics and Business. M. 1993.Siegel. 28 .” Journal of Financial Intermediation . Illinois. 1993. The Wharton School. Klausner and L. Moody’s Special Report . December. Illinois.” Risk Management Planning Seminar. “Organizing the Risk Management Process In Large Banks. 1994. Scharfstein. 1993. White. Moody’s Investor Service. and Udell. Jorion. Wharton Financial Institutions Center. July 1995. Irwin Professional Publications. 1997. and W. August. “Securitization. Corporate Bond Defaults and Default Rates 1970-1995 . Altman.Santomero. A. editors.. and M. University of Pennsylvania.” Journal of Banking and Finance . And Santomero . Philadelphia.Meckling.” Working Paper 96-47. and J. and A.” Journal of Commercial Bank Lending. Fallon. Froot. “Risk Management: Coordinating Investment and Financing Policies. A. 1993. June 1997 forthcoming. Stein. D.. Th e Wharton School. 1996. Irwin Publishers. “Valuation. Thakor. C. 1993. G. Berger.. September29. Washington.” Journal of Business. D. 1996. “A Survey of International Banking. Kim. Wharton Financial Institutions Center. 1997. “Contemporary Banking Theory. “Forecasting Required Loan Loss Reserves. K.” Journal of Financial Economics 3. W. E. D.” Working Paper 96-49.. S. and the Liquidity Problem in Banking.C. 1993. University of Pennsylvania. 1996. 8-25.
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These names have sufficient margins of protection and will qualify as acceptable borrowers. liquidity and debt service coverage. governments of major industrialized countries. A loss year or a declining earnings trend may not be uncommon. very good management. May or may not require collateral in the course of normal credit extensions. but susceptible to more rapid deterioration than class 3 names. Average Risk Borrowers with smaller margins of debt service coverage and where definite elements of reduced strength exist. Typically large national corporations. Typically good regional or excellent local companies. dependence upon one type of business. good debt capacity and coverage. Typically larger regional or national corporations. Almost no risk in lending to this class. Such borrowers or weaker typically require collateral in normal credit extensions. The margins of protection are satisfactory. Management Attention Risk Borrowers who are beginning to demonstrate above average risk through declining earnings trends. Typically solid local companies. Basically. 5. 4. The credit extension is considered definitely sound. a few major world class banks and a few multinational corporations. and good management in all critical positions. Very good asset quality and liquidity. however.. or declining collateral quality/adequacy. Satisfactory asset quality and liquidity. historic earnings and/or cash flow patterns may be sometimes unstable. strained cash flow. Substantially Risk Free Borrowers of unquestioned credit standing at the pinnacle of credit quality. and/or weakening market fundamentals. Projected cash flows (including anticipated credit extensions) will continue a strong trend. pending litigation of a significant nature. increasing leverage. and provide continued wide margins of protection. Modest Risk Borrowers in the lower end of the high quality range. Also. operating problems. etc. strong debt capacity and coverage. elements may be present which suggest the borrower may not be free from temporary impairments sometime in the future. stability of margins and cash flows. but not limited to: Deteriorating industry conditions. . however. 6. concentration of assets. Below Average Risk The high end of the medium range between the definitely sound and those situations where risk characteristics begin to appear. Some elements of reduced strength are present in such areas as liquidity. Excellent asset quality and management.TABLE 1 A TYPICAL CREDIT RATING SYSTEM The following are definitions of the risk levels of Borrowing Facility: 1. borrowers which are currently performing as agreed but could be adversely impacted by developing factors such as. strong and liquid. cyclical trends. Minimal Risk Borrowers of the highest quality. which may adversely affect the borrower. Cash flows over at least 5 years demonstrate exceptionally large and/or stable margins of protection and balance sheets are very conservative. 3. 2.
