Adam Smith Awards 2020: three award-winning clients
Treasury Today’s Adam Smith Awards are globally recognized as the industry benchmark for best practice and exceptional solutions in treasury.
This year, the panel of judges again selected the very best solutions that demonstrate exceptional best practice and innovation in the corporate treasury arena and awarded three Zanders client as category winners.
Kongsberg Automotive, Severn Trent and BAT have distinguished themselves with ground-breaking strong solutions to deal with their treasury challenges. We proudly present you these award-winning clients.
Kongsberg Automotive: winner ‘Harnessing the Power of Technology’
In 2019, Kongsberg Automotive Group AG received an Adam Smith Award for the ‘Best FinTech Solution’. This year, the worldwide supplier in the global vehicle industry won another award, in the ‘Harnessing the power of technology’ category. Two years ago, the company started to successfully transform its treasury function. Kongsberg’s treasury overhaul of centralizing and automating using BELLIN’s tm5 treasury management system (TMS) and Zanders intercompany rating and pricing tool, as well as a comprehensive process optimization, appeared to be is a shining example of a best practice approach, according to all parties involved.
Group Treasurer Abraham Geldenhuys: “A global treasury transformation is a journey that comes with significant change and various challenges but lots of excitement and opportunity! We started our journey with an ambitious vision. From Vision to strategic road map, detail ‘as-is’ analysis, understanding and documenting our functional and non-functional requirements, blueprint, implementation plan and a critical change management strategy. We partnered with Zanders and Bellin, and both stepped up to the plate during this intense and high-paced transformation. It has been, and still is, a pleasure to collaborate with these two class outfits with real depth in their ranks. Thank you both!”
Severn Trent: winner ‘Best Risk Management Solution’
Severn Trent Group is a listed UK water company, is exposed to interest and inflation risk originating from its core business, the regulatory framework, the debt portfolio, future debt planning and an inflation linked dividend policy. Given the complexity of the origination of these interest rate and inflation risks and their correlation, a more integrated and more quantitative Financial Risk Management (FRM) approach was required.
Zanders supported Severn Trent to succeed in adopting an integrated, strategic financial risk management framework to manage its primary financial risks. John Jackson, Group Treasurer of Severn Trent Plc, noted on the added value of the project and collaboration: “The purpose-built risk management tool has given us the ability to provide leading edge analysis to support financing decisions in the future. We were conscious that we were breaking new ground with this project, so having a partner we could trust to deliver was paramount. Zanders’ detailed and collaborative approach helped things run smoothly and any issues were quickly analysed and resolved.”
BAT: winner ‘Best Fintech solution’
As a part of a larger IHC/POBO/ROBO/Bank statement implementation project, BAT identified many business partners that had to be updated with new settlement instructions. The multinational therefore wanted to create and assign standard settlement instructions (SSI) in SAP, at business partner level for specific product types in an accurate, timely and auditable manner. As a solution, BAT automated the creation and assignment of SSI’s for its business partners in SAP using custom robotic process automation tools, leveraging on the SAP Gui scripting API.
Diana Macarascu, Head of Treasury Operations: “Usually, corporate treasures are quite conservative and to some extent risk-adverse people. It is not because of fear but because we want to do right by the company, to have it protected to the best of our abilities and we so like a controlled environment. Yet, as the time passes by, with all the new FinTech solutions available, everyone is evolving, it adapts to changes and progress, and in this sense treasury is no exception, as an operation in itself.
Looking back to what we have implemented through our project, it was not an easy feature and due to the time constrains it was adamant that we needed to look for a faster way to have it implemented. Through the partnership with the Zanders team, which was not only supporting us with development and changes in the ERP system itself, but as well on building the RPA, we have managed to deliver our project successfully, on time.
I need to admit that the RPA project in itself not only supported our project but equally meant an eye opener for myself at least, as it taught me an important lesson – the usage of RPA is only limited by our imagination.”
Once again, we want to congratulate these three winners and all other winner of the Adam Smith awards. For more information on the successful projects mentioned in this article, please contact Evaldas Balkys or Mark van Ommen.
Regional optimization in times of corona
Treasury Today’s Adam Smith Awards are globally recognized as the industry benchmark for best practice and exceptional solutions in treasury.
Just as growing companies plan to expand their operations internationally, corporate treasurers seek to identify new opportunities and take on challenges. The two seem to go hand in hand, as new challenges and difficulties materialize around every corner. Certainly the most daunting challenge that the global economy has been presented with recently is the COVID-19 outbreak. The recent outbreak represents a global health emergency and the biggest challenge the global economy has faced in over a decade. The fact that very few saw it coming highlights the shortcomings companies, even successful ones, can face.
In previous articles on Treasury optimization in Asia, we focused on the Treasury and Risk Maturity model, the three optimization phases and how to achieve local optimization for corporate treasuries in the foundation stage in Asia before the contagion had occurred. In this article, we continue to explore Asia, but also look at corporate treasuries (in the developing stage) seeking regional optimization and how regional treasury centers (RTC) can offer a solution as the coronavirus impacts the global economy.
According to an article in the Financial Times , based on data made available by the UN trade and development body (Unctad), Asian economies will grow to be larger than the rest of the world economies combined by 2020. As such, corporate treasurers should actively seek to mitigate risks and seize opportunities to improve their treasury operations in Asia where, as the impact of the contagion has underlined, the economies in the region are well connected.
Potential challenges of international operations range from:
- Regulatory requirements.
- Restricted countries.
- Access to liquidity markets.
- Local bank relationships.
If not properly addressed, these challenges can have financial consequences that will negatively impact the business. Therefore, to manage a company’s international operations effectively from a treasury perspective, one should decide which approach is best suited to managing operations within the region. This needs to be balanced with maintaining the agility to proactively manage unexpected global disruptions, such as the many consequences of the current pandemic.
For large multinational corporations (MNCs), which see Asia becoming increasingly important for their global trade, and Asian firms that have expanded well beyond their home market, both should seek to optimize operational efficiency, mitigate risks through concentrating activities and optimize capital through centralized liquidity management by setting up a regional treasury center (RTC). The challenge is to do that and still remain agile.
Considerations when setting up an RTC in Asia
MNCs have traditionally operated Shared Service Centres (SSC) in Asia because markets in the region were perceived as attractive locations for such ventures. As the Asian economy continues to grow, both global MNCs and Asian companies view the region as top of the list for establishing or expanding strategic RTCs.
According to a 2015 report by Reuters , about half the foreign or Chinese companies based in Hong Kong have set up regional centers that carry out treasury operations. In excess 12,000 European and US companies have set up an RTC in Singapore. With a diverse marketplace, regulatory conditions, market infrastructure and practices, business conventions, cultures, languages and currencies that differ across markets, a number of these traditional business issues must still be considered when entertaining the idea of setting up an RTC in Asia.
Added to that, now as the pandemic unfolds, we could see a restructuring of operations to move closer to the end users. This would require more regionalized centers, increasing the need for digitization and treasury technology to support the regional operations. This would increase agility, but companies still need to allow for a globalized approach, supported by a treasury management system (TMS) that provides global visibility on a regional basis.
A few key enablers can be identified for setting up an RTC, ranging from the introduction and implementation of (treasury) technology, policies and cash pooling, to bank account structures supported by banking tools and a TMS. Changing the treasury framework and reporting structures can also be beneficial.
Long-term view
If a treasury department is to support the organization in its quest for continuous future growth, it needs to adopt a corresponding view. This means it cannot treat the launch of an international subsidiary as a singular event. Future expansion and consistent growth are key elements in the creation of a sustainable perspective, with policies and structures that are scalable and can be easily aligned to an RTC’s operations as the company continues to grow. The organization must, therefore, adopt a long-term view.
That said, it is also important to remember that a long-term view is constantly subject to the set of circumstances in which the company finds itself. In other words, it will need to be re-visited and to evolve over time as the organization grows and changes.
Fast-tracking the process of digitizing the treasury organization can be a benefit here, as it will allow the treasurer to not only react but, in some cases, even proactively adjust course to mitigate the impact of disruptions on their organizations.
Operating within Asia requires treasurers to navigate an ever-changing sea of regulatory requirements, driven by unmatched economic growth. A sound long-term view and approach are vital when considering an RTC.
Strategy
With treasury’s role becoming more strategic, treasurers are frequently called on to provide sound international strategy, navigate local policies specific to situation and regulation, manage technological advancements and maintain a long-term view. As the world enters uncharted territory, regulatory changes might become even more prevalent, as governmental responses to the outbreak may require businesses to maintain certain levels of inventory and production quotas, for example.
It is important that the needs and objectives are correctly addressed from treasury’s perspective, and a seat at the executive table is therefore paramount when establishing regional objectives and policies. What is more, this should interlink with the objectives of the corporation’s TMS in its home country. From our experience, we know that companies encounter issues regarding centralization, governance, bank relations and FX policies, among others.
The extent of centralization is highly important for the overall strategy. The level of centralization that suits an organization can be driven by trade-offs when it comes to local banking and regulations, responsibilities and regional autonomy. Ideally, one consolidates the treasury function under a global treasurer and works from an operating model and infrastructure that aligns the diverse corporate activities. This assures that local treasury groups are able to respond quickly in a volatile market and uphold their reporting capabilities.
