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Liquidity Management in Banks: The Cash Flow Approach .

Measuring and managing the liquidity needs are vital for effective operation of commercial banks. By assuring a bank's ability to meet its liabilities as they become due, liquidity management can reduce the probability of an adverse situation developing. The importance of liquidity transcends individual institutions, as liquidity shortfall in one institution can have repercussions on the entire system. Bank managements should measure, not only the liquidity positions of banks on an ongoing basis, but also examine how liquidity requirements are likely to evolve under different conditions. Banks are in the business of maturity transformation. They lend for longer time periods, as borrowers normally prefer a longer time frame. But their liabilities are typically short term in nature, as lenders normally prefer a shorter time frame (liquidity preference). This results in long-term interest rates typically exceeding short-term rates. Hence, the incentive for banks for performing the function of financial intermediation is the difference between interest receipt and interest cost which is called the interest spread. It is implicit, therefore, that banks will have a mismatched balance sheet, with liabilities greater than assets in short term, and with assets greater than liabilities in the medium and long term. These mismatches, which represent liquidity risk, are with respect to various time horizons. Hence, the overwhelming concern of a bank is to maintain adequate liquidity. Liquidity has been defined as the ability of an institution to replace liability run off and fund asset growth promptly and at a reasonable price. Maintenance of superfluous liquidity will, however, impact profitability adversely. It can also be defined as the comprehensive ability of a bank to meet liabilities exactly when they fall due or when depositors want their money back. This is a heart of the banking operations and distinguishes a bank from other entities. Objectives and Methodology of the Study Though Basel Capital Accord and subsequent RBI guidelines have given a structure for Liquidity Management and Asset Liability Management (ALM) in banks, the Indian banking system has not enforced the guidelines in total. The banks have formed Asset-Liability Committees (ALCO) as per the guidelines; but these committees rarely meet to take decisions. Taking this as a base, this research article attempts to find out the status of Liquidity Management in State Bank of India with the help of "Cash Flow Approach" methodology for controlling liquidity risk. To achieve the main purpose, the following objectives are set forth:

To identify the liquidity risks faced by the banks. Classification of assets and liabilities into different time buckets as per RBI guidelines issued for liquidity management in banks.

Analysis of liquidity risk through Cash Flow Approach Method.

The study covers SBI's data for evaluation. The relevant data have been collected from the published annual report of the bank for the period from 2000 to 2007. In order to have effective liquidity management, bank need to undertake periodic funds flow projections, taking into account movements in nontreasury assets and liabilities [fresh deposits, maturing deposits (and maturing) and new term loans]. This enables forward planning for Cash Reserve Ratio (CRR) and Statutory Liquidity Ratio (SLR) maintenance. Cash Reserve Ratio A scheduled bank is under the obligation to keep a cash reserve called the Statutory Cash Reserve, with the Reserve Bank of India (RBI) under Section 42 of the Reserve Bank of India Act, 1934. Every scheduled bank is required to maintain with the Reserve Bank an average daily balance equal to least 3% of its net demand and time liabilities. Average daily balances mean the average of balances held at the close of business on each day of the fortnight. The Reserve Bank is empowered to increase the rate of Statutory Cash Reserve from 3% to 20% of the Net Demand and Time Liabilities (NDTL). The rate of CRR in March 2007 was 6%. Liabilities of a Scheduled bank exclude:

Its paid-up capital and reserves Loans taken from the RBI or IDBI or NABARD The aggregate of the liabilities of a scheduled commercial bank to the State Bank or its subsidiary bank, any nationalized bank or a banking company or a cooperative bank or any financial institution notified by the Central Government in this behalf shall be reduced by the aggregate of the liabilities of all such banks and institutions to the concerned scheduled bank.