indicating a downgrading from the better categories. Borrowers that have been or would normally be classified “Substandard” by regulatory authorities. no loss of principal or interest is envisioned. capital injection. for whatever reason. These are names that have been or would normally be criticized “Special Mention” by regulatory authorities. 7. highly questionable and improbable. conditions. Serious problems exist to the point where a partial loss of principal is likely. as well as those previously rated 6 or 5. but rather it is not practical or desirable to defer writing off this basically worthless asset even though partial recovery may be effected in the future. will weaken the asset or inadequately protect the bank’s position. This classification does not mean that the loan has absolutely no recovery or salvage value. increased reliance on bank debt. There is a distinct possibility that a partial loss of interest and/or principal will occur if the deficiencies are not corrected. Such borrowers may be highly leveraged companies which lack required margins or less leveraged companies with an erratic earnings records. the borrower is currently marginally acceptable. Potential Weakness Borrower exhibits potential credit weakness or a downward trend which. Pending factors include proposed merger. Potential Loss A borrower classified here has all weaknesses inherent in the one classified above with the added provision that the weaknesses make collection of debt in full. and some management weakness. Loss Borrowers deemed incapable of repayment of unsecured debt. No Loss A borrower with well defined weakness(es) that jeopardize the orderly liquidation of the debt.TABLE 1: A TYPICAL CREDIT RATING SYSTEM Page 2 Borrowers generally have somewhat strained liquidity. its classification as an estimated loss is deferred until its more exact status may be determined. or liquidation. The possibility of loss is extremely high. 8. Loans to such borrowers are considered uncollectible and of such little value that their continuance as active assets of the bank is not warranted. Included could be turnaround situations. limited debt capacity and coverage. Normal repayment from this borrower is in jeopardy. and values. on the basis of currently existing facts. names that have shown deterioration. although no loss of principal is envisioned. if not checked or corrected. While potentially weak. reasonably specific pending factors. 10. and slowing trade payments are some events which may occasion this categorization. which may work to the advantage and strengthening of the assets. Significant declines in earnings. and refinancing plans. but because of certain important. . A substandard loan is inadequately protected by the current sound worth and paying capacity of the obligor. frequent requests for waivers of covenants and extensions. Definite Weakness. acquisition. 9. perfecting liens on additional collateral.
LESS: OREO CHARGE-OFF ESTIMATE OREO RESERVABLES 3a.143 201 252 2. UNUSED COMMITMENTS @ 50% 3b.878 3a 2.144 0 1 0 1 1 0 1 0 27 27 0 0 0 0 27 288 0 0 0 0 1.139 201 0 252 0 511 1. OTHER LOANS AND LEASES TOTAL LOANS AND LEASES LOANS AND LEASES 1d.690 0 5 1 78 78 0 0 6 6 85 1.629 2.140 2.414 1b 481 1c 17. BANKER'S ACCEPTANCES @ 100% CONTINGENT EXPOSURE RESERVABLES RESERVABLES TOTAL RESERVABLES 0 0 0 18 18 0 0 0 0 18 20 0 0 1 5.143 0 201 0 252 0 2.111 0 0 0 15 15 0 0 0 0 15 240 0 0 0 0 0 0 0 0 0 0 1 0 0 2 0 5. COMMERCIAL LETTERS OF CREDIT @ 20% 3c. STAND-BY LETTERS OF CREDIT CONTINGENT EXPOSURE @ 100% 3d. LESS: GROSS COMMERCIAL LOAN C/O ESTIMATE TOTAL LOAN AND LEASE CHARGE-OFFS LOANS AND LEASE RESERVABLES 2a. OREO OREO 2b. COMMERCIAL LOANS AND LEASES 1b.856 45 231 0 48 0 9. CONSUMER LOANS 1c.037 0 2 1 50 50 0 0 0 0 51 2.751 21.374 65 481 3.959 980 19 4 76 76 0 0 1 1 1.901 0 -24 -24 1.TABLE 2 BANK LEVEL LOAN CREDIT QUALITY REPORT RISK RATING RATING TYPE RESERVABLES 1a.200 0 980 490 51 10 141 141 0 0 47 47 688 3.920 952 1.209 0 980 490 83 17 183 183 0 0 80 80 770 4.521 2 0 4 5.959 980 3 1 44 44 0 0 13 13 1.877 184 0 184 231 -17 0 -17 214 12 0 11 48 -47 0 -47 0 6 -6 1 937 15 1.169 0 1 2 3 4 5 6 7 8 9 10 TOTAL All items in millions of dollars .000 521 3.140 0 2. LESS: GROSS COMMERCIAL LOAN C/O ESTIMATE 1e.311 -64 1d -24 1e -89 17.037 1.060 3.222 202 2a -6 2b 196 5.521 0 3.939 165 3b 33 632 3c 632 1 3d 1 146 3e 146 3.920 0 952 2 5.426 1a 7.288 0 1. SWAPS @ 100% OF CREDIT EQUIVALENT EXPOSURE 3e.