These corporate activities can be split into:
- Strategy – determine funding, growth and business model strategy.
- Scope – identify and allocate functions and operations.
- Processes – design operational, tactical or strategic processes.
Depending on the level of treasury maturity, this may not always be feasible. Some companies’ treasury departments have become so mature and efficient that they are considering taking it a step further, closing regional RTCs and further centralizing to a single treasury center. Depending on the level of maturity, complexity (compliance, regulations and local banking), tax, funding requirements and achieved levels of efficiency, an RTC may still be a viable option if an organization has not yet reached that level of maturity. But once again, the current pandemic may have an impact here. As the world takes on the coronavirus, chosen strategies may need to be revisited. It may have even become a more viable option to decentralize from a global treasury center to multiple regional treasury centres to reach the required levels of agility.
Governance and controls within a treasury department must be reinforced during global expansion into developing regions. Given the many financial instruments and accounts that the department has access to, measures to counter fraud and mismanagement must be put in place. This requires a thorough examination of current policies and processes for the core responsibilities, followed by comprehensive testing to verify that they apply properly to realistic situations.
Different regions may have alternative requirements for establishing bank relationships, making the opening and structuring of bank accounts a challenging task. The strategic outset of the company in terms of bank relationships should be closely adhered to when managing these relations. The best course of action in such cases is often to work with someone who has experience in these regions and attribute a specific professional and dedicated staff to manage the entire process.
When working with various currency markets within an organization, it is important to consider the different regulatory requirements that may apply per country. It is possible to draw up a single global FX policy for the entire company that can then be modified to meet region-specific needs. This approach will keep priorities aligned with the company’s central view while also leaving flexibility to help control region-specific situations and support further decentralization, if required. Such cases include dealing with cash sweeps, cross-border payment flows, handling inter-company payments and repatriation of profits. Developing a global policy may prove difficult and considering a risk management framework as the basis of the treasury department’s policy may help in providing clarity in the decision-making process.
Technology and infrastructure
Technological considerations become more important as the assumptions held in the past are now challenged by the contagion. Structural changes become inevitable. International expansion increases the need for reliable reporting, sending and receiving messages and risk management. During the expansion phase, it generally becomes apparent that an enterprise resource planning (ERP) system or a TMS offers greater adequacy than the use of spreadsheet reporting. What is required is always dependent on the RTC’s final scope.
Although powerful, spreadsheet reporting often lacks satisfactory terms of control, validation and interconnectivity of information. All these items are essential for international business. Having a unified database, automated processes, integration, risk avoidance and enhanced management reporting make a strong case for considering technological upgrades. An RTC country’s infrastructure should be sufficiently developed to offer state of the art technological instruments to support the treasury center’s operations.
If we should see a counter movement from globalization towards more regionalization, corporate treasury needs to ensure cash visibility. The use of a TMS will become even more important to improve visibility on cash flows, FX exposures, liquidity and funding across the increased number of regional centers. Through a single TMS, the organization has access to aggregated data at a company-wide level.
Location selection
When selecting an RTC location, the aim of which is to centralize activities in a business-friendly environment, the following criteria should be considered; infrastructure and technology, end-user proximity, availability of general banking services, a large labor pool and relevant experts. In addition, it should also be in a location that reduces friction costs, has open FX-conversion supporting any in-country, cross-border funding requirements and offers access to liquidity markets.
Models and structures have been developed in response to the complexity of treasury organizations. They reveal the extent of functions implicated in the real international business environment, where MNCs are required to carry out extensive studies to ensure their treasury department operates efficiently. The level of maturity, taxes, centralization and regulations will dictate the best treasury center model to use.
Our experience shows that the following criteria should be considered and should serve as a checklist, when guiding your organization through this process:
Throughout the region, many new contenders have joined the race to become the next treasury center hotspot. The familiar names Singapore and Hong Kong still reign as treasury center location champions, but they are feeling the heat with competition now coming from countries such as Malaysia, Philippines, Thailand and Vietnam.
So, what next?
As the COVID-19 outbreak challenges many assumptions held in the past, structural changes are inevitable as we see the impact of the virus on the global economy. In the past, Asian companies have demonstrated dynamism, speed and agility as they not only operate in fast-growing and highly dynamic markets but also need to respond to rapidly evolving customer requirements and digital disruptions. They come well equipped to weather the current storm supported by early signs of successful containment of the virus leaving them a step ahead of the rest of the world. This may provide treasurers in the region an opportunity to start fortifying and upgrading their operations to become more agile.
In our experience, determining a single best practice approach or a one size fits all RTC for all corporations is an impossible task. Many of our projects confirm how unique corporations are in their processes and operations. The same goes for selecting a location for and the setting up of a regional treasury center as opposed to an RTC to cover the EU and its Single Euro Payment Area (SEPA), particularly in a region as diverse and intricate as Asia. Setting up an RTC within Asia necessitates a structural approach that is backed by management.
Ultimately, international expansion is a multifaceted undertaking and many of these facets are highly dependent on the individual situation. The key considerations addressed in this article are intended to serve as a guideline on where to start and how to approach setting up an RTC in Asia. If doubts persist, enlisting an experienced party to assist on the complexity of such projects is always an option. Zanders can help corporates in their search for the ideal location using our structured 7-step approach, see below, which is modified to their particular situation. This structured approach is especially helpful in these uncertain times.
Local optimization
Treasury Today’s Adam Smith Awards are globally recognized as the industry benchmark for best practice and exceptional solutions in treasury.
In our first article on treasury optimization in Asia, we introduced three different levels of optimization. These levels form the foundation for this series and will be highlighted and examined in greater detail. This will help you understand and identify your organization’s corporate treasury maturity level and the potential steps it should take for further optimization. In this second article, we explore the local optimization opportunities and the challenges that may be encountered when managing treasury in Asia.
In the previous article on treasury optimization, we also identified the foundation, developing, established, enhancing and optimized stages and – in some cases – a transcending stage based on corporate treasuries’ level of expertise and business integration. Using the Treasury and Risk Maturity model can help to plot your organization’s treasury along the model’s treasury maturity line. Understanding at what stage your treasury currently is at and what stage to strive for is an important first step.
Foundational maturity
Managing treasury in Asia poses many challenges and problems to European multinationals (MNCs) expanding outside their home countries. The main challenges of managing treasury in Asia include regulatory differences, the nature of financial markets, (cultural) diversities, distance and time zone, and levels of expertise and alignment.
If group treasury has limited visibility of its Asian treasury operations, and believes it’s ‘locally managed’, our experience shows there usually is much left to optimize as local CFOs and teams typically have KPIs focusing on revenue and EBIT. As with any problem, the first step to solving it is to acknowledge its presence. Once the problem has been recognized, the next step is to determine the cost of either not solving it or of allocating resources to solve it.
The same cost drivers apply in Asia as in mature markets, with the main difference being that for the same amount, balances or number of transactions, the costs are typically significantly higher. This is due to interest rates, FX spreads, fees and more being much higher. Even though it can be difficult to know in greater detail how much the value loss is, just making a rough estimate of the cost of unmanaged cash balance usually gives a good enough indication that action needs to be taken.
Example: Cost of Cash in China
China is typically one of the bigger Asian markets for many European MNCs. Regulations can provide obstacles in repatriating cash. Currently, Chinese regulations are quite supportive of outgoing cross-border loans and cash pooling. There are several different structures that can be put in place. The choice of which structure to use must be analyzed and decided on a case by case basis, as each comes with its own set of pros and cons.
In China, interest paid on a bank account is by regulation maximized at 0.35%. By getting cash out of China, swapping to EUR and reducing group borrowings, significant earnings can be achieved.
As idle cash is typically a longer-term problem, it is fair to use a medium-term average EUR funding cost. Even for a well rated company, this can be 1%. Furthermore, it is assumed that value of reduction of credit risk on banks in China is worth 1%.
Swapping CNY to EUR 3%
Repaying Group debt 1.0%
Reduction of China bank risk 1.0%
Less interest in China 0.35%
Total cost of Cash in China 4.65%
Even with a moderate amount of business in China, it is easy to have cash balances of CNY 100 M. Implementing such a cash pool could quickly add value within a month or two.
Is your cash really trapped?
Many European treasurers realize they have problems with idle cash balances in Asia and initially try to solve it remotely. Some visit Asia, agree on plans with local teams how to solve problems, and believe to have reached consensus. However, often nothing happens, despite trying to follow up. “Trapped cash” is often a term that is used to explain the situation. It is true that some cash balances really are trapped, but in many cases, there is much that can be done. Ultimately you need the team to roll up the sleeves, get into the details, understand how things really work out, be creative, determined and persistent. Using China as an example again, most cases can be solved with a cross border cash pool. Getting this cash pool in place may require effort and energy, but the outcome resulting in freed cash is well worth the effort.
A suggestion for treasurers is to run a calculation similar to the China example for all countries where their companies are active in Asia. This will provide a better understanding of their cost of cash in the region.
Maturing from Foundation to Developing
Once an organization can conclude that there is significant value in optimizing its treasury in Asia, resources and tools must be allocated to support the process of growing the corporate treasury’s maturity level from foundation to developing. When maturing from the Treasury Maturity Model’s stage of foundation to the developing stage, an organization must take into account the following four important factors: resources, dedication, integration and complexity.
