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BASEL III

BASEL III. A NEW PHASE OF LIQUIDITY MANAGEMENT FOR FINANCIAL INSTITUTIONS?. Kevin Wong, Director Client Insights & Solutions International & Institutional Banking. 23 February 2015. Background: the Basel III response to the GFC.

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BASEL III

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  1. BASEL III A NEW PHASE OF LIQUIDITY MANAGEMENT FOR FINANCIAL INSTITUTIONS? Kevin Wong, DirectorClient Insights & SolutionsInternational & Institutional Banking 23 February 2015

  2. Background: the Basel III response to the GFC In the view of banking regulators, the GFC exposed several key weaknesses in the global banking industry – capital, liquidity and leverage • Basel III is a complex, multi-faceted, multi-staged set of banking regulatory reforms • Global ‘base’ rules, but national differences • Milestones • 1 Jan 2013: Capital – quantity and quality • 1 Jan 2015: Liquidity Coverage Ratio (LCR) – short term liquidity • 1 Jan 2018: Net Stable Funding Ratio (NSFR) – longer term liquidity/’match funding’ • 1 Jan 2018: Leverage Ratio – on- and off-balance sheet leverage • Direct impact on banks; indirect impact on bank customers, counterparties and investors

  3. Liquidity Coverage Ratio (LCR) The new LCR framework took effect from 1 Jan 2015. The objective is to ensure that banks have sufficient, high quality liquid assets in an acute short-term liquidity stress scenario High Quality Liquid Assets (HQLA) Net cash outflows (30 days) ≥ 100% • Stress scenario is for a 30 day period • HQLA comprises essentially cash, RBA reserves and govt/semi-govt bonds in Australia • High quality but low yields • Net cash outflows represent highly prescriptive ‘run off’ assumptions across different funding liabilities of a bank • Framework applies to larger/more sophisticated banks/ADIs, but the practical scope seems broader

  4. Run-off assumptions - retail vs. wholesale funding In the eyes of banking regulators, retail deposits are ‘stickiest’ while wholesale financial institution deposits are considered the least ‘sticky’ • To illustrate – deposits with effective maturity of ≤30 days: • In other words, a bank has to hold: • $0.05-0.10 in cash/RBA reserves/govt bonds for a $1.00 Retail deposit vs. • $0.40 in HQLA for a $1.00 wholesale non-FI deposit vs. • $1.00 in HQLA for a $1.00 wholesale FI deposit 4-8x 2.5x

  5. So what are banks’ preferences under LCR? It’s worth thinking about this from a time perspective… … and from a client category perspective 0-30 days 31 days –up to 364 days 1 year+  • Retail/SME • Wholesale Operational – FI and non-FI • Wholesale – non-FI • Wholesale – FI • Banks are becoming more granular in viewing and differentiating client deposits • Segment prioritisation • Rates offered  • Term deposits of at least 31 days BUT: • Evergreen/rolling is better • Notice period is better • Longer term is better • 12 months+ is also a consideration as banks consider future regulatory reform on term/match funding • 6 months+ may provide additional bank benefit from a regulatory perspective vs <6 months? • Watch this space…  

  6. The decision tree on FI deposits Is remaining tenor ≤30 days? 0% Run-Off NO What is a “Financial Institution”? “… includes any institution engaged substantively in one or more of the following activities – banking; leasing; issuing credit cards; portfolio management (including asset management and funds management); management of securitisation schemes; equity and/or debt securities, futures and commodity trading and broking; custodial and safekeeping services; insurance (both general and life) and similar activities that are ancillary to the conduct of these activities. A financial institution includes any authorised NOHC or overseas equivalent” “For the avoidance of doubt, this definition includes money market corporations, finance companies, friendly societies and the trustees of superannuation/pension funds, public unit trusts/mutual funds and cash management trusts” YES Is deposit from a Financial Institution (FI)? YES Retail ‘look-through’ treatment – FI intermediary has no obligation/ability to act without retail clients’ instructions Are withdrawal /deposit decisions made by the underlying retail customer? YES NO [25%] Run-Off Is deposit on a transactional platform and required for company operations? Only that portion of the deposit proven to serve operational needs can qualify as stable YES NO YES 100% Run-Off 25% Run-Off

  7. Intermediated deposits Subject to strict criteria, APRA will recognise certain retail deposits on wholesale intermediary platforms as “retail” for purposes of the Basel III LCR framework • Extract re “intermediated deposits” from APRA banking prudential standard APS 210 – Liquidity:

  8. A new phase of liquidity management? Both clients’ and banks’ objectives can be better aligned with the appropriate cash management solutions Funding liability run-off requirements Liquidity needs BANK CUSTOMERS Term funding Yield benchmark Customer relationship and franchise Consistency of returns Full service bank Diversity of provider and counterparties Return on capital Overall banking needs

  9. 9 AUDIENCE QUESTIONS

  10. Audience question 1 Q. How do you prioritise the following objectives for cash management? (Rank from most to least important) • Liquidity • Yield • Consistency of yield • Diversity of provider

  11. Audience question 2 Q. What have you seen happen in rates offered by banks for your cash management/deposit needs over the past six months? Increased Decreased Steady

  12. Audience question 3 Q. What do you anticipate will happen to cash management/deposit rates offered by banks over 2015? Increase Decrease Steady

  13. Audience question 4 Q. For super fund members that specifically leave money within the Cash option, what do you believe they are primarily focused on? Capital preservation Liquidity Certainty of returns Maximising cash returns

  14. Audience question 5 Q. With a low rate environment persisting, what would you consider for enhancing cash returns? (Rank from most to least relevant) Longer dated term deposits More structured deposit products – e.g. notice period, rolling term deposits Include non-cash, liquid investments – e.g. bank paper Business model change – e.g. introduce member/intermediary platform

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