Publishing and Broadcasting Retail Stores Telecommunications Textiles and Leather Transportation Utilities 6.9 3 5.8 2.8 3.2 3.9 2.6 2.5 2.8 4.9 2.7 1.6 2 2.3 0.4 1.3 3.3 3.8 3.6 4. 0.2 5 4.5 2.9 3 1.6 1.8 4.6 3.4 3.2 2.8 2 2.5 2.1 3.s 0. .TABLE 3 CREDIT EXPOSURE BY 34 MINOR INDUSTRY SECTORS Outstandings MOODY'S GROUP Unfunded Commitments Commitments Utili- % of Term Risk % of Term Risk % of Term Risk zation Rate Total to Rating Total to Rating Total to Rating Mat.9 2.8 1.6 2.5 2.6 1.5 0.3 4.4 1. Motion Pictures.2 3.4 60 2.9 1.4 4.7 0.4 4.6 2 4.6 3.3 2.6 4.3 3.1 4.6 5 1.6 5 42 60 23 55 76 64 53 61 59 Aerospace and Defense Automobile Banking Beverage.6 4.9 2.3 4.6 2.7 4.7 4.6 2.6 2.1 3.5 1.5 3.2 2.4 4 2.6 4.7 2.7 3.7 3.9 2.s 1.9 4. Plastics and Rubber Containers.7 2 2 1.2 1 3.7 4.9 1.2 2 2.1 2.1 2.1 5.4 3.6 14 4.8 3.2 2.3 3.1 0. Housewares.6 4.s Hotels.1 4.6 3.3 2 2.3 4.9 3.8 4.8 1.1 2.7 0.7 0.5 2.7 1.5 3.3 1.8 3.1 0.1 2.9 1.2 4.6 2.7 1.7 0.5 3.4 1.2 1.7 2.9 5.4 1.8 2 2.5 1.6 0.1 1.1 2.3 59 71 55 41 71 56 69 53 57 60 1.8 0.2 3. Education and Childcare Home/Office Furnishings.6 1 2.3 1.5 4.2 2.8 1.4 2.9 2.1 0.7 1.6 3.5 4.6 2.6 3.9 2. Food and Miscellaneous Serv.4 1 1. Mat.3 1.7 1.1 4.5 0.4 4.6 3.6 4.6 2.8 2. Precious Metals and Minerals Diversified/Conglomerate Manufacturing Diversified/Conglomerate Sevice Ecological Electronics Farming and Agriculture Finance Government Grocery Healthcare.9 5.3 3. Amusement.7 10.7 2.6 3.7 2.3 3.6 3.8 2.1 4 4.4 4.9 1.6 1.2 4.8 2.5 1. Food and Tobacco Buildings and Real Estate Cargo Transport Chemicals.6 4 4.4 3.4 2.9 1. Mat.8 1.4 2.4 2.3 2 3.4 1.1 4.8 4.6 4.3 4. Prod.7 7.5 4.5 18.7 5.7 3. "Risk Rating" is based upon a ten point scale.7 2.4 1.1 3.1 3.1 1.5 2.6 0.3 1 2. Packaging and Glass Diversified Natural Resources.3 3.8 4.7 2.3 1.6 1.1 3.3 1.7 2. as a weighted average of industry group.1 2.1 0.2 2.3 4. "Term to mat" is the term to maturity in years.9 2.6 4 3. Durable Consum.4 4.3 3.9 2.7 0.2 4.3 4.8 2 2.1 4.6 0.8 2.9 59 52 76 56 71 63 46 40 63 60 32 Personal.7 5 4.Non-Elec.3 2 1.6 2.7 4.3 2..9 1.2 4.1 4.7 2.6 3.9 4 3.Non-Constr.2 82 36 62 2.3 4.7 2. Non-Precious Metals Oil and Gas Other Personal/Non-Durable Consumer Prod.4 0.2 Printing.5 2.5 4.9 0.6 3.2 1.6 1 5.7 4.7 4.3 2.4 2.7 2.6 5.8 5. Entertainment Machinery (Non-Agri.8 4.6 2.3 1.) Mining.6 1.4 5 5.9 1.8 1 5. Steel.6 0.1 4.6 2.8 4. Iron.9 4.5 2.3 24.2 2.3 1.3 2.6 "% of total" is the percentage concentration in loan portfolio at the end of the reporting period.8 3.5 2.5 2.7 2. Inns and Gaming Insurance Leisure.8 3.4 4 2.3 4.9 3.8 2.2 4.7 2.7 4. Motels.9 4..3 2.1 1.2 4.7 2.