Thus, the entire amount of interbank liability for the purpose of Section 42 is excluded and the net liability of a scheduled bank to the entire banking system, (i.e., after deducting the balance maintained by it with all other banks from its gross liabilities to them) will be deemed to be its liabilities to the system. The objective of maintaining a minimum balance with RBI is basically to ensure the liquidity and solvency of the scheduled banks. Every reporting fortnight starts on a Saturday, or, if it is a holiday, the next working day and ends on the following second Friday (Thursday or the previous working day if Friday is a holiday). Branches send their data to their Head Office. Preliminary NDTL returns are due to the RBI in seven days of the close of a reporting fortnight, while final returns must reach in 21 days.

The NDTL statement in Form A is prescribed by the RBI. There is a fixed format in which branches send data to the CRR/SLR cell responsible for the RBI returns. Statutory Liquidity Ratio Section 24(2A) of Banking Regulation Act, 1949, requires every banking company to maintain in India in Cash, Gold or Unencumbered Approved Securities or in the form of net balance in current accounts maintained in India by the bank with a nationalized bank, equivalent to an amount which shall not at the close of the business on any day be less than 25% or such other percentage not exceeding 40% as the RBI may from time to time, by notification in the Gazette of India, specify, of the total of its demand and time liabilities in India as on the last Friday of the second preceding fortnight, which is known as SLR. At present, all Scheduled Commercial Banks are required to maintain a uniform SLR of 25% of the total of their demand and time liabilities in India as on the last Friday of the second preceding fortnight which is stipulated under Section 24 of the RBI Act, 1949. RBI can enhance the stipulation of SLR (not exceeding 40%) and advise the banks to keep a large portion of the funds mobilized by them in liquid assets, particularly government and other approved securities. As a result, funds available for credit would get reduced. All banks have to maintain a certain portion of their deposits as SLR and have to invest that amount in these Government securities. Government securities are sovereign securities. These are issued by the RBI on behalf of the Government of India, in lieu of the Central Government's market borrowing program. The term government securities include:

Government Dated Securities, i.e., Central Government Securities State Government Securities Treasury Bills.

The Central Government borrows funds to finance its fiscal deficit. The market borrowing of the Central Government is raised through the issue of dated securities and 364 days Treasury Bills, either by auction or by floatation of fixed coupon loans. In addition to the above, Treasury Bills of 91 days are issued for managing the temporary cash mismatches of the government. These do not form part of the borrowing program of the Central Government. Based on the required CRR and SLR per day, the treasury department of the bank ensures that sufficient balance is maintained in the Reserve Bank (at its different branches). The fund manager calculates on a daily basis the RBI balances based on opening RBI balances and taking into account various inflows and outflows during the day. The fund manager takes the summary of inflows and outflows and the net effect is added to/subtracted from the

opening RBI balances. By this method, an RBI balance of all the 14 days is arrived at. For instance, on the opening day of the fortnight, if there is an anticipated surplus, banks can generally lend it at an average, subject to subsequent inflows/outflows. Conversely, for a shortfall, the bank may borrow the required amount in call/repo/Collatera lized Borrowings and Lending Obligations (CBLO) markets on a daily basis. Successful functioning of the funds department depends mostly on the prompt collection of information from branches/other departments regarding the inflow and outflow of funds. The information should also be collected accurately and collated properly/correctly. Improper maintenance of liquidity and CRR position by the fund manager may lead to either a default or an excess which does not earn any interest for the bank. Cash Flow Approach Model for Liquidity Risk Liquidity Risk Liquidity risk is the potential inability to meet the bank's liabilities as they become due. It arises when banks are unable to generate cash to cope with a decline in deposits or increase in assets. It originates from the mismatches in the maturity pattern of assets and liabilities. Measuring and managing liquidity needs are vital for effective operation of commercial banks. By assuring a bank's ability to meet its liabilities as they become due, liquidity management can reduce the probability of an adverse situation developing. Analysis of liquidity risk involves the measurement of, not only the liquidity position of the bank on an ongoing basis but also examining how funding requirements are likely to be affected under crisis scenarios. Net funding requirements are determined by analyzing the bank's future cash flows based on assumptions of the future behavior of assets and liabilities that are classified into specified time buckets and then calculating the cumulative net flows over the time frame for liquidity assessment. Future cash flows are to be analyzed under "what if" scenarios so as to assess any significant positive/ negative liquidity swings that could occur on a day-to-day basis and under bank specific and general market crisis scenarios. Factors to be taken into consideration while determining liquidity of the bank's future stock of assets and liabilities include: their potential marketability, the extent to which maturing assets /liability will be renewed, the acquisition of new assets/liability and the normal growth in asset/liability accounts. Factors affecting the liquidity of assets and liabilities of the bank cannot always be forecast with precision. Hence, they need to be reviewed frequently to determine their continuing validity, especially given the rapidity of change in financial markets. The liquidity risk in banks manifest in different dimensions:

