Blog
PRA regulation changes in PS9/24
The near-final PRA Rulebook PS9/24 published on 12 September 2024 includes substantial changes in credit risk regulation compared to the Consultation Paper CP16/22. While these amendments
Find out moreThe financial health of public institutions has been in the spotlight more prominently since the financial crisis. A healthy institution can meet its financial obligations in both the short and long term. This is reflected in good ratio developments, such as solvency, Loan-to-Value (LtV) and the Debt Service Coverage Ratio (DSCR). However, having healthy ratios does not automatically mean that you will have sufficient funds available quickly in case of incidental financial setbacks.
Financial setbacks can occur due to, for example, higher construction costs, inability to invoice due to IT problems, or production falling behind due to staff shortages. Savings, also called liquidity buffer, give you some time in such situations to take measures to resolve the incidents. If these temporary liquidity shortfalls cannot be compensated in time, this may translate into structural problems, deterioration of cash flow ratios, higher risk premiums on loans and, in the long term, perhaps even bankruptcy. A buffer therefore seems logical, but the design of a liquidity buffer is not that easy. After all, how is the amount and form of the buffer determined?
Maintaining a liquidity buffer requires reserving available funds, but may be seen as unnecessary and socially undesirable. After all, there seems to be enough liquidity available to compensate setbacks and the public money could be better spent on social purposes. In practice, however, it happens that additional liquidity is not routinely or immediately available, or it is difficult to release funds quickly, or the additional liquidity is insufficient to temporarily compensate deficits.
Banks are also less likely to provide money to cover shortfalls during difficult times. In addition, the application process at a bank can take a relatively long time. To ensure the financial continuity of an institution in both good and bad times, many healthcare and educational institutions therefore feel the need to keep extra liquidity on hand, often encouraged by the accountant or the supervisory board. Next to that, bodies such as the WFZ (Guarantee Fund for the Health Care Sector), the Education Inspectorate and banks also stress the importance of a healthy liquidity buffer.
An important consideration is that the comfort of a liquidity buffer in the event of financial setbacks is only temporary. After all, you can only spend the money set aside once. If liquidity shortages continue and thus become structural in nature, you will have to look at long-term measures. However, using the liquidity buffer for structural deficits can give you more time to take a considered decision on the measures to be taken.
An unequivocal answer to this question cannot be given. The starting points used differ per sector and per institution. In educational institutions, for example, we often see the current ratio as a yardstick for the buffer to be maintained. The current ratio indicates the relationship between the current assets and the current liabilities. The Education Inspectorate uses a current ratio of at least 0.5 for institutions in higher education and intermediate vocational education, and at least 0.75 for institutions in primary education, as a signaling value. However, many administrators and supervisory boards are comfortable with a higher standard and aim for a minimum ratio of 1.0 or higher.
An advantage of this methodology is that the current ratio does not yet take into account any room under the current account facility. This means that any current account facility can serve as an extra buffer in difficult times. A disadvantage is that the current ratio is generally a snapshot of the end of the year; no account is taken of intra-year developments. In case of an institution with volatile cash flows, guiding buffers by means of the current ratio can also lead to a yearly varying available buffer.
An alternative is to keep the amount of the liquidity buffer constant by steering towards an absolute norm. The WFZ, for example, advises healthcare institutions to use twice their turnover per month as the standard, but states that this is not a universal, objective standard. Zanders also sees many institutions using a standard of twice the monthly salary or 1.5 months' turnover. One point to note is that these standards are often quite high.
Our general advice is to gear the amount of the buffer to the liquidity development in both the short and long term, the risks and factors that play a role in your sector and in your institution. In addition, we recommend that the development of your long-term budget in the event of negative developments, also referred to as scenario analyses, be included in the consideration. Comfort can also play an important role. After all, it is up to you to determine which liquidity buffer is most appropriate and offers most comfort in daily operations.
Decisions must be made not only about the amount, but also about how to build up the liquidity buffer. Banks often offer the option of maintaining a liquidity buffer in the form of a current account facility, where the borrower pays commitment fees on the unused proportion and is charged a variable interest rate plus mark-up on the used portion. Generally, the amount of the current account is tailored to the institution's liquidity forecasts.
When deploying the current-account credit, it is important to determine whether it is committed or uncommitted. With an uncommitted overdraft, the bank can unilaterally cancel the facility daily - this is an availability risk. With a committed facility, there is the 'certainty' that the bank may not withdraw the facility during the agreed term. Also for this service, a commitment fee must be paid on the unused portion and the bank may ask for a higher mark-up during bad years when using the current account. In addition, there may be contractual terms that still allow the bank to unilaterally cancel the unused portion.
"An important consideration is that the comfort of a liquidity buffer in the event of financial setbacks is only temporary. After all, you can only spend the money set aside once."
From a risk perspective, it could therefore be argued that credit balances are safer than current account facilities. After all, this money cannot be cancelled unilaterally and there is no commitment fee on the unused portion or interest charges on the used portion. However, due to the low interest rates in recent years, the savings interest rate on credit balances has fallen to such a low level that it is currently even negative. For some banks this means that interest is no longer received on positive balances, but that from a certain size of credit balance onward, interest may have to be paid, also called negative interest. As a result, financing must then also be attracted in order to maintain the liquidity buffer, so there are double costs. In this case you not only pay interest on the credit balance, but also the regular financing costs.