TABLE 4 COMPOSITION OF LOAN PORTFOLIO BY GEOGRAPHIC AREA Distribution of domestic commercial real estate loans by region Geographic Region Project Type Office complexes Retail Hotels Industrial Apartments Undeveloped land Health care Residential Other project types Total Central Southeast Midwest Atlantic $196 155 72 50 31 6 11 17 56 $594 $46 70 49 2 18 9 $194 $46 45 10 2 17 10 $130 West $36 22 6 5 9 4 3 $85 Southwest Northeast $12 11 12 3 3 4 4 $49 $6 $6 Total $342 303 149 62 51 43 28 24 56 $1.058 All items in millions of dollars .
000 2.000 3.629 Fixed 8% --- 1 3/10/95 D Miscellaneous Credit 5/5 900 9/31/94 100 Variable Base-FFB plus 50 0 Total Credit Availability (TCA) 10.629 1.000 Fixed 7% --- 3 1/2/95 C Commercial Mortgage Renovate Commercial Property 5 1.729 E Related Exposure (Not included in TCA): Advised Line of Credit Finance Accounts Receivable 6 200 0 Variable Base plus 100 0 -- All units in thousands of US dollars .000 0 B Commercial Mortage Acquire Commercial Property 6 3.529 6.TABLE 5 EXPOSURE SUMMARY FOR ONE SPECIFIC EXISTING FACILITY PRODUCT/PURPOSE RISK RATING APPROVED AMOUNT FACILITIES IN USE LOAN PRICING DOCUMENT DATE STRUCTURE /RATE A Advised Line of Credit Finance A/R and Inventory 6 5.000 INDEX /SPREAD 2 5/30/95 Limit: Loans Revolving Finance Accounts Receivable 3.000 Variable Base plus 50 Limit: LC's/ Revolving Finance Accounts Receivable 2.
668 $711 - $3.478 18 628 850 5.065 5.150 5.513 All units in millions of US dollars (Table continued on next page) .163 8.024 412 99 6.458 2.386 52 3.550 2.747 1.114 8.315 - $40 - $13.865 578 235 2.636 52.572 732 729 8.354 - $1.099 52 47.163 2.163 8.636 8.150 1.162 3.110 8.071 85 18 9.286 1.223 125 913 222 2.162 3.478 4.877 4.769 11.069 359 93 8 1.TABLE 6 INTEREST RATE SENSITIVITY TYPICAL GAP REPORT Prime loans and funding source ASSETS 0-3 months >3-6 months >6-12 months >1-5 years >5 years Nonmarket Total Investment Securities Federal funds sold and securities purchased under resale agreements Loans: Commercial Real estate 1-4 family first mortgages Other real estate mortgages Real estate construction Consumer Lease financing Foreign: Total Loans (2) Other earning assets: Total earning assets Noninterest-earning assets: Total assets $ - $533 1.990 11.058 1.912 7.668 4.103 1.865 2.519 66 1.990 591 1 226 94 3.212 18 33.053 3.015 115 1.085 - $7.715 13.565 316 1.171 112 4.069 13.162 537 12 303 175 2.