Once resources and the required tools have been allocated, optimization can proceed. When initiating the change, it is best to focus on both resources and tools. The optimization of Asian treasuries tends to be a more iterative process than European optimization projects, so this helps prevent the organization becoming mired in detail. A number of steps must be taken to ensure a structured approach to attaining the local optimization level. These steps do not necessarily need to be taken sequentially, and can be taken simultaneously. Their order will depend on the respective countries’ requirements and the iterative approach adopted.
Local Treasury Center
A comparison of Asian and European treasury optimization reveals the process to be ‘same, but different’. It is important to be aware of the differences. Optimizing treasury in Asia generally plays a prominent role in an organization’s global footprint, and we have seen how timely optimization can prevent an organization incurring huge costs through inefficient operations.
There are three possible treasury center models an organization can consider when attaining specified levels of optimization:
- Global Treasury Center (GTC):
Treasury undertakes all functions and has the highest level of centralized management. It serves as the only treasury for all global markets by combining all local and regional treasuries into a single location. - Regional Treasury Center (RTC):
Serves mainly regional operations and has central management with dedicated staff - Local Treasury Center (LTC):
Serves mainly local operations and is decentralized with dedicated staff.
Treasuries still in the foundation stage seeking to reach the developing stage can be described as operating in a less complex business environment. They operate autonomously from each other and therefore tend to have limited or no dedicated staff, and limited integration. To optimize this level of treasury to the stage of a developed local corporate treasury – a Local Treasury Center – it is necessary to allocate local dedicated treasury staff to focus solely on their tasks. As operations become more streamlined and efficient, more time becomes available to increase their levels of expertise, integrate with the business and tackle the level of business complexity encountered in the local economies.
Next steps
Identifying and acknowledging the problem, and the drivers that may be behind problems and inefficiencies in the foundation phase is vital. Allocating the right resources and tools is also a crucial second step towards attaining the next level of maturity. As the process tends to be more iterative in Asia, try not to get mired in details.
Treasury optimization is a multi-faceted discipline, and many of these facets depend on the individual situation. The key considerations described above are intended to serve as a guideline on where to start and how to approach Treasury optimization in Asia. If doubts persist, enlisting an experienced party to assist with the complexity of such projects is always an option. Zanders can help corporates both in structuring the right approach and as an implementation partner.
Credits
This article was written in cooperation with Aron Åkesson. Aron has been living in Asia for eight years working with and helping MNCs to improve their treasury in the region. He has detailed understanding of local banking, financial markets and culture, speaks mandarin and is well connected among banks and financial institutions in the region. For more information, go to www.aaatreasury.com. As of 1 October 2019, Zanders is also present in Asia. We have opened an office in Tokyo, Japan, to cater to our clients located in the East-Asia region. If you have any questions regarding our operations in Asia, please feel free to reach out to Michiel Putman Cramer via +81 3 6892 3232.
Central Finance and Treasury: a marriage to last?
Treasury Today’s Adam Smith Awards are globally recognized as the industry benchmark for best practice and exceptional solutions in treasury.
Given that it runs on a S/4 HANA engine, it is mainly profiled in the market as a phased approach to adopt SAP S/4HANA, as well as a method to centralize and harmonize local finance processes.
CFin is an SAP S/4 HANA product that was launched in 2015. In its first stage, it enables data collection from multiple ERPs into one S/4 Hana running Central Finance. This also allows opportunities for data harmonization achieved by data cleansing in the source systems and/or by applying derivation rules (during the transfer of data to S/4) to achieve data attributes that have common usage across the organization. Data transfer to CFin occurs in real-time. The harmonized data in one CFin system enables systematic consolidated reporting, removing manual work around consolidating reports (in different formats) from multiple ERPs. CFin provides the most value to an organization where there are multiple older SAP ERP instances or other non-SAP Finance applications.
CFin exploits the capabilities of HANA – real-time, speed and agility to replicate financial documents into the central system – providing a real-time organization-wide financial view. In other words, CFin allows you to create a real-time common finance reporting structure for an organization.
Perceived use cases in the market for CFin are the following:
- Merger and acquisitions: repeatable onboarding for non-organic growth.
- Instance consolidation: credit, accounts payable and collections can be centralized in one instance.
- System consolidation: migrate and decommission selected existing SAP and non-SAP ERP systems.
- Subsidiary onboarding: smaller entities or subsidiaries can be easily onboarded onto the platform.
- SAP & non-SAP: the solution lets you consolidate and harmonize data on the fly, and update enterprise structures across SAP and non-SAP ERP systems like Oracle, PeopleSoft, or JD Edwards.
- Business transformation while staying on the ECC platform but leveraging on the S/4 Hana capabilities around improved processing.
- Enriched user experience via transformed UI and Fiori apps running on S/4.
- Shared service centre optimization through central process execution in one system.
- Centralized treasury through centralized payments, In-House Banking, Bank account management, Cash positioning and forecasting and Exposure identification and measurement
Deployment as Central reporting (release 1511 and onwards)
In a first phase, SAP CFin allows real-time replication of FI Documents. The replication of data is enabled via the SAP Landscape Transformation (SLT) replication server. More specifically, SLT is a tool that allows you to load and replicate data in real-time or via batch processing data from the SAP and non-Sap source systems into the SAP S/4 HANA database. This piece of software is a key element of the CFin solution. To provide full visibility on the SLT server, SAP has developed an application interface management framework (AIF). AIF is a monitor that allows error handling and full visibility on the SLT interface, as well as mapping functionality. It is important to highlight that CFin allows both the AIF and SLT for the integration of older SAP and non-SAP ERP systems.
Once an initial load of data is performed out of the various source systems into the CFIN application, continuous replication can be setup. If all systems are setup and connected to the CFin box, CFin can function as a central database of all financial data across the organization. If fully implemented, even a single universal journal can be operated
CFin also includes a Master Data Governance (MDG) application. The MDG allows you to manage all your master data centrally with a workflow and distribution functionality to all connected systems. If MDG is fully deployed, no new master data can be created outside of MDG. While basic functionality is included in CFin license, a separate license is required for full functionality.
To minimize any impact on the source system, CFin offers the functionality to enable mapping. General master data mapping can either be configured in the CFin customizing or by using the MDG functionality. Master data related to cost object is mapped using the cost object mapping framework.
Next to the technical complexity, CFin requires intensive business changes in order to be successful. The following business changes need to occur to unleash CFin’s full potential:
- Clean up master data.
- Clean up transactional data and verify consistency.
- Clean up old processes in source systems.
- Data harmonization of GL Accounts to enable one Universal Journal.
- Harmonization of profit and cost centers across legacy systems.
- Unification of Business partner set.
- Move to standard SAP as much as possible.
Mapping, either via the cost mapping framework, customization or the MDG, can alleviate the burden of harmonization on the source systems.
The key benefits of the deployment of CFin as a central reporting solution are:
- Real-time harmonized global financial reporting on various units and source systems.
- Universal journal for external, internal and management accounting.
Deployment of central processing (release 1809 and onwards)
After the first level of deployment, CFin can be an enabler for central processing. To enable central processing, the CFIN engine needs to be used as the single source of truth. This means that any documents created in the source systems are technically cleared and replicated in the CFin system. Even transactions can be directly entered in the CFin system. As a logical consequence, all status management is executed in the CFin application.
Various processes can be run on the CFIN engine, but in this document we are focusing on the following three relevant processes:
- Central payments.
- Cash application.
- Banking hub.
All three activities are a logical extension of centralizing all financial data. For example, instead of connecting to external banks out of each individual source system, all bank connections can be centrally managed out of the CFin system. Bank connectivity over Swift would further make the connectivity landscape bank agnostic, thereby limiting the connectivity to your Swift partner. Centralizing the bank connection entails outgoing traffic such as payments and collections, and incoming traffic such as bank statements.
The central payments functionality does not replace a treasury payment factory, as transactions are still executed from the debtor accounts, while a payment factory enables the on behalf payments from a centrally held set of accounts supported by an in-house bank structure
As all transactions and bank connections move to CFin, it is also therefore logical to centralize all bank statements in CFin. No distribution to ERP systems is required as all documents are technically cleared in the source systems.
Cash application refers to the management of open items, cash in transit and bank reconciliation. As all transactions are centrally executed, cash application is logically also executed centrally.
As is the case with all centralization exercises, special attention needs to be paid to the support of local payments in a central instance. With card payments, for example, the bill of exchange requires specific data elements to enable matching. If the elements are not mapped correctly to the central instance, the local payment method might not be fully supported in the central instance.
At the time of writing, only a handful of companies are live with central processing. Most CFin clients are still in the first phase of implementation.
Additional key benefits of the deployment of CFin as a central process engine include:
- Central open item management and payments.
- Consolidation.
- Central close.
Interaction Central Finance & Treasury
A key question treasurers ask is how treasury and CFin relate towards each other. Firstly, CFin central processing instance focuses on the centralization and standardization of local finance processes. However, as treasury is a well-connected corporate function in any organization, Zanders expects a sizeable impact from CFin on the treasury function. Let’s look at a few key areas:
Payment factory: Payment factory is defined here as a central structure that facilitates payment on behalf of/in name of and receivables on behalf of for all subsidiaries in the company.
