Intraday liquidity survey
Zero sum. Real time.
Intraday liquidity is a fresh challenge every 24 hours. With new safeguards in effect, Deloitte surveyed banks’ ability to comply.
Are banks ready?
Large banks have had years to adapt to US regulations and international standards that govern liquidity reserve requirements, monitoring, and reporting on a large scale. Now, similar standards apply to intraday liquidity.
Amid all the other evolving regulatory challenges they face, how well are banks progressing toward compliance with these new standards? What are their capabilities, and how much emphasis are they putting on the job?
About the survey
Deloitte surveyed representatives from 15 of the largest US bank holding companies (BHCs) and foreign banking organizations (FBOs) to learn more about their institutions’ approach and capabilities in the area of intraday liquidity risk management. The survey focused on five key topics:
Regulatory requirements and readiness: Do banks understand the new rules, and have they set up formal initiatives to address them?
Drivers and challenges: Are banks addressing intraday liquidity only because they must, or are there strategic considerations?
Roles and responsibilities: What are the governance and operating models, and who owns the decisions?
Processes and reporting: How—and how frequently—do banks calculate their intraday positions? What goes into those calculations, and how do they interact with stress-testing methodology?
Technology: What platforms will it take to satisfy the new requirements, and how do present systems compare?
Based on some of the data these questions generated, a scoring methodology divided institutions into “most mature” and “less mature” categories of readiness. This categorization led to some of the most notable survey results:
- For most banks, activities related to intraday liquidity are spread across several different groups, while the most mature banks have shifted these responsibilities solely to treasury and risk.
- At both maturity levels, low quality of data and challenges in data technology capabilities were a consistent finding.
- Some banks actually view collateral management as distinct from intraday liquidity management, and have devoted minimal focus to automation of those functions.
Overall, the banks showed widely varying degrees of readiness to address the existing and upcoming regulations around intraday liquidity monitoring, management, and reporting. Factors that appeared to determine a bank’s level of capability included their understanding of regulatory requirements across different jurisdictions, the organizational and management focus they brought to the topic, and simple timing.
Download the full survey report to explore the results.
If you’re interested in learning more, please contact us. We’d be happy to schedule a meeting with you and your team.
Joan P. Cheney