163 - 1.256 8.931) $4.405 $14.343 $11.163 2.965 37.487) ($1.163 $ 5.005 1.412 $7. .789 $2.315 4.402 245 $10.820) ($7.375 3.315 2.429 2.660 -14.789 $2.527 26 318 343 42 - 188 2.098 2. (2) The nonmarket column consists of nonaccrual loans of $1. fixed-rate credit card loans of $2.628 163 7.333 $10.785 1.155 315 8.011 1.079 - - - - - 1.544 14 2 $4.544 17.062 million (including $39 million in commercial credit card loans) and overdrafts of $130 million.401 3.935 $1.660 $14.00 ($1.00 761 1.072 $7.971 - 205 - 70 7.971 205 22.413 10.721 10.925 - 1.405 $ $ - - - - - - - $10.349 38 31.866) ($5.163 12.487) 193 $954 $533 214 $1.519 52.895 12.429 - 2.513 - -835.745 $2.494 million.464 - -7333 ($8.111 2.357 13 $ 2.825 - 2.437 191 $ 150 13 $4.785 - - - - - - 4.464 (1) The nonmarket column consists of marketable equities securities.405 - $ $ - -652.419 10.825 $ 8.128 65 >3-6 months >6-12 months >1-5 years >5 years Nonmarket Total $ 1.401 - 3. noninterest-bearing liabilities and stockholders'equity Move interest-bearing checking and savings deposits from nonmarket to shortest maturity Adjusted cumulative gap $ 8.079 - 188 1.069 31 $ 2.TABLE 6 continued Prime loans and funding source 0-3 months LIABILITIES AND STOCKHOLDERS' EQUITY Deposits: Interest-bearing checks Savings deposits Market rate savings Saving certificates Other time deposits Deposits in foreign offices: Total interest bearing deposits Federal funds purchased and securities sold under repurchase agreements Commercial paper and other short-term borrowings Senior debt Subordinated debt Total liabilities Noninterest-bearing liabilities Stockholders' equity Total liability and stockholders'equity Gap before interest rate financial contracts Interest-bearing interest rate swaps Gap adjusted for interest rate financial contracts Cumulative gap Adjustments: Exclude noninterest-earning assets.905 2.084 7.163 38 8.
45 Effective Duration Years Off Balance Sheet Notional Amount(1) Combined On & Off Balance Rate Adjusted Net Adjusted Effective Spread Rate Duration $15.133.00 0.53 1.61 1.00 14.62 2.33 2.64 6.00 8.07 -5.00 15.00 $72.90 1.19 1.47 1.73 1.01 1.00 2.78 7.78 0.460.00 2.00 2.638.84 $16.74 0.TABLE 7 A DURATION ANALYSIS OF INTEREST RATE RISK EXPOSURE On Balance Sheet As of December 31.61 2.250.629.10 6.49 -1.677.342.15 -1.04 2.205.61 2.73 0.00 31.624.04 2.90 9.729. .836.179.00 8.003.00 6.00 $16.75(%) 7.476.00 7.57 2.00 40.24 2.00 12.409.148.963.00 20.00 1.00 0.91 9.42 1.28 0.08 0.460.00 1. 1995 $ (millions) Assets: Variable rate prime loans Other variable loans/investments Total variable rate assets Fixed rate loans Other fixed investements Total fixed rate assets Other assets Total assets Liabilities: Contractually repriceable Variable borrowings Total variable liabilities Total fixed liabilities Non-interest bearing DDA Total deposits/borrowings Other liabilities Total liabilities $27.76 2.08 1.00 14.66 7.133.54 0.19 2.05 1.34 1.17 1.63 6.41 2.00 1.00 5.51 (1) $5.00 13.75 3.95 2.34 2.73(%) 7.19 2.00 37.885.98 -8.479.06 1.6 billion of basis swaps are excluded from variable rate prime notional amounts.00 0.919.00 10.00 71.42 2.00 1.00 0.00 27.396.06 2.73 $5.42 1.00 2.00 198.263.00 58.259.93 2.49 3.82 8.07(%) 8.67 8.88 0.51 4.00 $79.21 1.889.00 $14.26 3.82 2.38 1. but included in effective duration calculations.19 0.29 0.
00 -486 11.420 4.5.857 +/.6(%) +/.560.857 +/.80 32.545.20 4.60 -2.78.7(%) 2.00 32.5.20 -2.50 0.0(%) 4.241.40 32.6(%) $1.560.9 +/.75(%) -10.20 -0.90 +/.20.4(%) +/.892 4.00 32.545.90 +/.79(%) $1.551.0(%) Change in net interest income % Net interest income (b) W/ Deposit rates reflecting 50 basis point tightening in unchanged Total earning assets Net rate $1.72(%) $1.346 4.9 +/.50 32.109.892 4.00 $5.912 4.5.912 4.60 -0.420 4.40 32.80 32.30 .78(%) -5.5188.8.131.52 -1.0(%) $1.TABLE 8 NET INTEREST MARGIN SIMULATION Rate Scenario Unchanged 12 Months Net Interest Income: (a) W/ Deposit rates unchanged from 9/94 Total earning assets Net rate +100 bps +200 bps Limit -200 bps Limit $1.75(%) -36.0(%) $6.5.727.577.0(%) Change in net interest income % Net interest income Portfolio Equity: Market value Change in market value % Shareholder's equity Duration (years) $5.0(%) $1.1(%) +/.3(%) +/.74(%) 9.346 184.108.40.2060.90 +/.78(%) -31.0(%) $1.50 32.0(%) +/.74(%) -16.00 382 8.