CFin and payment factory applications are independent modules and ring fenced in terms of the functionality they deliver. CFin, however, complements the payment factory by simplifying the integration of source ERPs to the system hosting payment factory (the same system as having CFin). In a CFin world, the payables and receivables (for direct debits) are technically cleared in the source ERPs, as these open items are transferred to the CFin system. The payments (and direct debits) can be then executed in CFin system in a standardized way. The complexities of integrating payment requests from ERPs, particularly non-SAP ERPs, in a non-CFin world do not exist. Therefore a payment factory implementation will require less effort if CFin central processing is fully implemented.
Cash positioning: Cash positioning is defined here as establishing and managing your daily cash position by currency or bank account as well as evaluating the short-term cash needs and liquidity position.
A prerequisite for enabling central cash positioning is the setup of centralized payment processing. This allows cash positioning for subsidiary companies to be enabled in the central system. A major benefit compared to today’s process in the non S/4 HANA source systems is the overhauled user experience. Currently, a sizeable set of new Fiori apps in the cash management space are readily available on S/4, such as a Fiori app on automatic reconciliation of intraday bank movements against cash estimates. Similar apps are available on variance analysis and request bank transfers on the fly from cash position reporting. The real-time availability of data also leads to a more accurate evaluation of the short-term liquidity position.
Cash flow forecasting: Cash flow forecasting is defined as estimating the timing and amounts of cash inflows and outflows over a specific period. Cash flow forecasting tackles a longer-term horizon than cash positioning does. Generally speaking, cash flow forecasting works of provided date from treasury stakeholders combined with historic patterns.
CFin currently does not have the functionality to support cash flow forecasting. However, the real-time integration of ERP documents into the central system provides the capability to do more accurate mid-term cash forecasting. An additional benefit realized by the availability of real-time data is the pre-population of subsidiary forecasts, which leads to more accurate cash flow forecasting. It is important to note that SAP does not offer any standard functionality regarding pre-population of data in subsidiary cash flow forecasting. The interaction for treasury is mostly limited to interfacing cash flow and transaction data.
Risk management: Risk management is any functionality linked to the management of financial risk, to allow the company to meet its financial obligations and ensure predictable business performance. In most companies, treasury actively manages liquidity, credit, FX, interest rate and commodity risk.
Limited functionality is present in CFin to support risk management. The main interaction is limited to interfacing exposure data to treasury. Although all relevant accounting information is available in the CFin system, no risk management functionality is available. Therefore, treasury can help to actively manage the foreign currency risks from any balance sheet position or even from any single item. This feature is supported with the functionality Balance Sheet FX Risk within SAP’s Treasury solution.
Looking further than foreign currency balance sheet risk, as the data from multiple ERPs is now available on one system, with bespoke development it could be linked in real-time to the one exposure table from where it can be managed via SAP standard functionality on exposure, risk and hedge management. The availability of data into the exposure functionality provides significant value in overall risk mitigation. It is important to highlight that attention needs to be paid on mapping when documents are replicated to the central system. Mapping can have a substantial impact on risk management operations if not executed diligently.
Looking at the system architecture, a common question is: “Do Treasury & Central Finance operate on one common platform or as two separate boxes?” Unfortunately, the question does not have a clear-cut answer. To balance the merits of both approaches, a more detailed assessment is required.
Conclusion
CFin will become an important counterparty for treasury to cooperate with. Treasury will be a major consumer of CFin data to run operations such as a payment factory, risk management, and cash flow forecasting. Due to the importance of CFin to treasury and its operations, treasury needs a seat at the table of any CFin implementation. Involvement in the design phase is key to ensuring the information needed for treasury is available. Involvement in the mapping and harmonization exercise is particularly crucial.
Zanders & Central Finance
Given our 25 years of experience in treasury and our renowned SAP Treasury practice, Zanders is well placed to take up the role of treasury at the table. Thanks to our in-depth business expertise, as well as our extensive experience with both systems, we can be the perfect partner for your Central Finance implementation. Would you like to know more? Then contact Sibren Schilders via s.schilders@zanders.eu.
Tech savvy people needed for Treasury function
Treasury Today’s Adam Smith Awards are globally recognized as the industry benchmark for best practice and exceptional solutions in treasury.
What are the main changes influencing treasury’s added value within corporates? Laurens Tijdhof (LT): “Business models are changing. In the decades since the introduction of the internet, ‘digital natives’ – new multinational companies such as Uber […]
Ron Chakravarti, Citi’s global head of treasury advisory, and Zanders partner Laurens Tijdhof discuss some of the key themes.
What are the main changes influencing treasury’s added value within corporates?
Laurens Tijdhof (LT): “Business models are changing. In the decades since the introduction of the internet, ‘digital natives’ – new multinational companies such as Uber and Google – have emerged to disrupt all industry sectors. These companies have less legacy than traditional multinationals. Treasury plays an important role in that digital native environment, for example with payment innovation in ecommerce. Traditional multinationals are typically dealing with a lot of legacy because of mergers and acquisitions throughout their history. For them, the change is more transformational in nature, as they are doing something different than they have done in the past decades or even in the past century. This is one of the elements where treasury can add significant value; to understand from a financial point of view where the business is in the current cycle and to see what things need to be changed, updated or optimized to add value.”
Ron Chakravarti (RC): “Firstly, the pace of change in commerce has picked up, driven by new technologies and new ways of doing business. These are shifting the timing, value, and volume of cash flows and, of course, that impacts treasury. Secondly, while treasury always has to manage regulations and the cash flow impact of changes in global taxation, the pace of change in these have also picked up. Finally, geopolitical uncertainty has created additional considerations at this point in time. Corporate treasurers, therefore, need to ensure their teams are increasingly nimble to deal with all of these issues. The good news is that the availability of new technologies, data and artificial intelligence have the potential to change how treasury works and to create added value.”
At what point are companies ready for new technology?
LT: “Before a company can enter the next stage of treasury maturity, it first needs to get the basics right. This means having a focus on centralization, standardization and automation, typically using traditional technology like a TMS or an ERP system. And if you have these systems in place, be sure you’re using and benefiting them optimally from that environment first. Once you have the basics right, you can go to the next stage of a smart treasury, using the new digital or exponential technologies. Then you can benefit from the good basis and use more of the data in analytical ways, with algorithms or newer technologies like robotic process automation (RPA) or artificial intelligence (AI).”
RC: “I completely agree that getting the basics right, by completing the journey to an efficient treasury comes first. Treasury is on an evolution path of becoming first efficient, then smart, and finally integrated. Getting to efficient means that you must standardize, centralize, and automate. Even among multinational companies, not all have mature, centralized treasury models. Getting to a best in class model is key. In most industries that includes a functionally centralized regionally distributed treasury model, with operational treasury on a common infrastructure and processes. Once you are substantially there, you can work on the next step change, in making the move to a smart treasury. And ultimately to an integrated treasury.”
How should a treasurer deal with the continuous change driven by these exponential technologies?
RC: “Well, an issue is that – as The Future of Treasury whitepaper indicates – only 14 percent of corporates have a digital strategy at the treasury level. Why is this so low? One reason is the availability of the right resources. While treasurers have previously adapted to technology change, this change is all happening a lot faster now – for treasury and the broader business. Ultimately, treasury is all about information. Today, more than ever, the treasury function needs to include people who are technologically savvy. People who are able to comprehend what is changing and how to best deploy technology. That will become increasingly important to create value for the business. Treasury teams recognize that they need to have a digital strategy, but many of them are not fully equipped to define one. They are looking for help from industry leaders with a treasury framework to define their digital treasury strategy. That is one of the reasons for this collaboration between Citi and Zanders; in many cases we recognize that we can better do it together, creating added value for our mutual clients.”
LT: “If you compare the current situation to ten years ago, a treasurer would only buy new technology if there was a real requirement. Today, there’s new technology that many treasurers do not fully understand – in terms of what problems it could potentially solve for the company. What you often see now is that treasurers start with small projects, proofs of concepts, to test some innovative ideas. You can compare it with the iPhone; when Steve Jobs invented it, it took some time before people really understood what to do with it, what value it would add in their life. First you need to see what it is, what it can do for you, whether it can solve a real problem. That’s the exiting stage in which we are now. Some treasurers are trail blazers, others are more followers that first want to learn from others about how it has brought them forward.”
Where can these latest technologies really improve treasury? Are there any issues they cannot solve?
LT: “Treasury is all about information and data. There’s a lot of information available in a treasury environment and you sometimes need new technologies and standardized processes to unlock the value out of these data. Treasury covers a large amount of structured data in all kinds of systems. If you want to translate that data insight into valuable conclusions, then technology is probably the right enabler to help; with data analytics and visualization, for example. But, if you don’t have your data centrally available in a data warehouse or data lake, then that’s the first part you should work on; you first need to have your data centrally available to be able to do something with it. Unfortunately, many large multinational companies are still in that stage, they still have data that’s very fragmented and decentralized. For those companies, you could say that the newest technologies have come too early.”
RC: “What will improve treasury? We should first consider what treasurers are seeking to do. Today, we are seeing an increasing appetite from corporate treasurers for integrated decision support tools going beyond what treasury management systems can provide. To that end, we at Citi are running a number of experiments, collaborating with our clients and fintechs, and enabling our clients’ journey towards smart treasury. This is about moving beyond descriptive analytics to decision support and decision automation, and offering opportunity to realize the full automation of operational treasury. What won’t be solved? Well, we won’t get there in 2020 but we will certainly soon start seeing the foundational steps in this transition to a fully automated operational treasury and that’s what is so exciting.”
