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Presentation from SWIFT Compliance Dy 2014 in Frankfurt
Citation preview
Intraday liquidity reporting Solutions from SWIFT to support compliance
with BCBS monitoring requirements
Compliance Forum Germany
Geertjan van Bochove, Manager Business Intelligence, EMEA
What is BCBS intraday liquidity about?
BCBS monitoring tools for intraday liquidity (2013) To enable banking supervisors to better monitor a bank's management of intraday liquidity
risk and its ability to meet payment and settlement obligations on a timely basis
• Detailed set of 7 monitoring tools
• Consider impact under 4 stress scenarios: own, counterparty, customer, market stress
• Report by systems, correspondent banks, currencies, branches and subsidiaries
Implementation • Internationally active banks, in all countries and for all currencies they operate in
• Report monthly to regulator, from 1st of January 2015
BCBS monitoring tools for intraday liquidity management was published in April 2013.
2008 financial crisis • Market turmoil that began in mid-2007 re-emphasised the importance of
liquidity to the functioning of financial markets and the banking sector
• September 2008, Basel Committee on Banking Supervision (BCBS)
published Principles for Sound Liquidity Risk Management and Supervision
Applicability Monitoring tools
All reporting banks 1. Daily maximum intraday liquidity usage
2. Available intraday liquidity at the start of the business day
3. Total payments
4. Time-specific obligations
Banks providing
correspondent
banking services
5. Value of payments made on behalf of correspondent
banking customers
6. Intraday credit lines extended to customers
Direct participants 7. Intraday throughput
BCBS monitoring tools for intraday liquidity management
As of January 2015
• Understand intraday exposure for your bank?
• Position of branches and subsidiaries?
• Produce report for BCBS?
How does this impact you?
Data sourcing
alternatives
BCBS | broad reporting requirements
BCBS
User
Self-clearing
RTGS reporting
Central Bank account
Nostro’s
> 20 accounts per entity
> 200 accounts per group
Reporting on customer credit
lines usage Group-wide
System A
Branch B
Request
Monthly Excel
E-banking
platforms
Intra-day liquidity usage (retrospective) 1-day’s of reporting messages mapped
* Balance of EUR denominated MT900 and MT910 received by group X from group Y (aggregated per 5 min interval)
Demo report
Sourcing the right data from the Swift network Liquidity messaging concept explained
You
Correspondent
Counterparty
End of day
balance (MT950)
Only 3% of cross-
border payments sent
from Germany are
confirmed
24% of domestic
payments are
confirmed
7
* Full year 2013, non-T2 flows, MT103 and MT202
Intra-day confirmations in Germany and Europe
15% of cross-border
payments received in
Germany are
confirmed
24% of cross-border
payments sent from
Europe are confirmed
15% of cross-border
payments received in
Europe are confirmed
USER
PROVIDER
USER
PROVIDER
20% of intra-
Europe payments
are confirmed
MT942 | Issues identified
Time-stamp of individual transactions missing
-300
-250
-200
-150
-100
-50
0
50
100
150
00:00
00:30
01:00
01:30
02:00
02:30
03:00
03:30
04:00
04:30
05:00
05:30
06:00
06:30
07:00
07:30
08:00
08:30
09:00
09:30
10:00
10:30
11:00
11:30
12:00
12:30
13:00
13:30
14:00
14:30
15:00
15:30
16:00
16:30
17:00
17:30
18:00
18:30
19:00
19:30
20:00
20:30
21:00
21:30
22:00
22:30
23:00
23:30
MT942 received at
5:00am | with non-
reported items
MT942 received at
5:00am | with non-
reported items MT942 received at
4:30am | all reported
through R-T messages
already
MT942 received at
4:30am | all reported
through R-T messages
already
MT942 received at
5:00am | with non-
reported items
MT942 received at
5:00am | with non-
reported items
MT942 statement:
- +25 (Coupon)
- +25 (cust pay)
- -25 (Tax)
- -25 (book trf)
Network complexity of intra-day reporting
DE HUB
(all BICs running
over the same
interface)
US entity
Other entities
running stand-
alone interface
USD
agent
CAD
agent
AUD
agent JPY
agent
RUB
agent
AUD
agent
JPY
agent
Client-
bank
Client-
bank
Client-
bank
User
Provider
BCBS monitoring tools- The pain points
Data availability
Understand intraday exposure across Nostro accounts for
all currencies
Reporting both globally and at the level of each legal entity
Vostros aggregated intraday credit lines usage
Resourcing to produce reports for BCBS
Short time line
Not a revenue generator
Duplication of efforts: centrally vs. Locally
Development needed at you institution
3) Reporting and analysis
- Normalize data
- Build BCBS reporting
- Build control check on data
coverage
2) Set-up technical infrastructure
- Collect data (FINInform)
- Route data
- Extract and parse relevant
information
- Safe store in database
Parsing
Database Database
Gateway /
Access
Reporting
Analysis
1) Source correct data from agents
- Analyze data gaps
- Define missing intra-day reporting
- Define business rules
- Go-out to correspondents
Data gap
analysis
Technical
set-up
Reporting
design
Regulatory reporting,
analytics,
management, etc.
Supporting the development of the
Intraday Liquidity reports
(2) Opening
balance
Statement
MT940/950
(3) Credit / Debit entries confirmations
Amount/ Date-time/ Currency
Correspondent BIC
MT900/910/ 942/ 103/202/ 545/ 547
(1) Closing
Balance
Statement
MT940/ 950
(8) Back/Forward
value
entries
(5) Balance
(7) Date/time message stamping
is different from value date?
Calculation
Indicate
discrepancy to
user through the
interactive
dashboards
(6) Matching
Discrepancy
between calculated
balance & MT950
BCBS
aggregated measures/
reports
Transactional reportsdetailed report per transaction +
transaction reference number
Report entries
& calculated balance
based on back value
items
(4) Identify duplicates
from 103/202/ 900/910
& reported again in 942 or
reported twice with 942
Specifications definition or
support to the
BCBS reports implementation
Specifications definition or
support to the
BCBS reports implementation
Intra-day liquidity reporting tool The scope
Liquidity reporting objectives:
Comply with the BCBS nostro reporting requirements
Provide a retrospective monitoring dashboard on cash positions
Enable the bank to do analytics on the data
Limit the investment and implementation time
We will not report to the regulator, this is the bank’s responsibility
The tool is currently not aimed at Real-Time monitoring
The tool does not include stress testing
13
User Nostro
14
Effective Intra-Day Liquidity Management =
quality data + business rules
Correspondent bank
Your institution
T +/- X
Messages can
be received on
the same, but
can also be
received a day
before
Statements
Some specific
flows will be
recorded only on
an end-of-day
statement,
without intra-day
advices
Difference in behavior Different correspondents and even accounts will have
different behavior in sending reporting flows M
T900
MT
910
MT
103
MT
202
MT
545
MT
547