In all cases. C. the policy will support the overall business and asset/liability strategies of the institution. Investment Authority Authority for investments is the responsibility of the Board Directors. Quarterly. B. The investment portfolio will be managed on a “buy and hold” basis. Reasonable portfolio diversification should be pursued to ensure that the bank does not have excessive concentration of individual securities. investments must meet all criteria stated in the Federal Law. and all requirements of our bonding company. Chief Financial Officer and the Financial Consultants will review the past quarter’s investment activity for safety and soundness. Investment performance in all classifications will be monitored on a frequent and regular basis to ensure that objectives are attained and guidelines adhered to. In all cases.TABLE 9 INVESTMENT POLICY A. but not excessive liquidity in meeting member demand for funds. Certain general tenets apply to the investment portfolio. Safety of assets is of primary concern. Paid in Capital. The investment portfolio should provide adequate. the activity for safety and sound the Chief Executive Officer. and the Allowance for Loan Losses. Investment Philosophy The bank recognizes a fiduciary responsibility to customers to invest all funds prudently and in accordance with ethical and prevailing legal standards. periodic sales of investment securities are permissible to meet operational cash needs or to restructure the portfolio mix in accordance with changes in investment strategy. In addition. in conjunction with wither the Controller or the Financial Analysis Manager. Unless stated otherwise. Introduction The purpose of this policy is to provide the basis for the bank to responsibly manage the investments in accordance with the philosophy and objectives stated below. The Chief Financial Officer. It recognizes that the investment portfolio must complement the loan portfolio and together they must be matched with liabilities. The Board shall designate the Chief Executive Officer and the Chief Financial Officer to act on its behalf and in accordance with this policy. Investment Objectives and Guidelines . only high quality investments will be purchased. the Rules and Regulations of the Regulators. D. However. security types or security characteristics. shall oversee the day-to-day operations of the investment portfolio and have specific investment and transaction execution authority. Regular Reserve. The term “capital “ will refer to the sum of Undivided Earnings. the terms “investment” and “investment portfolio” will refer to both cash management activities and longer-term investment securities.
c. f. and the only financial instruments which may be purchased are those which in the opinion of the Chief Financial Officer pose no significant credit risk. e. but three year ARMs and seven year balloons may be purchased. Term Fed Funds shall not exceed one year in maturity.Firm investments shall be managed at two levels: cash management needs and longer-term investment activities. Mortgage Backed Securities issues by or fully guaranteed as to principal and interest by the Federal National Mortgage Association. United States Treasury obligations will have a maximum maturity of three years. All investment activity is to be guided by the criteria specified in this policy. . safety of funds shall take precedence over yield and its attendant risks. 1. Maturities will be no longer than 180 days and the securities will be delivered to a third-party safekeeping agent. Fed Funds sold shall be conducted only with approved banks. Total private issue Mortgage Related Securities purchased shall not exceed $50 million. The minimum credit rating of these securities at the time of purchase must be AA or equivalent. In all cases. d. the Chief Financial Officer shall review a prospectus to determine whether the investment is permissible. Bankers’Acceptances issues only by approved banks. Total Bankers’ Acceptances purchased from a single issuing institution shall not exceed $50 b. g. or the Federal Home Loan Mortgage Corporation. Total certificates deposited in a single institution shall not exceed $50 million. United States Agency Securities (excluding MBS) shall be limited to a maximum maturity of three years. with both parties acting in the capacity of principal. Before authorizing a purchase of this type. Individual issues shall not exceed $50 million in value at the time of purchase. Total Fed Funds sold to a single institution shall not exceed $50 million. The funds of the bank can be invested in the following types of instruments with qualifications as provided: a. These investments will primarily be one year ARMs and five year balloons. Certificates of Deposit issued only by approved banks with a maximum maturities not to exceed one (1) year. Repurchase and Reverse Repurchase Agreements. Government National Mortgage Association. Individual securities shall not exceed $10 million in value at the time of purchase. Private Issue Mortgage Back Securities. but only with a Federally Insured Bank on the approved bank list. h.