Click here to download the whitepaper ‘The Future of Corporate Treasury’.
Updated IRRBB guidelines pose new challenges for banks
On 31 October 2017, the European Banking Authority (EBA) published a consultation paper on the update of its ‘Guidelines on the management of interest rate risk arising from non-trading book activities’.
This long-awaited update for the management of Interest Rate Risk in the Banking Book (IRRBB) builds on the original guidelines published in May 2015. It also effectively is the translation to European law of the IRRBB Standards published by the Basel Committee on Banking Supervision (BCBS) in April 2016. Market participants had until 31 January 2018 to put forward their feedback on the updated guidelines. After completion, the guidelines will apply from 31 December 2018. Certain aspects of the BCBS standards from April 2016 are not addressed in the updated EBA guidelines. The EBA is still working on a number of technical standards as part of the ongoing CRD and CRR revision in which they for example will prescribe disclosure requirements and the standardised approach for IRRBB.These technical standards will be published separately at a later stage.
Compared to the 2015 version, the guidelines have increased in size significantly. As published in our infographic, the guidelines contain over 40% new articles, which originate partly from the BCBS standards, but also contain some new guidelines. This article discusses the three main changes introduced in the consultation. First of all, the major overhaul of the supervisory outlier test. Next, the strong increase in the guidance on governance and model risk management. And finally, the shift EBA requires from the more traditional Net Interest Income (NII) metrics to a true earnings-based approach. The article concludes with an overview of the main comments provided by market participants in response to the consultation.
Supervisory outlier test
The existing supervisory outlier test (SOT) measures how the Economic Value of Equity (EVE) responds to an instantaneous +/- 200 basis points parallel yield curve shift. The SOT is an important tool for supervisors to perform peer reviews and to compare IRRBB exposures between banks. Changes in EVE that exceed 20% of the institution’s own funds will trigger supervisory discussions and may lead to additional capital requirements.
In the BCBS standards, a different SOT definition was proposed, introducing a 15% trigger compared to Tier 1 capital in combination with six interest rate scenarios that also include non-parallel shocks. The EBA has decided to implement both SOTs. The combination of more scenarios and an additional trigger level will restrict the maneuvering capabilities of banks, even though the new SOT is considered an ‘early warning signal’ only.
In an attempt to further improve the comparability of results between banks, the EBA has strengthened the guidance for the calculation of the SOTs. This covers both scoping requirements (e.g. non-performing loans and pension obligations and pension plan assets now need to be included) and measurement requirements (e.g. lowering the zero interest rate floor, now ranging from -150 basis points for overnight positions to zero basis points for 30 years and more).
One of new measurement requirements for the calculation of the SOT, is particularly noteworthy. The EBA guidelines require the use of risk-free discounting for the calculation of the SOT. With respect to the cash flows, it is up to banks to decide whether or not they want to include the commercial margin and other spread components. This level of flexibility should primarily be interpreted as an escape route in case banks are not able to strip the commercial margins from their cash flows. From an interest rate risk management perspective it is clear that alignment between discounting and cash flows is preferable. The interesting development in the guidelines is that a bank can only choose to use stripped cash flows in the SOT calculation if this is consistent with the way the bank manages and hedges IRRBB. In this way, aiming for alignment between discounting and cash flows for the SOT may have large consequences, depending on the choices a bank has made for the internal management of IRRBB.
Governance and model risk management
The section in the updated guidelines on governance has significantly increased in size compared to the original version. It includes new guidelines on the risk management framework, risk appetite and model governance. These may seem new, but on close inspection, the majority of these added guidelines are direct copies of the BCBS standards, as can also be seen in Figure 1. This figure provides a graphical overview of the main areas in the EBA consultation and how the original EBA guidelines and BCBS standards have been incorporated in the consultation. While the guidelines on the risk management framework and risk appetite can be considered a more detailed explanation of the original guidelines, the main addition is on model risk management. This requires institutions to set up a model governance, not only for any behavioural models, but for all IRRBB measurement methods that traditionally have not always been in scope of a model governance.
Where the majority of the original EBA guidelines have been transferred to the consultation, sometimes with more detail, some of the BCBS standards have not been included at all. This is especially true for ‘Principle 5: Behavioral optionalities’ and ‘Principle 8: IRRBB Disclosure’. Guidelines on Behavioral optionalities were already far more detailed in the original EBA guidelines and therefore the BCBS standards were not incorporated in the EBA consultation. The guidelines on IRRBB Disclosure have not been included as these will be addressed in the separate reporting technical standards mentioned earlier.
From NII to earnings
One of the main additions to the guidelines, which didn’t originate from the original guidelines nor from the BCBS standards, is the requirement to also include market value changes in earnings metrics. This change will require banks to start modeling a true IFRS Profit & Loss at Risk and take into account the increase or reduction in total earnings and capital. Traditionally, earnings metrics just focus on NII and ignore any interest rate sensitivity in other areas of the Profit and Loss (P&L) account. It will have a significant impact on the modeling of earnings measures, as the accounting treatment of instruments will start to determine how the measure will be impacted. Although this seems a logical extension of an earnings metric, it presents significant challenges especially in the area of derivatives used for hedge accounting and instruments in an Available-for-Sale portfolio, for which only coupon payments were included up till now. Adding market value movements of these instruments introduces the risk of double counting and therefore requires a clear definition of how the interest rate sensitivity impacts the P&L. Integrating these effects in a forward looking calculation will pose challenges to the implementation in systems.
Consultation responses
In total, 19 organizations responded to the consultation. Some of them responded to the 16 questions in the consultation, while others chose to add a more general response to the consultation.
One of the main critiques is around the inclusion of CSRBB in the scope of IRRBB. Especially the lack of a proper definition (currently defined as “any kind of spread risk that is not IRRBB or credit risk”) and the inclusion in an IRRBB context is commented on by the respondents. The general response is to remove CSRBB from the scope of the IRRBB guidelines and to create separate guidelines on CSRBB instead. Another area of concern is the guidance on capital calculation. Although primarily copied from the original guidelines, this particular part of the guidelines raises a considerable number of questions. In particular, whether capital should be calculated for variability risk or loss risk and how capital for earnings risk and value risk should be integrated in a consistent framework, without duplications, remains unclear. Finally, the date of implementation is also considered challenging by a number of respondents, as a December 2018 implementation date effectively requires banks to implement all changes in six to nine months.
Conclusion
For many banks the implementation of the 2015 EBA guidelines is still a work in progress. The recent update of the guidelines poses new challenges for banks. Given the substantial number of changes compared to the previous version, the December 2018 implementation deadline will prove to be challenging. And we haven’t seen the end of it, because a number of technical standards as part of the ongoing CRD and CRR revision are still in the pipeline. This includes for example requirements to standardize the disclosure of IRRBB, which currently shows a lot of variety between various jurisdictions and will likely require a significant effort for all banks as well. As a result, IRRBB will remain on the agenda of the regulator and the management board of many banks in the years to come.
IRRBB Quick Scan
Should you want to assess your bank’s IRRBB framework, Zanders offers an IRRBB Quick Scan. Based on a review of available model documentation, risk reports and interviews with your bank’s risk specialists, the scan provides an independent and objective assessment of your bank’s IRRBB implementation relative to the new IRRBB principles and best-market practices. More information on the IRRBB Quick Scan can be found here.
Time to brush-up your bank’s IRRBB framework
On 31 October 2017, the European Banking Authority (EBA) published a consultation paper on the update of its ‘Guidelines on the management of interest rate risk arising from non-trading book activities’.
Regulation on interest-rate risk in the banking book (IRRBB) is evolving after being somewhat overlooked in recent years. Banks are now updating their interest-rate risk frameworks and have important choices to make on the design of a new IRRBB framework: what are the risk types that need to be covered and how can a value and earnings measure be created? Nonetheless, this process provides an excellent opportunity for improving regulatory compliance as well as reviewing a financial organization’s benchmarks and best practices.
After a long period of limited regulatory attention for interest-rate risk in the banking book (IRRBB), the subject has moved up the regulatory priority list in the last couple of years. Maybe this is the result of the low interest-rate environment or because an update on the subject was long overdue.
After a long period of limited regulatory attention for interest-rate risk in the banking book (IRRBB), the subject has moved up the regulatory priority list in the last couple of years. Maybe this is the result of the low interest-rate environment or because an update on the subject was long overdue.
It still came as a bit of a surprise when the European Banking Authority (EBA) published an update of their 2006 guidelines in May 2015. The Basel Committee on Banking Supervision (BCBS) was known to be working on an update of their standards too and it is quite uncommon for the EBA to front-run BCBS standards.
When the BCBS standards were finalized in April 2016, the industry was relieved that the regulator did not opt for a Pillar 1 approach for IRRBB (leading to standardized minimum capital requirements), but chose to capture IRRBB as part of Pillar 2 (where the supervisor can tailor capital requirements to the [heterogeneous] IRRBB profile of banks).
