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It’s three years since the Basel Committee published their BCBS248 requirements, which outlined the need for banks across the world to report formally on their intraday liquidity positions. This is a big deal for banks, requiring a complete rethink of their approach to liquidity management, with many questions asked of a bank’s data and technology capabilities.
But here is the confusing thing, how much pain (or gain?) a bank is currently feeling from BCBS248 is little to do with the bank’s business model and all to do with where in the world the banks sits.
How can that be? After all, just like its liquidity big brother Basel III, BCBS248 will cover the entire globe once fully adopted.
Those last three words are important, as what I am seeing in all my interactions with firms across the world, is that rollout of the BCBS248 regime is incredibly patchy and different regulators have differing priorities for BCBS248 regime and intraday liquidity risks in general.
There is little information available in the public domain as to individual regulator timetables and their detailed requirements, so defining the regulatory landscape is more of an art than a science.
There are a handful of territories where the regulator requires BCBS248 monitoring today:
Often the regulator will build up the BCBS248 pressure on firms in private, but I am already aware of two territories where banks are being asked to report by the end of 2016, and I am sure that more will move in the next few months:
There are many territories where the regulator has dusted off the 2008 Sound Principles for Liquidity Management, where Principle 8 says “A bank should actively manage its intraday liquidity positions and risks”.
This can actually be a much more powerful lever for the regulators than BCBS248 compliance, as it means the bank must know its intraday indicators in real-time rather than weeks after the event!
I would include the following territories as falling into this category, although how aggressively the regulator utilises this lever is open to debate, it appears to vary by bank within a particular territory.
The position in the US is a little mixed, there is very little said in public about the BCBS248 regime currently, but the Fed is certainly putting significant pressure on the biggest banks to improve intraday capabilities.
A good example is SR14-1, where the Recovery and Resolution Preparedness regime is forcing the largest banks to up their game in their use and provision of intraday information. And the rumour on the street is that during 2016 the Fed put out formal guidance on BCBS248 and how they will implement the regime.
The story in Europe is frustrating to those who want regulatory support to drive intraday improvements. Up until recently the EBA appeared to be moving to a 2016 drive for compliance across the bulk of Europe. But then budget pressures forced their intraday regime into their 2017 work programme. Expect other territories to follow the UK PRA, by implementing temporary arrangements while waiting for a Europe-wide common approach.
Unless there is a major about-turn, then all regulators will adopt BCBS248, not just those mentioned above. It is just a question of when. So wherever the bank is regulated, there will be no hiding place.
And one thing that is for sure, once your regulator fires that starting pistol, ignorance of the agenda will be a poor enough excuse for failing to hit the timetable. All banks have been aware of the regime for three years already, and should be on top of their intraday liquidity risks now as part of good management practice.
So far, all the regulators that have implemented their own interpretation of the requirements have stayed pretty close to the BCBS248 guidance. If a bank in a ‘late adopter’ territory could today populate the example reporting templates in the BCBS248 paper, then they would be well on the way to satisfying their regulator when their time comes.
In my next post I will talk about the best regulatory guidance I have seen on BCBS248, so practitioners can start to get on top of what they need to do next.