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Classification | Public
The Letter of Credit Opportunity
John Biestman, Vice President | Senior Relationship Manager
November 2021
Classification | Public
LETTER OF CREDIT (LOC) OVERVIEW
PERFORMANCE GUARANTEE LOCs
PUBLIC FUNDS LOCs
BOND ISSUANCE CREDIT & LIQUIDITY LOCs
THE MECHANICS
Agenda
Classification | Public
OVERVIEW
• Address Counterparty Requirements• Examples include rating confirmation
requirements of swap and other counterparties
• Provide select liquidity, community lending, housing and other requirements involving your institution and your customers (e.g. captive and other forms of insurance)
PERFORMANCE GUARANTEE LOCs
Classification | Public
THE CONFIRMING LOC
Member issues its direct pay LOC that is confirmed by the FHLB Des Moines LOC
• FHLB Des Moines confirms member’s LOC and improves credit rating of transaction
• FHLB Des Moines LOC stands behind the member’s LOC
• FHLB Des Moines LOC is drawn on for member insolvency/ non-performance for Principal and Interest payments, as well as other transactional charges
PERFORMANCE GUARANTEE LOCs
Classification | Public
PERFORMANCE OBLIGATION LOC EXAMPLE #1
PERFORMANCE GUARANTEE LOCs
• Self-insured general liability program for a fleet operator
• First-dollar claims exposure retained, larger potential losses contracted out
• FHLB Des Moines confirms member’s LOC and according “Aaa/AA+” rating supported beneficiary’s guarantee requirements
• FHLB Des Moines LOC stands behind the member’s LOC
• Result: Lower premiums, stronger deposit and loan balances, relationship building
Classification | Public
PERFORMANCE OBLIGATION LOC EXAMPLE #2
• Member originated a construction loan
• Takeout ultimately via a Freddie Mac permanent loan
• Freddie Mac required a confirming LOC as security until rental rolls established and confirmed
• Structured as a one-year confirming LOC
PERFORMANCE GUARANTEE LOCs
Classification | Public
PERFORMANCE OBLIGATION LOC EXAMPLE #3
• Member’s customer purchasing crude oil contracts forward
• Customer counterparty requires securities or highly-rated LOC issuer
• Member issues direct pay LOC in favor of its customer’s counterparty
• FHLB Des Moines issues confirming LOC, effectively “crapping” the member LOC and providing the customer’s counterparty with an ultimate “AAA/AA+” performance guarantee
PERFORMANCE GUARANTEE LOCs
Classification | Public
“PUDs” are demand, NOW, MMA or time deposits controlled by a municipality or political subdivision
Examples: • School districts• Bridge and port authorities• Sanitation• Utility and fire districts• Any municipal entity that is authorized to hold exclusive use and control of funds
Often seasonal activity around tax and revenue dates
PUDs focus on:• Safety and soundness of depository• Maximizing yield
PUBLIC FUNDS LOCs
Classification | Public
TYPICAL COLLATERALIZATION ARRANGEMENTS FOR LOCAL PUBLIC UNIT DEPOSITS
• Above $250,000 FDIC insurance limit, Treasury, Agency and other high-quality securities are pledged as collateral for public unit deposits by a FHLB Des Moines depository member
• Pledged securities held by trustee or custodian, as required by the public unit
• Trustee or custodian provides frequent collateral reports to the public unit
• Securities market values, substitutions and maturity dates require constant monitoring –high administrative burden
• Should depository member default, public unit may exercise the right to pledged securities collateral
PUBLIC FUNDS LOCs
Classification | Public
BENEFITS OF FHLB DES MOINES AS A COLLATERALIZATION OPTION
• FHLB Des Moines is rated ‘AAA/AA+” and issues LOCs on behalf of our members, in favor of public units as an alternative collateral source in lieu of pledged securities
• FHLB Des Moines LOC enables our member to leverage less-liquid collateral that may already be pledged to FHLB Des Moines
• Relieves the administrative burden associated with: substituting collateral, call provisions, calculating mark-to-market value and adjusting collateral values as markets fluctuate (margin calls)
• Should a depository member default, a public unit can immediately draw on the FHLB Des Moines LOC
Customizable: Individual, Pooled, Fixed, Evergreen Finite
PUBLIC FUNDS LOCs
Classification | Public
THE FDIC ON DEPOSIT INSURANCE FOR ACCOUNTS HELD BY GOVERNMENT DEPOSITORS
“All time and savings deposits owned by a public unit and held by the public unit's official custodian in an insured depository institution within the State in which the public unit is located are added together and insured up to $250,000. Separately, all demand deposits owned by a public unit and held by the public unit's official custodian in an insured depository institution within the State in which the public unit is located are added together and insured up to $250,000.”