All the recent regulatory attention has caused the subject to be high on the agenda of the management board of many European banks. Consequently, IRRBB policies and governance are being reviewed and updated to align them with regulatory requirements, while the measurement of interest-rate risk is also being enhanced. This includes enhancements to the models used to measure interest-rate risk as well as to the Risk Appetite Statement (RAS), which brings it all together.
Important choices are to be made in the update of an IRRBB framework: the main ones concern the scope and the balance between the value and earnings perspective.
With respect to the former, the traditional approach was to measure interest-rate risk through a parallel shift of the yield curve. It is clear that this is no longer sufficient and that several other risk types (e.g. non-parallel, basis and optionality risks) should be consistently included in the framework as well.
With respect to the latter, the EBA guidelines and BCBS standards state that interest rate risk needs to be measured both through a value and an earnings perspective. These metrics show two sides of the same coin, but cannot be optimized at the same time.
IRRBB appetite and scope
One of the first decisions in setting up an IRRBB framework is to determine the appetite for both value and earnings risk. This appetite is set in terms of the value and earnings a bank is willing to lose in a pre-determined adverse scenario.
As a first step, typically a parallel scenario is selected for this. The appetite can then be translated into risk limits and one of the common metrics for this is the duration of equity. The appetite for earnings and value risk usually introduces a duration interval in which the balance sheet can be optimized. This poses the question of how this optimization should be achieved.
If a bank aims for low volatility in value, the duration of equity should be low. That, however, will come at the cost of increased earnings volatility. As the majority of the banking book is accounted for at amortized cost, the only way for the profit and loss (P&L) of a bank to be hit is through a loss in earnings. Aiming for low earnings volatility instead of low value volatility therefore seems a more sensible option.
Managing the banking book through the duration of equity also has its shortcomings as it only covers linear interest-rate risk. As already discussed in the introduction, other risk types should also be included in the risk appetite. The difficulty in setting a risk appetite for those types is that it is challenging to create scenarios that cover only the additional risk types, as scenarios usually exhibit some overlap.
The three main additional risk types to be included in a bank’s RAS are:
Non-parallel gap risk
This determines how exposed a bank is to a steepening, flattening or rotation of the curve. Especially when a bank has a duration mismatch between its assets and liabilities it is expected to have an exposure to non-parallel gap risk.
Basis risk
With parallel and non-parallel gap risk, it is usually assumed that all yields in a specific currency move together; this assumption is relaxed in basis risk. Basis risk comes in multiple forms, the most apparent ones being tenor, currency or reference curve basis risk.
Optionality risk
Optionality risk can be included in the framework in different ways. If the cash flows used to calculate the value or earnings risk do not reflect the interest-rate risk dependent behavior of options, this dependency should be reflected here.
This approach aligns with the BCBS standards. It also makes sense, however, to change the interest-rate dependent cash flows when measuring the parallel and non-parallel risk.In that case, the option risk is already captured. In addition, it could be considered to measure the exposure to changes in the volatility of interest rates, especially if interest-rate risk dependent models are used.
Two other risk types that are very much related to IRRBB and that can be captured in the same framework are credit spread risk (in the banking book) and client behavior risk.
The latter measures the sensitivity of value and earnings to unexpected client behavior. The interest-rate risk dependent behavior of options is measured under gap risk or optionality risk and concerns the expected client behavior in, for example, mortgage prepayments.
This expected client behavior is estimated through a model, but the actual behavior will likely differ from the model outcome. Client behavior risk measures this model error. The former, credit spread risk, measures the sensitivity of value and earnings to changes in credit spreads. In general credit spread risk is only measured for the limited part of the banking book that is not accounted for at amortized cost.
When the scope and the appetite for all risk types in scope of IRRBB are determined, the next step is to measure the value and earnings risk.
Value risk
The main challenge in measuring value risk is the approach to determine the value. If, as a starting point, the cash flows and discounting must align, two approaches can be considered:
The first approach we call the ‘pure interest-rate view’, as it only covers the interest-rate component of the cash flows (thus excluding margins and other spread components) and discounts those at the risk-free rate.
This approach aligns well with the way the banking book is managed: the interest-rate risk can easily be hedged and the margin that remains is considered a constant income flow.
Furthermore, it aligns with the way the regulator wants interestrate risk to be disclosed through the economic value of equity (ΔEVE) and how it is limited by means of the standard outlier test. The base valuation that is used to calculate the at-risk numbers is difficult to interpret, however, as it does not link to a market value at all.
The second approach addresses this shortcoming and aims to measure value risk through a mark-tomarket valuation. In this approach, all cash flow components are discounted against a curve that includes margins and other spread components.
This is easier said than done, as for illiquid products, such as savings or mortgages, a market value is not directly available and therefore needs to be estimated based on a model. Taking the second approach implies that the value risk of the banking book’s margin is also captured by the risk measure. As that risk will generally not materialize, one may consider not using this measure as the basis for hedging the interest-rate risk.
Finally, it is important to realize that the resulting duration of equity differs for the two approaches. Consequently, the limit setting will depend on the choices made here. This interplay with setting the RAS should be carefully managed.
Earnings risk
Earnings metrics have increased in popularity in recent years as they better align to the way the banking book is accounted for. Contrary to value risk, no regulatory limits are imposed on earnings volatility and only recently has the BCBS added the disclosure of earnings risk to the standards. While the measurement of value risk is relatively straightforward, with only a limited number of options to model the risk, the measurement of earnings volatility comes with a whole range of parameters that need to be set.
The first decision is on the scope of the earnings measure; will this be a true earnings at risk (covering the entire impact of interest-rate risk on the P&L) or will it only cover interest-rate income and expenses? The latter is often referred to as a net interest income at risk (NII-at-risk), where the former will also include interest-rate dependent commissions and fair value changes in the banking book that have impact on the P&L.
One of the main features of an earnings measure is that it attempts to forecast future earnings. This requires a forecast both of the balance sheet and the interest-rate term structures. Forecasting the balance sheet makes most sense if it aligns with the corporate planning process, where a projection of future earnings is made as well.
Alternatively, it is possible to assume a static balance sheet and although this is prescribed in the BCBS standards, it is not preferred to use this for internal measurement.
For forecasting interest rates, several options exist as well. It is possible to align with the forward interest rates; just use the current interest rates as a future projection or use the forecasted rates that have been used in the corporate planning. Again, the latter makes most sense for internal management.
A final decision is on the forecasting horizon. Not too long ago, most banks calculated earnings risk using a one-year horizon. Extending the horizon to two or three years and defining limits on those longer horizons is a trend, but also comes at an increased dependency on forecasting assumptions. Furthermore, a bank should consider upfront how it can manage its earnings risk in case of limit breaches.
Regulatory requirements
The regulatory requirements with respect to the management of IRRBB are still evolving. Both the EBA guidelines and the BCBS standard list explicit requirements with respect to the use of both value and earnings-based measures.
For a start, banks are required to define their risk appetite, measure their IRRBB, and report on IRRBB, using both perspectives. It is stressed that the two perspectives are complementary, because of their differences in terms of outcomes, assessment horizons and balance sheet assumptions that have been discussed in this article. More detailed requirements with respect to the calculation of value and earnings-based measures are also included in the BCBS standard, to facilitate the comparability of the IRRBB reported by banks.
The BCBS expects banks to implement their latest standard by 1 January 2018 and so far it is expected that the EBA and FINMA (the Swiss regulator) will demand the same timelines for the upcoming update of their guidelines. Due to these evolving regulatory requirements, many banks are currently updating their IRRBB framework.
Such a process is an excellent opportunity to not only aim for regulatory compliance, but to also benchmark your bank’s IRRBB framework to best-market practices.
Quick Scan
Zanders uses its IRRBB Quick Scan to assess your bank’s IRRBB framework. Based on a review of available model documentation, risk reports and interviews with your bank’s risk specialists, the scan provides an independent and objective assessment of your bank’s IRRBB implementation relative to the new IRRBB principles and best-market practices. After having assessed all principles and accompanying requirements, Zanders will state to what extent your bank’s IRRBB framework is compliant with the regulatory requirements.Per IRRBB principle, Zanders will indicate whether your bank’s IRRBB framework is above, at or below the new minimum standards of the BCBS. For the areas of the IRRBB framework that do not meet the minimum standards, recommendations will be presented in the report (including a level of priority that accounts for proportionality and materiality).
Mortgage valuation, a discounted cash flow method
On 31 October 2017, the European Banking Authority (EBA) published a consultation paper on the update of its ‘Guidelines on the management of interest rate risk arising from non-trading book activities’.
The most common valuation method for mortgage funds is known as the ‘fair value’ method, consisting of two building blocks: the cash flows and a discount curve. The first prerequisite to apply the fair value method is to determine future cash flows, based on the contractual components and behavioral modelling. The other prerequisite is to derive the appropriate rate for discounting via a top-down or bottom-up approach.
Two building blocks
The appropriate approach and level of complexity in the mortgage valuation depend on the underlying purpose. Examples of valuation purposes are: regulatory, accounting, risk or sales of the mortgage portfolio. For example BCBS, IRRBB, Solvency, IFRS and the EBA ask for (specific) valuation methods of mortgages. The two building blocks for a ‘fair value’ calculation of mortgages are expected cash flows and a discount curve.