Funding Risk need to replace net outflows due to unanticipated withdrawal/non- renewal of deposits (wholesale and retail); Time Risk need to compensate for non-receipt of expected inflows of funds, i.e., performing assets turning into non-performing assets; and Call Risk due to crystallization of contingent liabilities and inability to undertake profitable business opportunities when desirable.

A Framework for Measuring and Managing Liquidity Measuring and managing liquidity needs are vital for effective operation of commercial banks. By assuring a bank's ability to meet its liabilities as they become due, liquidity management can reduce the probability of an adverse situation developing. The importance of liquidity transcends individual institutions, as liquidity shortfall in one institution can have repercussions on the entire system. Bank managements should measure not only the liquidity positions of banks on an ongoing basis, but also examine how liquidity requirements are likely to evolve under different assumptions. Experience shows that assets like government securities and other money market instruments, which are generally treated as liquid could also become illiquid when the market and players are unidirectional. Therefore, liquidity has to be tracked through maturity or cash flow mismatches. The framework for assessing and managing bank liquidity has three dimensions:

Measuring and managing net funding requirements Managing market access and Contingency planning.

Measuring and Managing Net Funding Requirements The first step towards liquidity management is to put in place an effective liquidity management policy, which, inter alia, should spell out the funding strategies, liquidity planning under alternative scenarios, prudential limits, liquidity reporting/reviewing , etc. Liquidity measurement is quite a difficult task and can be measured through stock or cash flow approaches. The key ratios, adopted across the banking system are: loans to total assets, loans to core deposits, large liabilities (minus) temporary investments to earning assets (minus) temporary investments, purchased funds to total assets, loan losses/net loans, etc. While liquidity ratios are the ideal indicators of liquidity of banks operating in developed financial markets, the ratios do not reveal the intrinsic liquidity profile of Indian banks which are operating generally in an illiquid market. Experiences show that assets like government securities, other money market instruments, etc., commonly considered as liquid have limited liquidity as the market and players are unidirectional. Thus, analysis of liquidity involves tracking of cash flow mismatches.

For measuring and managing net funding requirements, the use of a maturity ladder and calculation of cumulative surplus or deficit of funds at selected maturity dates is adopted as a standard tool. The maturity profile could be used for measuring the future cash flows of banks in different time buckets. The time buckets, given the Statutory Reserve Cycle of 14 days,which are generally treated as liquid may be distributed as under:

1 to 14 days 15 to 28 days 29 days and up to 3 months 3 months and up to 6 months 6 months and up to 1 year 1 year and up to 3 years 3 years and up to 5 years Above 5 years.

The investments in SLR securities and other investments are assumed as illiquid due to lack of depth in the secondary market and are, therefore, required to be shown under the respective maturity buckets, corresponding to the residual maturity. However, some of the banks may be maintaining securities in the `Trading Book', which are kept distinct from other investments made for complying with the Statutory Reserve Requirements and for retaining relationship with customers. Securities held in the `Trading Book' are subject to certain preconditions like:

Clearly defined composition and volume; Maximum maturity/duration of the portfolio is restricted; The holding period not to exceed 90 days; Cut-loss limit prescribed; Defeasance periods (product-wise) , i.e., time taken to liquidate the position on the basis of liquidity in the secondary market are prescribed; Marking to market on a daily/weekly basis and the revaluation gain/loss charged to the profit and loss account, etc.