“Collateralization of Public Unit Deposits …
Depending on applicable state or federal law, public unit deposits may be secured by collateral or assets of the bank. In the event of the failure of the bank, the FDIC will honor the collateralization agreement if the agreement is valid and enforceable under applicable law. The FDIC does not guarantee, however, that the collateral will be sufficient to cover the amount of the uninsured funds. As such, although it does not increase the insurance coverage of the public unit deposits, collateralization provides an avenue of recovery in the unlikely event of the failure of an insured bank.”
PUBLIC FUNDS LOCs
Classification | Public
SUMMARY OF STATUTORY TREATMENT OF FHLB Des Moines LOCs FOR PUDs
PUBLIC FUNDS LOCs
State Public Deposit Statute FHLB LOC Accepted by Statute Credit Rating Requirement
Alaska Investment Policies and Procedures, Department of Treasury, “Collateralized State Deposits”
Yes
Hawaii Hawaii Revised Statutes Annotated 38-3 Yes
Idaho Idaho Code Annotated 57-128 Implied; has accepted LOC’s from FHLBDMIowa Iowa Annotated 12C.16 Yes. Accepts direct obligations of an instrumentality
of the U.S. (by case law interpreted to include FHLBank). Has accepted FHLB LOC’s.
Minnesota Minnesota Statutes Annotated 118A.03 Yes Minimum FHLB Public Debt of ‘AA’ from Moody’s or S&P
Missouri Missouri Revised Statutes 30.270 YesMontana Montana Code Annotated 17-6-103 YesNorth Dakota North Dakota Century Code 21-04-09 Yes Minimum Rating of ‘AA’ rating or
better from Moody’s or S&POregon Oregon Statutes 295-004 YesSouth Dakota South Dakota Codified Laws title 4,
Chapter 06A, 4-6A-1Yes Minimum Rating of ‘AA’ rating or
better from Moody’s or S&P
Utah Utah Code Annotated 51-7-18.1 Limited RequirementsWashington Revised Code of Washington Annotated
39.58.050Yes
Wyoming Wyoming Statutes Annotated 9-4-805.Deposit of state money in approved depositories; other acceptable security
Yes
Classification | Public
CASE ONE: THE FORGOTTEN SECURITY CALL
Challengeo Member currently using a callable security to collateralize a public unit deposit. The member receives
notification that the bond is going to be called at the next call date, which is in five days.
Optionso Pledge another security or purchase a replacement security.
− Member subsequently receives the proceeds from the called security and forgets to replace another security that is needed to fully collateralize the deposit. The security takes at least one day to settle.
OR
o Collateralize the deposit until a replacement security is pledged or purchased using an FHLB Des Moines LOC. The LOC can be written for any suitable amount and timeframe that the member selects. Also, consider replacing the entire securities pledging mechanism with an FHLB Des Moines LOC program.
PUBLIC FUNDS LOCs
Classification | Public
CASE TWO: DIMINISHING SECURITIES AVAILABILITY
Challengeo A member is experiencing strong loan growth and has been selling securities to fund the growth.
Unfortunately, a sizeable percentage of securities have been pledged to school districts in order to collateralize deposits.
Optionso Continue securities pledging program and suppress loan growth due to liquidity constraints.
OR
o Secure an FHLB Des Moines LOC to collateralize the deposits. Pledge the additional loans, if eligible, as collateral. Continue to fund loan growth.