The market value is the sum of the expected cash flows at the moment of valuation, which are derived by discounting future expected cash flows with an appropriate curve. For both building block models, choices have to be made resulting in a tradeoff between the accuracy level and the computational effort.
Cash flow schedule
The contractual cash flows are projected cash flows, including repayments. These can be derived based on the contractually agreed loan components, such as the interest rate, the contractual maturity and the redemption type.
The three most commonly used redemption types in the mortgage market are:
- Bullet: interest only payments, no contractual repayment cash flows except at maturity
- Linear: interest (decreasing monthly) and constant contractual repayment cash flows
- Annuity: fixed cash flows, consisting of an interest and contractual repayment part
However, the expected cash flows will most likely differ from this contractually agreed pattern due to additional prepayments. Especially in the current low interest rate environment, borrowers frequently make prepayments on top of the scheduled repayments.
Figure 1 shows how to calculate an expected cash flow schedule by adding the prepayment cash flows to the contractual cash flow. There are two methods to derive : client behavior dependent on interest rates and client behavior independent of interest rates. The independent method uses an historical analysis, indicating a backward looking element. This historical analysis can include a dependency on certain contract characteristics.
On the other hand, the interest rate dependent behavior is forward looking and depends on the expected level of the interest rates. Monte Carlow simulations can model interest dependent behavior.
Another important factor in client behavior are penalties paid in case of a prepayment above a contractually agreed threshold. These costs are country and product specific. In Italy, for example, these extra costs do not exist, which could currently result in high prepayments rates.
Discount curve
The curve used for cash flow discounting is always a zero curve. The zero curve is constructed from observed interest rates which are mapped on zero-coupon bonds to maturities across time. There are three approaches to derive the rates of this discount curve: the top down-approach, the bottom-up approach or the negotiation approach. The first two methods are the most relevant and common.
In theory, an all-in discount curve consists of a riskfree rate and several spread components. The ‘base’ interest curve concerns the risk-free interest rate term structure in the market at the valuation date with the applicable currency and interest fixing frequency (or use ccy- and basis-spreads). The spreads included depend on the purpose of the valuation. For a fair value calculation, the following spreads are added: liquidity spread, credit spread, operational cost, option cost, cost of capital and profit margin. An example of spreads included for other valuation purposes are offerings costs and origination fee.
Top-down versus Bottom-up
The chosen calculation approach depends on the available data, the ability to determine spread components, preferences and the purpose of the valuation.
A top-down method derives the applied rates of the discount curve from all-in mortgage rates on a portfolio level. Different rates should be used to construct a discount curve per mortgage type and LTV level, and should take into account the national guaranteed amount (NHG in the Netherlands). Subtract all-in mortgage rates spreads that should not part of the discount curve, such as the offering costs. Use this top-down approach when limited knowledge or tools are available to derive all the individual spread components. The all-in rates can be obtained from the following sources: mortgage rates in the market, own mortgage rates or by designing a mortgage pricing model.
The bottom-up approach constructs the applied discount curve by adding all applicable spreads on top of the zero curve at a contract level. This method requires that several spread components can be calculated separately. The top-down approach is quicker, but less precise than the bottom-up approach, which is more accurate but also computationally heavy. Additionally, the bottom-up method is only possible if the appropriate spreads are known or can be derived. One example of a derivation of a spread component is credit spreads determined from expected losses based on an historical analysis and current market conditions.
In short
A fair value calculation performed by a discounted cash flow method consists of two building blocks: the expected cash flows and a discount curve. This requires several model choices before calculating a fair value of a mortgage (portfolio).
The expected cash flow model is based on the contractual cash flows and any additional prepayments. The mortgage prepayments can be modeled by assuming interest dependent or interest independent client behavior.
To construct the discount curve, the relevant spreads should be added to the risk-free curve. The decision for a top-down or bottom-up approach depends on the available data, the ability to determine spread components, preferences and the purpose of the valuation.
These important choices do not only apply for fair value calculations but are applicable for many other mortgage valuation purposes.
Zanders Valuation Desk
Independent, high quality, market practice and accounting standard proof are the main drivers of our Valuation Desk. For example, we ensure a high quality and professionalism with a strict, complete and automated check on the market data from our market data provider on a daily basis. Furthermore, we have increased our independence by implementing the F3 solution from FINCAD in our current valuation models. This permits us to value a larger range of financial instruments with a high level of quality, accuracy and wider complexity.
For more information or questions concerning valuation issues, please contact Pierre Wernert: p.wernert@zanders.eu.
IFRS 17: the impact of the building blocks approach
On 31 October 2017, the European Banking Authority (EBA) published a consultation paper on the update of its ‘Guidelines on the management of interest rate risk arising from non-trading book activities’.
The new standards will have a significant impact on the measurement and presentation of insurance contracts in the financial statements and require significant operational changes. This article takes a closer look at the new standards, and illustrates the impact with a case study.
The standard model, as defined by IFRS 17, of measuring the value of insurance contracts is the ‘building blocks approach’. In this approach, the value of the contract is measured as the sum of the following components:
- Block 1: Sum of the future cash flows that relate directly to the fulfilment of the contractual obligations.
- Block 2: Time value of the future cash flows. The discount rates used to determine the time value reflect the characteristics of the insurance contract.
- Block 3: Risk adjustment, representing the compensation that the insurer requires for bearing the uncertainty in the amount and timing of the cash flows.
- Block 4: Contractual service margin (CSM), representing the amount available for overhead and profit on the insurance contract. The purpose of the CSM is to prevent a gain at initiation of the contract.
Risk adjustment vs risk margin
IFRS 17 does not provide full guidance on how the risk adjustment should be calculated. In theory, the compensation required by the insurer for bearing the risk of the contract would be equal to the cost of the needed capital. As most insurers within the IFRS jurisdiction capitalize based on Solvency II (SII) standards, it is likely that they will leverage on their past experience. In fact, there are many similarities between the risk adjustment and the SII risk margin.
The risk margin represents the compensation required for non-hedgeable risks by a third party that would take over the insurance liabilities. However, in practice, this is calculated using the capital models of the insurer itself. Therefore, it seems likely that the risk margin and risk adjustment will align. Differences can be expected though. For example, SII allows insurers to include operational risk in the risk margin, while this is not allowed under IFRS 17.
Liability adequacy test
Determining the impact of IFRS 17 is not straightforward: the current IFRS accounting standard leaves a lot of flexibility to determine the reserve value for insurance liabilities (one of the reasons for introducing IFRS 17). The reserve value reported under current IFRS is usually grandfathered from earlier accounting standards, such as Dutch GAAP. In general, these reserves can be defined as the present value of future benefits, where the technical interest rate and the assumptions for mortality are locked-in at pricing.
However, insurers are required to perform liability adequacy testing (LAT), where they compare the reserve values with the future cash flows calculated with ‘market consistent’ assumptions. As part of the market consistent valuation, insurers are allowed to include a compensation for bearing risk, such as the risk adjustment. Therefore, the biggest impact on the reserve value is expected from the introduction of the CSM.
The IASB has defined a hierarchy for the approach to measure the CSM at transition date. The preferred method is the ‘full retrospective application’. Under this approach, the insurer is required to measure the insurance contract as if the standard had always applied. Hence, the value of the insurance contract needs to be determined at the date of initial recognition and consecutive changes need to be determined all the way to transition date. This process is outlined in the following case study.
A case study
The impact of the new IFRS standards is analyzed for the following policy:
- The policy covers the risk that a mortgage owner deceases before the maturity of the loan. If this event occurs, the policy pays the remaining notional of the loan.
- The mortgage is issued on 31 December 2015 and has an initial notional value of € 200,000 that is amortized in 20 years. The interest percentage is set at 3 per cent.
- The policy pays an annual premium of € 150. The annual estimated costs of the policy are equal to 10 per cent of the premium.
In the case of this policy, an insurer needs to capitalize for the risk that the policy holder’s life expectancy decreases and the risk that expenses will increase (e.g. due to higher than expected inflation). We assume that the insurer applies the SII standard formula, where the total capital is the sum of the capital for the individual risk types, based on 99.5 per cent VaR approach, taking diversification into account.
The cost of capital would then be calculated as follows:
- Capital for mortality risk is based on an increase of 15 per cent of the mortality rates.
- Capital for expense risk is based on an increase of 10 per cent in expense amount combined with an increase of 1 per cent in the inflation.
- The diversification between these risk types is assumed to be 25 per cent.
- Future capital levels are assumed to be equal to the current capital levels, scaled for the decrease in outstanding policies and insurance coverage.
- The cost-of-capital rate equals 6 per cent.
At initiation (i.e. 2015 Q4), the value of the contract under the new standards equals the sum of:
- Block 1: € 482
- Block 2: minus € 81
- Block 3: minus € 147
- Block 4: minus € 254
Consecutive changes
The insurer will measure the sum of blocks 1, 2 and 3 (which we refer to as the fulfilment cash flows) and the remaining amount of the CSM at each reporting date. The amounts typically change over time, in particular when expectations about future mortality and interest rates are updated. We distinguish four different factors that will lead to a change in the building blocks:
Step 1. Time effect
Over time, both the fulfilment cash flows and the CSM are fully amortized. The amortization profile of both components can be different, leading to a difference in the reserve value.