Bruyette and Woods. etc. and that which conform to Federal rules and regulations. and minimum balance requirements for the Federal Reserve Account. and other external factors deemed appropriate. Cash Management a. j. domiciled subsidiaries of foreign institutions which are federally insured and carry a minimum credit rating of “B/C” by Keefe. i. The list may include several of the largest domestic banks and U. Investments in the money market mutual fund will be limited to $100 million on and investments in the MBS mutual fund will be limited to $25 million. The amount of funds will be continually evaluated depending upon lending trends and withdrawal experience. Total Yankeedollar or Eurodollar deposits in a single institution shall not exceed $50 million. Repurchase Agreements.S. Mortgage Backed Securities mutual funds that invest in agency and private issue MBS. Deliverable securities purchased will be delivered (either physically or via the Federal Reserve Bank wire system) simultaneously with the release of cash.. member demand for funds. The objective of the firm’s cash management policy is to provide sufficient liquidity each day to meet operating cash needs. the contracted safekeeping agent or trustee will provide written confirmation of each transaction to us and a monthly listing of all securities in its account. Banker’s Acceptances. 2. At a minimum. Agency Notes. The Chief Financial Officer shall maintain an approved list(s) of banks and other financial institutions with which the bank may conduct investment transactions. or Controller.million. or Accounting Supervisor shall execute these cash management activities and the Chief Financial . The Chief Financial Officer will make additions/deletions from the list(s) as appropriate. b. The Chief Financial Officer. whether to a custodian or to a trust account maintained. Money Market mutual funds that invest in CDs. and minimal fund price volatility. capital preservation. c. Financial Analysis Manger. Cash management funds shall be maintained to meet the withdrawal and lending needs of the customers. The objective of the MBS fund must be current income. Yankeedollar or Eurodollar deposits only in approved banks. Such delivery will be made to a third party for safekeeping. The bank will minimize the risk associated with executing securities transactions by limiting the securities brokers/dealers with which it does business to those who are primary dealers recognized and approved by the Federal Reserve System.
Each specific investment decision will be evaluated with respect to such issues as expected return. and the objectives of this Policy Statement. liquidity. b. meaning any method or transaction used to defer a loss whereby the bank sells a security to a vendor at a price above its current market price and simultaneously purchases or commits to purchase from that vendor another security above its current market price. 3.Officer shall review these transactions. Standby commitments to purchase or sell a security at a future date whereby the buyer is required to accept delivery of the security at the option of the seller. reinvestment risk) and changing market conditions. Investment Portfolio The management objective of the firm’s Investment Portfolio is to provide maximum return within the bounds of safety of principal and interest. F.e. d. Adjusted to trading. . liquidity. price risk. Maturity Structure The maturity structure of the investment portfolio will be managed in accordance with asset liability management needs. Controller. Cash forward agreements to buy when the delivery date is in excess of ninety (90) days from the trade date. liquidity risk. Prohibited Activities The following activities are prohibited: a. These modifications will be based on Asset/Liability Management concerns (i. It is the responsibility of the Chief Financial Officer to constantly monitor the maturity structure of the investment portfolio and implement modifications in the average maturity and makeup of the portfolio. Short sales of securities not owned by the bank. Futures trading. effect on the investment portfolio. market conditions. 4. credit risk. impact on asset/liability needs.. The Chief Financial Officer. E. FASB 115 Compliance In order to comply with the FASB 115. the bank will classify its investments as Trading. and proper safekeeping. e. and asset liability management demand. or Financial Analysis manager will execute investment portfolio transactions. c.