Some institutions see their investment portfolio as an emergency pool they can use in difficult times. The advantage of invested money is that you do not suffer from negative interest rates or commitment fees. You also have a monthly stream of investment income. However, not every institution is allowed to invest money due to laws and regulations. Furthermore, you have to deal with counterparty risk, price risk in case of interim sales, and risk of negative returns. Moreover, the question is whether you can liquidate your investments fast enough to make payments.
The above options provide institutions with the room to have additional funds available during financially challenging times. However, the question remains as to which is the best option. Each option has advantages and disadvantages, and to make the choice even more difficult, a combination of the above options could also be a good solution for you.
Many institutions see the need to maintain a liquidity buffer either from a risk perspective, because of regulatory requirements, or for having comfort in operational execution. However, there is no simple answer to what the optimum level of a liquidity buffer is and how exactly it should be built. Each institution has its own risks and factors that must be taken into account. Setting up a liquidity buffer therefore requires a thorough analysis of cash flow development in the short and long term, key figures, costs, risks and options available from banks while adhering to legislation and regulations. In short, setting up a liquidity buffer is and remains custom work!
The near-final PRA Rulebook PS9/24 published on 12 September 2024 includes substantial changes in credit risk regulation compared to the Consultation Paper CP16/22. While these amendments
Find out moreThe ECB Banking Supervision has identified deficiencies in effective risk data aggregation and risk reporting (RDARR) as a key vulnerability in its planning of supervisory priorities for the
Find out moreRecently, Zanders' own Sander de Vries (Director and Head of Zanders’ Financial Risk Management Advisory Practice) and Nick Gage (Senior VP: FX Solutions at Kyriba) hosted a webinar. During
Find out moreThe Right Payment Orchestration Strategy: A Critical Factor for Success The digitalization and globalization of payment infrastructures have significantly impacted businesses in
Find out moreIn our previous article 'Navigating the Financial Complexity of Carve-Outs: The Treasury Transformation Challenge and Zanders’ Expert Solution' we outlined that in a carve-out, the TOM for
Find out moreIn today's dynamic economic landscape, optimizing portfolio composition to fortify against challenges such as inflation, slower growth, and geopolitical tensions is ever more paramount. These
Find out moreEffective liquidity management is essential for businesses of all sizes, yet achieving it is often challenging. Many organizations face difficulties due to fragmented data, inconsistent
Find out moreExploring S/4HANA Functionalities The roundtable session started off with the presentation of SAP on some of the new S/4HANA functionalities. New functionalities in the areas of
Find out moreAccurately attributing changes in counterparty credit exposures is essential for understanding risk profiles and making informed decisions. However, traditional approaches for exposure
Find out moreHowever, CCR remains an essential element in banking risk management, particularly as it converges with valuation adjustments. These changes reflect growing regulatory expectations, which were
Find out moreThe timelines for the entire exercise have been extended to accommodate the changes in scope: Launch of exercise (macro scenarios)Second half of January 2025First submission of results to
Find out moreWithin the field of financial risk management, professionals strive to develop models to tackle the complexities in the financial domain. However, due to the ever-changing nature of financial
Find out moreAddressing biodiversity (loss) is not only relevant from an impact perspective; it is also quickly becoming a necessity for financial institutions to safeguard their portfolios against
Find out moreSAP highlighted their public vs. private cloud offerings, RISE and GROW products, new AI chatbot applications, and their SAP Analytics Cloud solution. In addition to SAP's insights, several
Find out moreSAP In-House Cash (IHC) has enabled corporates to centralize cash, streamline payment processes, and recording of intercompany positions via the deployment of an internal bank. S/4 HANA
Find out moreHistorically, SAP faced limitations in this area, but recent innovations have addressed these challenges. This article explores how the XML framework within SAP’s Advanced Payment Management
Find out moreDespite the several global delays to FRTB go-live, many banks are still struggling to be prepared for the implementation of profit and loss attribution (PLA) and the risk factor eligibility
Find out moreIn a world of persistent market and economic volatility, the Corporate Treasury function is increasingly taking on a more strategic role in navigating the uncertainties and driving corporate
Find out moreSecurity in payments is a priority that no corporation can afford to overlook. But how can bank connectivity be designed to be secure, seamless, and cost-effective? What role do local
Find out moreIn brief Despite an upturn in the economic outlook, uncertainty remains ingrained into business operations today. As a result, most corporate treasuries are
Find out moreIn a continued effort to ensure we offer our customers the very best in knowledge and skills, Zanders has acquired Fintegral.
In a continued effort to ensure we offer our customers the very best in knowledge and skills, Zanders has acquired RiskQuest.
In a continued effort to ensure we offer our customers the very best in knowledge and skills, Zanders has acquired Optimum Prime.
You need to load content from reCAPTCHA to submit the form. Please note that doing so will share data with third-party providers.
More Information