PUBLIC FUNDS LOCs
Classification | Public
CASE THREE: DIMINISHING SECURITIES ELIGIBILITY
Challengeo A member’s investment portfolio has historically contained a high percentage of mortgage-backed
and callable Agency securities. Rates have dropped and many of these securities have been called. With MBS prepayments accelerating, the member would like to purchase municipal securities (which are not PUD-eligible for securing deposits in their operating area).
Optionso Refrain from purchasing municipal securities and continue to sub-optimally pledge other securities.
OR
o Shift to municipal security purchases and pursue investment objectives by deploying an FHLB Des Moines LOC to collateralize the deposit program at a negligible cost.
PUBLIC FUNDS LOCs
Classification | Public
CASE FOUR: STRATEGIC REVIEW OF LIQUIDITY AND MARGIN
Challengeo A member’s investment portfolio has historically contained a high percentage of mortgage-backed
and callable Agency securities. Rates have dropped and many of these securities have been called. With MBS prepayments accelerating, the member would like to purchase municipal securities (which are not PUD-eligible for securing deposits in their operating area).
Optionso Refrain from purchasing municipal securities and continue to sub-optimally pledge other securities.
OR
o Shift to municipal security purchases and pursue investment objectives by deploying an FHLB Des Moines LOC to collateralize the deposit program at a negligible cost.
PUBLIC FUNDS LOCs
Classification | Public
INCREMENTAL IMPACT OF LOC PROGRAM ON LIQUIDITY AND OPPORTUNITY INCOME
PUBLIC FUNDS LOCs
Classification | Public
DISAVANTAGES OF OTHER FORMS OF COLLATERALIZATION
PUBLIC FUNDS LOCs
Reciprocal Deposits:• Expensive• Considered brokered deposits• Capacity and settlement limitations not
coinciding with PUD cash flow• Operationally intensive• PUD faces overnight exposure
Pledged Securities: • Encumbers highly liquid assets• Capacity limited to available collateral• Securities release is cumbersome with
calls and maturities of deposits
Surety Bonds:• More expensive than LOCs• Callable by underwriter• Monthly reporting required on daily
deposits• Capacity limitations
Classification | Public
ADVANTAGES OF FHLB DES MOINES LOCs AS A PLEDGING ALTERNATIVE
• Minimal cost to the member• No cost to the public unit• Operationally efficient for the member as well as the public unit:
o Does not encumber securities portfolioo Helps redirect capital from low-yielding investments to higher-yielding assets
Direct and straightforward obligation. o Compared with pledging securities, relieves the administrative burden associated with: substituting
collateral, call provisions, calculating mark-to-market value and adjusting collateral values as markets fluctuate (margin calls)
PUBLIC FUNDS LOCs
Classification | Public
What Types of Debt Issuances Can FHLB Des Moines Enhance?
FHLB Des Moines has historically issued our Letters of Credit on behalf of our member institutions to enhance the financing of residential or community lending-related projects.
Enhancements typically cover: • Non-housing, taxable issues• Housing, taxable issues• Housing, non-taxable issues
BOND ISSUANCE CREDIT AND LIQUIDITY ENHANCEMENT
Classification | Public
How Confirming LOCs Are Structured for Debt Enhancement
LOC from the member institution with a confirming LOC issued by FHLB Des Moines
• FHLB Des Moines credit enhanced bonds are in high demand
• Enables access to the private placement, public and/or variable-rate demand (“low floaters”) market
• Capital markets look to the credit rating of the Confirming LOC provider (the FHLBankrating, in this case is “Aaa/AA+” for FHLB Des Moines)
• Interest and principal can be paid from a pledge of specific and definable revenues
BOND ISSUANCE CREDIT AND LIQUIDITY ENHANCEMENT
Classification | Public
Example of Confirming LOC Flows on an Enhanced Bond
BOND ISSUANCE CREDIT AND LIQUIDITY ENHANCEMENT
Classification | Public
Why use FHLB Des Moines Confirming LOCs vs. Lend Directly?