Banks which maintain such `Trading Books' and comply with the above standards are permitted to show the trading securities under 1-14 days, 1528 days and 29-90 days buckets on the basis of the defeasance periods. The Board/ALCO of the banks should approve the volume, composition, holding/defeasance period, cut loss, etc., of the `Trading Book' and copy of the policy note thereon should be forwarded to the Department of Banking Supervision, RBI. Within each time bucket, there could be mismatches depending on cash inflows and outflows. While the mismatches up to one year would be relevant since these provide early warning signals of impending liquidity problems, the main focus should be on the short-term mismatches, viz., 1-14 days and

15-28 days. Banks, however, are expected to monitor their cumulative mismatches (running total) across all time buckets by establishing internal prudential limits with the approval of the Board/Management Committee. The mismatches (negative gap) during 1-14 days and 15-28 days in normal course may not exceed 20% of the cash outflows in each time bucket. If a bank, in view of its current asset-liability profile and the consequential structural mismatches, needs higher tolerance level, it could operate with higher limit sanctioned by its Board /Management Committee, giving specific reasons on the need for such higher limit. The Statement of Structural Liquidity (Annexure I) may be prepared by placing all cash inflows and outflows in the maturity ladder according to the expected timing of cash flows. A maturing liability will be a cash outflow while a maturing asset will be a cash inflow. It would also be necessary to take into account the rupee inflows and outflows on account of Forex operations. While determining the likely cash inflows/ outflows, banks have to make a number of assumptions according to their asset-liability profiles. For instance, Indian banks with a large branch network can (on the stability of their deposit base as most deposits are rolled-over) afford to have larger tolerance levels in mismatches in the long-term, if their term deposit base is quite high. While determining the tolerance levels, the banks may take into account all relevant factors based on their asset-liability base, nature of business, future strategy, etc. The RBI is interested in ensuring that the tolerance levels are determined keeping all necessary factors in view and further refined with experience gained in Liquidity Management. "In order to enable banks to monitor their short-term liquidity on a dynamic basis over a time horizon spanning from 1-90 days, they may estimate their short-term liquidity profiles on the basis of business projections and other commitments for planning purposes." Managing Market Access Apart from the above cash flows, banks should also track the impact of prepayments of loans, premature closure of deposits and exercise of options built in certain instruments which offer put/call options after specified times. Thus, cash outflows can be ranked by the date on which liabilities fall due, the earliest date a liability holder could exercise an early repayment option or the earliest date on which contingencies could be crystallized. The difference between cash inflows and outflows in each time period, the excess or deficit of funds becomes a starting point for a measure of a bank's future liquidity surplus or deficit, at a series of points of time. Banks should also consider putting in place certain prudential limits, as detailed below, to avoid liquidity crisis:

Cap on interbank borrowings, especially call borrowings; Purchased funds vis--vis liquid assets; Core deposits vis--vis Core Assets, i.e., CRR, SLR and Loans;

Duration of liabilities and investment portfolio; Maximum Cumulative Outflows across all time bands; Commitment Ratio track the total commitments given to corporates/banks and other financial institutions to limit the offbalance sheet exposure; and Swapped Funds Ratio, i.e., extent of Indian Rupees raised out of foreign currency sources.

Banks should also evolve a system for monitoring high-value deposits (other than interbank deposits), say Rs. 1 cr, or more to track the volatile liabilities. Further, the cash flows arising out of contingent liabilities in normal situation and the scope for an increase in cash flows during periods of stress should also be estimated. It is quite possible that market crisis can trigger substantial increase in the amount of draw downs from cash credit/overdraft accounts, contingent liabilities like letters of credit, etc. The liquidity profile of the banks could be analyzed on a static basis, wherein the assets and liabilities and off-balance sheet items are pegged on a particular day and the behavioral pattern and the sensitivity of these items to changes in market interest rates and environment are duly accounted for. Banks can also estimate the liquidity profile on a dynamic way by giving due importance to:

Seasonal pattern of deposits/loans; Potential liquidity needs for meeting new loan demands, unavailed credit limits, potential deposit losses, investment obligations, statutory obligations, etc.