Step 2. Realized mortality is lower than expected
In our case study, the realized mortality is about 10 per cent lower than expected. This difference is recognized in P&L, leading to a higher profit in the first year. The effect on the fulfilment cash flows and CSM is limited. Consequently, the reserve value will remain roughly the same.
Step 3. Update of mortality assumptions
Updates of the mortality assumptions affect the fulfilment cash flows, which is simultaneously recognized in the CSM. The offset between the fulfilment cash flows and the CSM will lead to a very limited impact on the reserve value. In this case study, the update of the life table results in higher expected mortality and increased future cash outflows.
Step 4. Decrease in interest rates
Updates of the interest rate curve result in a change in the fulfilment cash flows. This change is not offset in the CSM, but is recognized in the other comprehensive income. Therefore a decrease in the discount curve will result in a significant change in the insurance liability. Our case study assumes a decrease in interest rates from 2 per cent to 1 per cent. As a result, the fulfilment cash flows increase, which is immediately reflected by an increase in the reserve value.
The impact of each step on the reserve value and underlying blocks is illustrated below.
Onwards
The policy will evolve over time as expected, meaning that mortality will be realized as expected and discount rates do not change anymore. The reserve value and P&L over time will evolve as illustrated below.
The profit gradually decreases over time in line with the insurance coverage (i.e. outstanding notional of the mortgage). The relatively high profit in 2016 is (mainly) the result of the realized mortality that was lower than expected (step 2 described above).
As described before, under the full retrospective application, the insurer would be required to go all the way back to the initial recognition to measure the CSM and all consecutive changes. This would require insurers to deep-dive back into their policy administration systems. This has been acknowledged by the IASB by allowing insurers to implement the standards three years after final publication. Insurers will have to undertake a huge amount of operational effort and have already started with their impact analyses. In particular, the risk adjustment seems a challenging topic that requires an understanding of the capital models of the insurer.
Zanders can support in these qualitative analyses and can rely on its past experience with the implementation of Solvency II.
Hedge accounting changes under IFRS 9
On 31 October 2017, the European Banking Authority (EBA) published a consultation paper on the update of its ‘Guidelines on the management of interest rate risk arising from non-trading book activities’.
Cross-currency interest rate swaps (CC-IRS), options, FX forwards and commodity trades are just a few examples of financial instruments which will be affected by the upcoming changes. The time value, forward points and cross-currency basis spread will receive different accounting treatment under IFRS 9. Within Zanders, we feel the need to clarify these key changes that deserve as much awareness as possible.
1. Accounting for the forward element in foreign currency forwards
Each FX forward contract possesses a spot and forward element. The forward element represents the interest rate differential between the two currencies. Under IFRS 9 (similar to IAS 39), it is allowed to designate the entire contract or just the spot component as the hedging instrument. When designating the spot component only, the change in fair value of the forward element is recognised in OCI and accumulated in a separate component of equity. Simultaneously, the fair value of the forward points at initial recognition is amortised, most expected linearly, over the life of the hedge.
Again, this accounting treatment is only allowed in case the critical terms are aligned (similar). If at inception the actual value of the forward element exceeds the aligned value, changes in the fair value based on the aligned item will go through OCI. The difference between the fair value of the actual and aligned forward elements is recognized in P&L. In case the value of the aligned forward element exceeds the actual value at inception, changes in fair value are based on the lower of aligned versus actual and go to OCI. The remaining change of actual will be recognized in P&L.
Please refer to the example below:
In this example, we consider an entity X which is hedging a future receivable with an FX forward contract.
MtM change of the forward = 105,000 (spot element) + 15,000 (forward element) = 120,000.
MtM change of the hedged item = 105,000 (spot element) + 5,000 (forward element) = 110,000.
We look at alternatives under IAS39 and IFRS9 that show different accounting methods depending on the separation between the spot and forward rates.
Under IAS39 and without a spot/forward separation, the hedging instrument represents the sum of the spot and the forward element (105 000 spot + 15 000 forward= 120 000). The hedged item consisting of 105 000 spot element and 5 000 forward element and the hedge ratio being within the boundaries, the minimum between the hedging instrument and hedged item is listed as OCI, and the difference between the hedging instrument and the hedged item goes to the P&L.
However, with the spot/forward separation under IAS39, the forward component is not included in the hedging relationship and is therefore taken straight to the P&L. Everything that exceeds the movement of the hedged item is considered as an “over hedge” and will be booked in P&L.
Line 3 and 4 under IFRS9 characterise comparable registration practices than under IAS39. The changes come in when we examine line 5, where the forward element of 5 000 can be registered as OCI. In this case, a test on both the spot and the forward element is performed, compared to the previous line where only one test takes place.
2. Rebalancing in a commodity hedge relation
Under influence of changing economic circumstances, it could be necessary to change the hedge ratio, i.e. the ratio between the amount of hedged item and the amount of hedging instruments. Under IAS 39, changes to a hedge ratio require the entity to discontinue hedge accounting and restart with a new hedging relationship that captures the desired changes. The IFRS 9 hedge accounting model allows you to refine your hedge ratio without having to discontinue the hedge relationship. This can be achieved by rebalancing.
Rebalancing is possible if there is a situation where the change in the relationship of the hedging instrument and the hedged item can be compensated by adjusting the hedge ratio. The hedge ratio can be adjusted by increasing or decreasing either the number of designated hedging instruments or hedged items.
When rebalancing a hedging relationship, an entity must update its documentation of the analysis of the sources of hedge ineffectiveness that are expected to affect the hedging relationship during its remaining term.
Please refer to the example below:
Entity X is hedging a forecast receivable with a FX call.
MtM change of the option = 100,000 (intrinsic value) + 40,000 (time value) = 140,000.
MtM change of the hedged item = 100,000 (intrinsic value) + 30,000 (time value) = 130,000.
In example 3, we consider entity X to be hedging a forecast receivable via an FX call. Note that under IAS39 the hedged item cannot contain an optionality if this optionality is not present in the underlying exposure. Hence, in this example, the hedged item cannot contain any time value. The time value of 30,000 can be used under IFRS9, but only by means of a separate test (see row 5).
In line 1, we can see that without a time-intrinsic separation, the hedge relationship is no longer within the 80-125% boundary; therefore, it needs to be discontinued and the full MtM has to be booked in the P&L. In line 2, there is a time-intrinsic separation, and the 40 000 representing the time value of the option are not included in the hedge relationship, meaning that they go straight to the P&L.
Under IFRS9 with no time-intrinsic separation (line 3), the hedging relationship is accounted for in the usual manner, as the ineffectiveness boundary is not applicable, with 100 000 going representing OCI, and the over hedged 40 000 going to the P&L.
However, the time-intrinsic separation under IFRS9 in line 4 is similar to line 2 under IAS39, in which we choose to immediately remove the time value for the option from the hedging relationship. We therefore have to account for 40 000 of time value in the P&L.
In the last line, we separate between time and intrinsic values, but the time value of the option is aimed to be booked into OCI. In this case, a test on both the intrinsic and the time element is performed. We can therefore comprise 100 000 in the intrinsic OCI, 30 000 in the time OCI, and 10 000 as an over hedge in the P&L.
4. Cross-currency basis spread are considered a cost of hedging
The cross-currency basis spread can be defined as the liquidity premium of one currency over the other. This premium applies to exchanges of currencies in the future, e.g. a hedging instrument like an FX forward contract. If a cross currency interest rate swap is used in combination with a single currency hedged item, for which this spread is not relevant, hedge ineffectiveness could arise.
In order to cope with this mismatch, it has been decided to expand the requirements regarding the costs of hedging. Hedging costs can be seen as cost incurred to protect against unfavourable changes. Similar to the accounting for the forward element of the forward rate, an entity can exclude the cross-currency basis spread and account for it separately when designating a hedging instrument. In case a hypothetical derivative is used, the same principle applies. IFRS 9 states that the hypothetical derivative cannot include features that do not exist in the hedged item. Consequently, cross-currency basis spread cannot be part of the hypothetical derivative in the previously mentioned case. This means that hedge ineffectiveness will exist.
Please refer to the example below:
In example 4, we consider an entity X hedging a USD loan with a CCIRS.
MtM change of CCIRS = 215,000 – 95,000 (cross-currency basis) = 120,000.
MtM change hedged = 195,000 – 90,000 (cross-currency basis) = 105,000.
Under IAS39, there is only one way to account for CCIRS. The full amount of 120 000 (including the – 95 000 cross-currency basis) is considered as the hedging instrument, meaning that 105 000 can be listed as OCI and 15 000 of over hedge have to go to the P&L.
Under IFRS9, there is the option to exclude the cross-currency basis and account for it separately.
In line 2, we can see the conditions under IFRS9 when a cross-currency basis is included: the cross-currency basis cannot be comprised in the hedged item, so there is an under hedge of 75 000.
In line 3, we exclude the cross-currency basis from the test for the hedging instrument. By registering the MtM movement of 195 000 as OCI, we then account for the 95 000 of cross-currency basis, as well as -/- 20 000 of over hedge in the P&L. In line 4, the cross-currency basis is included in a separate hedge relationship – we therefore perform an extra test on the cross-currency basis (aligned versus actual values) . From the first test, -/- 195,000 is registered as OCI and -/- 20,000 (“over hedge” part) in P&L; from the cross-currency basis test 90,000 represents OCI and 5,000 has to be included in P&L.