The remainder of the portfolio will be classified as Held-to-Maturity. Dollar and therefore will not incur any Sovereign or Exchange Rate Risk. All balloon MBS securities. FHLB stock. The bank has the positive intent and ability to hold these to maturity. Given our asset size. Sovereign and Exchange Rate Risk The bank will not invest in any foreign banking institutions or securities denominated in currencies other that U.Held-to-Maturity. $200 million of instantly accessible cash is more than adequate liquidity for any possible scenario. H. and Available-for-Sale. These securities will not be sold in response to changes in market interest rates. The bank normally has $20 million in Fed Funds and has a line of credit with the FHLB of over $50 million. G. and other fixed rate investments with a maturity of greater than one year at the time of purchase will be classified as Held-to-Maturity. Approved by the Board of Directors . All Fed Funds and mutual fund accounts will be classified as Trading Accounts.S. Modifications to Policy The Chief Financial Officer is responsible for recommending changes to this policy.
000 1.800 2. DOLLAR CANADIAN DOLLAR POUND STERLING SWISS FRANC GERMAN MARK DUTCH GUILDER JAPANESE YEN ITALIAN LIRE FRENCH FRANC BELGIAN FRANC AUSTRALIAN DOLLAR EUROPEAN CURRENCY UNIT (ECU) MINOR CURRENCIES ARGENTINIAN AUSTRAL AUSTRIAN SCHILLING BAHAMIAN DOLLAR BAHRAIN DINAR BARBADOS DOLLAR BERMUDA DOLLAR BRAZIL CRUZADO CAYMAN DOLLAR CHINESE RENMINBI DANISH KRONE E.00 2.040 6.00 4.00 65.240 5.417 625.00 4.200 8.00 4.00 30.00 ARP ATS BSD BHD BBD BMD BRC KYD CNY DKK XCD FJD FIM GRD 5.00 180.000 14.500 2.) DAYLIGHT CURRENCY POSITION (2 x NET) FX FORWARD RISK POINTS (US$ Equivalent) LIMIT INCR.500 5.666.00 18.00 140.00 45.00 560.000 -1.00 25.00 8.000 3.10 YRS./ (DECR.720 7.500 6.00 130.00 2.P.000 2.00 9.00 10.00 185.729.00 90.600 2.000 2.125 55.00 -60.00 840.00 2.167 1.500 1.00 10.00 60.167 864.00 10.00 220./ (DECR.00 5. CHANGE IN INTEREST RATES MAJOR CURRENCIES U.00 90.00 4.00 20.000 640 12.00 60.160 1.00 10.00 60.00 30.00 15.00 120.00 10.00 4.) CAP = 85.00 210.00 280.000.CARIBBEAN DOLLAR FIJI DOLLAR FINNISH MARKKA GREEK DRACHMA 540.000 OVERALL 0 .00 5.TABLE 10 GLOBAL FOREIGN EXCHANGE TRADING LIMITS CURRENCY TYPE CURRENCY SHORT NAME NET POSITION NET OVERALL CURRENCY POSITION LIMIT INCR.00 USD CAD GBP CHF DEM NLG JPY ITL FRF BEF AUD XEU 275.500 270.00 370.500 3.00 70.600 7.167 2.00 420.00 10.167 750 510 78.00 72 250 130 7.00 150.00 2.00 420.000 1.000 2.10 YRS.00 160.00 16.000 500 500 500 -4.667 312.00 2. LIMIT INCREASE MED-LONG TERM 2 .00 2.300 3.000 16.510.00 60.00 5.500 -1.520.604.500 26.040 6.00 60.00 14.220 900 3. LIMIT DECREASE SENSITIVITY TO A 25 B.00 65.00 4.000 -3.00 8.670 500 -500 500 -1.583 312.150 23.000 -1.500 104.792 .00 130.00 210.000 14.00 120.833 229.S.833 744.042 120 1.
938) (17.65%) (61. Change CATEGORY: TERM FUNDS AVAILABLE Rating Movement Downward Thomson Bankwatch B Thomson Bankwatch B/C Thomson Bankwatch C Total $19. Change .299 $17.TABLE 11 ONE DAY FALLOUT FUNDING SCENARIO CATEGORY: OVERNIGHT FUNDS AVAILABLE Rating Movement Downward to: Thomson Bankwatch B Thomson Bankwatch B/C Thomson Bankwatch C Total $16.864) ($9.771) (11.229 $13.24%) Change Pct.458 ($2.49%) (35.365 $6.209) ($6.291 ($2.21%) Change Pct.020 $12.
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