Topic 7: Systems & Governance Flashcards
Creating TSY policy
* Describe limits for Currency & Rates (5), Funding (6)
Currency & Rates
- Balances per currency
- Tenor
- Hedging profile
- VaR
- Instruments Used
Funding
- Maturity
- Max tenor
- Annual refinancing
- Markets / countries
- Gearing
- Rating agency triggers
Creating TSY policy
* Describe limits for Investments (4), Credit (5)
Investments
- Tenor
- Instrument max
- % of market size
- What type of instruments
Credit
- Exposure per counterparty
- Exposure per country
- Tenor per counterparty
- Concentration limit
- Type of instrument
Controls
- Style
- Why
- Style -
- Preventative vs detective
- Why
- Minimise risk of error
- Minimise likelihood of fraud
- Minimise chance of unathorised activity
- Ensure compliance with policy and expected risk outcome
- Ensure clarity in roles and responsibilities
List Organisational controls (8)
- Full segregation of duties
- Trained back up for key staff
- Independent oversight (senior mgmt, middle office, audit)
- Forced annual leave
- Experienced staff
- Remuneration based on role and experience
- Ongoing training
- List of authorised dealers
Operational Controls (8)
Operational COntrols
- Documented policy, limits and authorities
- Detailed procedures & processes
- Fully operational business continuity process
- Adequate systems for exposure
- Phone calls recorded
- Straight through processing
- SSIs and dealmatching in real time
- Physical security (eg pass card)
- Describe Treasury Policy (2)
* Key Inclusions (10)
- Describe Treasury Policy
1. Sets guidelines to drive daily activities and risk appetite
2. Approved by Board, endorsed on annual basis (living doc) - Key Inclusions
1. Risk mgmt philosophy & objectives
2. Risk exposures & tolerance
3. Approved instruments
4. Roles & responsibilities
5. Limits
6. Credit framework (may be sep doc)
7. Oversight / breach framework
8. Reporting requirements
9. Benchmarking
10. Approved markets
Current large scale recent scandals (3)
- LIBOR rate rigging
- BBSW rigging
- FX rate fixing
Impacts from external environment LIBOR fixing (background - 6)
LIBOR fixing (background - 6)
- Major b/m for lending & swaps, underpins USD 350tn in derivs
- Major banks admitted manipulating rates betw 2005 / 2010
- One banker claimed went on since 1991
- Multiple investigations (US, Canada, UK, Swiss)
- UK Serious Fraud Office
- Every bp move, a couple of million profit
Impacts from external environment
BBSW rate rigging (6)
- A$350bn in loans & bonds priced off BBSW plus IRS & CCFX
- 2013, UBS voluntarily disclosed to ASIC
- BNP SIngapore, 2007 to 2010 expressed preferences on direction / level of rate submissions
- Process to calc BBSW changed late 2012
- ASIC considered market impact insignificant initially, penalties totalled A$3.6m. Now has reconsidered impact
- ASIC investigation ongoing - banks “defensive & legalistic”
Impacts of external environment
FX Daily Rate Fixing
Impacts from External Environment
FX daily rate fixing
1. June 2013 but prob was going on for a decade
2. Regulators in Asia, Switzerland, UK, Europe, US
3. 4 banks control over 50% of currencies traded
4. Banks accused of
- rigging daily FX fixings
- Front running customers orders
- Sharing info on open positions
Impacts of External environment
- What can Treasurer do re rate fixings?
- Watch pricing / exposures landing on a common date / time
2. Avoid 4pm rate fix, avoid too many rate sets on same day…
Treasury Reporting (7)
Treasury Reporting (7)
- What to report, to who, how often
- Establish data source
- Who should prepare
- 3 aspects: governance / performance / communication
- Market commentary should be done by front office, but all governance / performance prepared by independent party (middle office)
- Level of detail decreases with seniority of recipient
- Full detail vs exception based?
Treasury Reporting - FUnding updates (10)
Treasury Reporting - FUnding updates (10)
- Capital markets update
- BOrrowing capacity
- Maturity profile
- RE-financing profile
- Cost of funds
- Liquidity forecast
- Borrowing requirements
- Activity against borrowing mandates
- Exposure against rating metrics
- Exposure against internal metrics
Measuring Treasury Performance (10)
- # bank accounts, Overnight Cash balance, trapped cash
- CF accuracy, achieved rate (interest & FX)
- Return on funds invested
- Credit margin on bond issuance, average credit spread on CP balance
- Mix fixed / floating exposure
- Average maturity / duration
- Spread of business
- Failed payments, deal input error, limit breaches
- Hedge effectiveness
- Credit rating
Treasury Systems (3)
- Stand alone or Excel or outsource (depends on size/complexity)
- Can be integrated into bank platforms, market data systems, confirmation systems & accounting
- Provide audit trail, workflows