• Provides opportunity for FHLB Des Moines members to issue LOCs (off-balance sheet) that could they could not issue directly their own – Fee Income
• Enables community financial institutions to offer highest rated credit to their customers
• Offers customers a unique and timely structural alternative vs. commodity loan pricing
• Retains and grows local business relationships
• Can provide lower interest rate for projects
• Low cost
BOND ISSUANCE CREDIT AND LIQUIDITY ENHANCEMENT
Classification | Public
Advantages of LOC Transactions vs. Direct Funded Loans*
Considerations:1. Members are required to allocate existing or additional collateral at FHLB Des Moines when
providing confirmed LOCs. Collateral amounts will vary by member and the face amount of the LOC. FHLB Des Moines activity stock purchase required (10 bps).
2. Will the FHLB Des Moines member assign an internal charge for use of the credit and collateral allocation in return for the higher capital-adjusted ROE of a contingent LOC transaction vs a direct funded loan?
* Institutions < $50 billion in assets, per Basel III.
BOND ISSUANCE CREDIT AND LIQUIDITY ENHANCEMENT
Advantages Direct Loan LOC TransactionEquity Required 10.0% 5.0%
Cash Required 100% 0%
Liquidity Required 100% 0%
Fee Income No Yes
Classification | Public
Example ROE Comparisons: Direct Loan vs. LOC Transaction*
* Assumes transaction size of $10,000,000. Ignores any member institution internal overhead charges that may differ between direct loan and LOC costs.
BOND ISSUANCE CREDIT AND LIQUIDITY ENHANCEMENT
Assumptions Direct Loan LOC TransactionSpread 2.00% 1.34%
Spread Income $200,000 $134,000
Equity Requirement (10%-5%) $1,000,000 $500,000
ROE 20.0% 26.8%
After Tax ROE (25% Rate) 15.0% 20.1%
Economics to Borrower Direct Loan LOC TransactionSpread 2.00% 1.34%
Bond Rate (appx. Fed Funds) 0.50% 0.50%
FHLB Confirmation N/A 0.115%
Remarketing Fee N/A 0.125%
Trustee Fee N/A .0250%
All-In Rate 3.00% 1.98%
Closing Costs Direct Loan LOC TransactionLegal $20,000 $50,000
Underwriter N/A $62,500
Bank Fee $100,000 $100,000
Other $20,000 $35,000
All-In Rate $140,000 $247,500
Classification | Public
FHLB Des Moines LOC REQUIREMENTS
Collateral RequirementsLOCs are subject to the same collateral requirements as Bank advances.
Activity Stock RequirementsCurrently, members are required to purchase Activity Stock that is equivalent to 10 bps of the notional LOC amount.
Application RequirementsRequests for an LOC for Public Unit Deposit purposes (e.g., state and county treasurers, school districts, cities and townships) or for Non-Public Unit Deposit purposes (e.g., to facilitate residential housing finance, community lending or for asset/liability management) require the submission of an LOC application. Completed applications should be emailed to [email protected] by 3:00 PM (CT) for same day processing. You may also fax the application to 515.699.1250.
PUBLIC FUNDS LOCs
Classification | Public
FHLB Des Moines LOC PRICING
Standard Billing for LOC
Upon issuance of an LOC, the Bank charges a non-refundable fee which is calculated using the following formula:
{Face Amount * FEE * (Term in Days/360)}
The FEE used in the above formula is based upon the Face Amount of the Standby LOC. The current fee is 11.5 basis points.
Minimum charge for any LOC is $250.
PUBLIC FUNDS LOCs
Classification | Public
“When trust was in the room, whatever room that was – the family room, the schoolroom, the coach’s room, the office room, the government room or the military room – good things happened. When trust was not in the room, good things did not happen. Everything else is details.”
- George P. Shultz
Classification | Public
STAY IN TOUCH WITH US
Headquarters909 Locust StreetDes Moines, IA 50309
Western Office901 5th AvenueSuite 3800Seattle, WA 98164
Our Phone(800) 544-3452
Websitewww.fhlbdm.com