Contingency Planning

All banks are required to produce a Contingency Funding Plan (CFP). These plans are to be approved by ALCO, submitted annually as part of the Liquidity and Capital Plan, and reviewed quarterly. The preparation and the implementation of the plan may be entrusted to the treasury. CFP are liquidity stress tests designed to quantify the likely impact of an event on the balance sheet and the net potential cumulative gap over a 3-month period. The plan also evaluates the ability of the bank to withstand a prolonged adverse liquidity environment. At least two scenarios require testing: Scenario A, a local liquidity crisis, and Scenario B, where there is a nationwide problem or a downgrade in the credit rating if the bank is publicly rated. The bank's CFP should reflect the funding needs of any bank managed mutual fund whose own CFP indicates a need for funding from the bank. Reports of CFPs should be prepared at least quarterly and reported to ALCO.

If a CFP results in a funding gap within a 3-month time frame, the ALCO must establish an action plan to address this situation. The Risk Management Committee should approve the action plan. At a minimum, CFPs under each scenario must consider the impact of accelerated run off of large funds providers. The plans must consider the impact of a progressive, tiered deterioration, as well as sudden, drastic events. Balance sheet actions and incremental sources of funding should be dimensioned with sources, time frame and incremental marginal cost and included in the CFPs for each scenario. Assumptions underlying the CFPs, consistent with each scenario, must be reviewed and approved by ALCO. The Chief Executive/Chairman must be advised as soon as a decision has been made to activate or implement a CFP. The Chief Executive or the Risk Management Committee may call for implementation of a CFP. The ALCO will implement the CFP, amending it with the approval of the Risk Management Committee, where necessary, to meet changing conditions; daily reports are to be submitted to the Treasury Head, comparing actual cash flows with the assumptions of the CFP.

Foreign Currency Liquidity Management For banks with an international presence, the treatment of assets and liabilities in multiple currencies adds a layer of complexity to liquidity management for two reasons. First, banks are often less well-known to liability holders in foreign currency markets. Therefore, in the event of market concerns, especially if they relate to a bank's domestic operating environment, these liability holders may not be able to distinguish rumor from fact as well or as quickly as domestic currency customers. Second, in the event of a disturbance, a bank may not always be able to mobilize domestic liquidity and the necessary foreign exchange transactions in sufficient time to meet foreign currency funding requirements. These issues are particularly important for banks with positions in currencies for which the foreign exchange market is not highly liquid in all conditions. Banks should, therefore, have a measurement, monitoring and control system for liquidity positions in the major currency markets in which they are active. In addition to assessing their aggregate foreign currency liquidity needs and the acceptable mismatch in combination with their domestic currency commitments, banks should also undertake separate analysis of their strategies for each currency individually. When dealing in foreign currencies, a bank is exposed to the risk that a sudden change in foreign exchange rates or market liquidity, or both, could sharply widen the liquidity mismatches. These shifts in market sentiment might result, either from domestically generated factors or from contagion effects of developments in other countries. In either event, a bank may find that the size of its foreign

currency funding gap has increased. Moreover, foreign currency assets may be impaired, especially where borrowers have not hedged foreign currency risk adequately. The Asian crisis of the late 1990s demonstrated the importance for banks to closely manage their foreign currency liquidity position on a day-to-day basis. The particular issues to be addressed in managing foreign currency liquidity will depend on the nature of the bank's business. For some banks, the use of foreign currency deposits and short-term credit lines to fund domestic currency assets will be the main area of vulnerability, while for others, it may be the funding of foreign currency assets with domestic currency. As with overall liquidity risk management, foreign currency liquidity should be analyzed under various scenarios, including stressful conditions. Observations of the Study Based on Cash Flow Approach (Net Funding Requirements) From the year ending March 31, 2000, banks are required to disclose the maturity patterns of loans and advances, investments in securities, deposits and borrowings, and foreign currency assets and liabilities. The data since the year ending March 31, 2000 to March 31, 2007 has been used to conduct a Cash Flow Approach (short-term maturity gap) analysis of assets and liabilities for different maturity buckets. The analysis of net funding requirements involves the construction of a maturity ladder and the calculation of cumulative net excess or deficit of funds at selected maturity dates. This is called "Cash Flow Approach" to liquidity management. A maturity ladder of an 8 time bucket is used to compare SBI's future cash inflows to its future cash outflows. Evaluating whether a bank is sufficiently liquid depends in large measure on the behavior of cash flows under different scenarios, such as normal conditions (going concern scenario) or a bank specific crisis (the bank's liabilities cannot be rolled over or replaced and will have to pay higher at maturity) or general market crisis (liquidity affects all the banks or one or two markets). For evaluation of Cash Flow Approach, 1-14 days bucket, 15-28 days time bucket and 29-90 days time buckets have been taken as the relevant time frames for active liquidity management as it does not generally extend to more than a few weeks. Since the SLR/CRR maintenance period is 14 days, meaningful information is arrived at by a short time horizon which is stacked by many short periods (ranging up to 3 months by every week). There was a negative gap (cash inflow-cash outflow) in the 1-14 days bucket and 15-28 days time bucket in the year 2000, as shown in Table 1A with Rs. 90 cr and Rs. 1,475 cr respectively. Negative gap to cash outflow is 0.22% in 1-14 days time bucket and 41.7% in 15-28 days time bucket. In the 15-28 days time bucket, SBI exceeded 20% of cash outflows limitations. So, in the year 2000, SBI had to depend on medium-term and long-term assets or cash inflows for its liquidity position.

Table 1A (Click Here To View) In the year 2001, there was a positive gap in short-term liquidity, i.e., up to 3 months. Its short-term cash outflow was less than cash inflow which means that SBI maintained a sound liquidity position, as shown in Table 1A in the year 2001. As shown in Table 1B, SBI maintained its liquidity position and also showed a positive cumulative gap throughout its time bucket in the years 2002 and 2003. Its total cash outflow was less than total cash inflow. Thus, during this period its liquidity risk was negligible and liquidity was maintained. Table 1B (Click Here To View) In the year 2004 and 2005 Table 1C, SBI showed a positive gap in 1-14 days bucket, 15-28 days bucket, 29-3 months bucket. So, its short-term liquidity was maintained and during this period, SBI had a sound liquidity position. There was a negative gap in 3-6 months (Rs. 3,802 cr in 2004 and Rs. 14,892 cr in 2005). Also there was a negative gap in 6-12 months (Rs. 52,382 cr in 2004 and Rs. 6,653 cr in 2005). But at the end, i.e., in the 5 years and above it had a positive cumulative gap which shows that its medium-term liquidity risk could be maintained. Table 1C (Click Here To View) In the year 2006 and 2007 Table 1D there was a negative gap in 1-14 days bucket, (i.e., Rs. 13,057 cr in 2006 and Rs. 593 cr in 2007), 15-28 days bucket (Rs. 1,135 cr in 2006 and Rs. 72 cr in 2007). There was a negative gap in 29 days-3 months bucket with Rs. 6,527 cr only in 2007. Again there was a negative gap in 3-6 months, with Rs. 3,165 cr in 2006 and Rs. 2,437 cr in 2007. Percentage of negative gap to cash outflow was 16.58% in 1-14 days time bucket, 8.66% in 15-28 days time bucket, 11.60% in 3-6 months time bucket in the year 2006 respectively, which had not exceeded the prudential limit of 20%.