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Risk Management Program · CoreTrack
1Risk, Treasury & Financial Control
iRisk Foundations
Risk Appetite, Tolerance, Capacity…The Risk Taxonomy and UniverseRisk Register vs Risk MatrixStress TestingScenario Analysis vs Stress TestingImpact and LikelihoodLikelihoodThe Risk EventRisk Assessment
iiEnterprise Risk Management
Enterprise Risk ManagementThe Four Risk TreatmentsRisk CultureRisk MaturityRisk Monitoring
iiiRisk Governance
Risk GovernanceHow to set a…The Risk PolicyThe Risk OwnerThe Risk Committee and Its CharterThe Risk Limit FrameworkRisk EscalationHow to set a…
ivCredit and Counterparty Risk
Collateral AgreementsCollateral vs NettingProbability of DefaultExposureCounterparty ExposureConcentration Risk vs Wrong Way RiskCounterparty Risk vs Credit RiskHow to assess Counterparty ExposureHow to assess Concentration Risk
vMarket Risk
Market RiskSensitivity MeasuresThe Hedging PolicyInterest Rate Risk in the Banking BookIRRBB vs Market RiskExpected ShortfallEconomic Value of EquityVaR BacktestingOpen PositionValue at RiskValue at Risk and Expected ShortfallEconomic Value SensitivityFX ExposureValue at Risk vs Expected ShortfallEarnings at Risk vs…FX Transaction Risk vs…How to measure Interest…How to measure Foreign…
viLiquidity Risk
Liquidity Stress TestingLiquidity Gap vs Liquidity BufferMaturity MismatchThe Debt Maturity ProfileFunding ConcentrationSurvival HorizonThe Contingency Funding PlanNet Stable Funding RatioLiquidity Risk vs Funding RiskLiquidity Coverage RatioLiquidity Gap and BufferHow to run a Liquidity Gap Analysis
viiOperational Risk
Operational LossThe Loss EventRisk and Control Self AssessmentException ManagementInformation Security as a…Segregation of DutiesIssue ManagementThe Near MissRoot Cause Analysis in RiskThe Fraud TriangleCyber Risk vs Third Party RiskHow to run a…How to assess Third…
viiiRisk Reporting, Data and Model Risk
Model RiskModel Validation vs BacktestingHow to run Model ValidationData Governance in RiskModel Risk vs Data RiskKey Risk IndicatorsManagement InformationRisk ReportingRisk ScoreEarnings at RiskRisk Adjusted ReturnEarly Warning IndicatorsHow to build a KRI Dashboard
ixTreasury
Corporate TreasuryAsset Liability ManagementIntragroup FundingThe Treasury PolicyThe Treasury Management SystemThe Cash ForecastCash Pooling and ConcentrationHow to build a Cash Forecast
xFinancial Controls and Assurance
Control AssuranceThe Control LifecycleThe Assurance MapThe Audit FindingIssue RemediationInternal Financial ControlsControl Design vs Control EffectivenessHow to map Internal Financial ControlsHow to test Control…Control DeficiencyMaterial Weakness
xiOperational Resilience
Operational ResilienceBusiness Continuity and Disaster RecoveryBusiness Continuity vs Operational…Crisis ManagementDisaster RecoveryIncident Management

Asset Liability Management: Matching the Two Sides

Asset liability management is the standing job of matching what a bank holds against what it owes, on two axes at once: when each side falls due, and when each side reprices. Asset liability management is a function rather than a measure. A committee runs it, and because a large part of a bank's deposits carry no contractual maturity at all, the matching runs on behavioural assumptions that same committee decides.

Two things have to be accepted before the rest of the subject makes sense. The first is that a bank borrows short and lends long as a matter of choice, and that the mismatch this creates earns the bank its living rather than marking an error inside it. The second is smaller and harder: where a contract does not say when money leaves, somebody has to assume it, and an assumption is a decision made by named people at a named meeting. Everything difficult in asset liability management comes out of that second sentence.

Why does matching stand inside a bank?

A corporate treasury lives inside an operating business, and Nirjhar Industries Limited, an invented steel and alloys group, is one. Matching the two sides of a balance sheet is a bank's problem in a way it is simply not a steel maker's. A steel maker funds itself and then goes and makes steel; its balance sheet is the scaffolding around an operating business. A bank has no operating business behind the balance sheet. The balance sheet is the business. A bank holds somebody else's promise to pay, owes its own promise to pay, and takes the whole of its earnings from the difference between the two. A balance sheet that is itself the business is why asset liability managementThe standing function of matching what an institution holds against what it owes, by when each side falls due and when each side reprices. is a named standing function inside a bank and a paragraph in a policy inside most companies.

The bank throughout is Vindhya Commercial Bank Limited, an invented commercial bank with a balance sheet of Rs 96,000 crore. Every ratio, factor and limit that follows is Vindhya's own working number, set by Vindhya's own committees, rather than a rule Indian banking imposes on anybody.

What are the two sides, and what is each one made of?

The phrase "the two sides" gets used so loosely that people stop looking at what is actually in them, so start with the object itself. Vindhya's assets total Rs 96,000 crore and its liabilities and equity total the same Rs 96,000 crore. Balancing to the rupee is arithmetic rather than achievement. The shape inside each side is what matters. On the asset side, Rs 57,600 crore of net advances is money that will come back over years and on dates the bank agreed with borrowers; on the liability side, Rs 36,000 crore of current and savings balances is money that can walk out this afternoon. A book of agreed dates funded by a book with no dates at all is the whole subject in one sentence.

BOTH SIDES ARE Rs 96,000 CRORE AND ONLY ONE OF THEM HAS DATES ON IT Vindhya Commercial Bank Limited, invented. Rs crore. Every figure is the bank's own and none is a requirement or a market figure. ASSETS, Rs 96,000 CRORE 26,400 57,600 Cash and bank balances Rs 7,200 crore Investments Rs 26,400 crore Advances, net of provisions Rs 57,600 crore Fixed and other assets Rs 4,800 crore LIABILITIES AND EQUITY, Rs 96,000 CRORE 36,000 29,280 11,520 Current and savings balances Rs 36,000 crore Term deposits, retail Rs 29,280 crore Term deposits, wholesale Rs 11,520 crore Borrowings Rs 8,400 crore Other liabilities and provisions Rs 3,120 crore Equity Rs 7,680 crore NOT ONE CONTRACT IN THIS Rs 36,000 CRORE BLOCK STATES A DATE 46.9 per cent of the bank's Rs 76,800 crore of deposits, repayable whenever the customer asks, and every table the bank builds still has to place it somewhere.
Laid out to the same scale, the two sides balance to the rupee and share none of the same certainty: the asset side carries agreed dates almost all the way across, while a bright green quarter of the liability side carries none at all and still has to be placed in every table the bank builds.

Look at that bright green block again. The block is the reason this subject is hard. Rs 9,600 crore of current account balances and Rs 26,400 crore of savings balances add to Rs 36,000 crore of non-maturity depositsA balance the customer may take at any time, so no contract anywhere says when it leaves., being 46.9 per cent of the bank's Rs 76,800 crore deposit book. Every one of those rupees is contractually repayable on demand. Nothing anywhere says when they leave, so the bank cannot look it up. And yet the bank has to build tables that place them somewhere, and every table it builds has a different reason for placing them.

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What are the two axes, and why is answering one not answering the other?

Matching sounds like one activity and it is two. An ordinary rent agreement shows why. The landlord fixes the rent for eleven months, so the date on which the price can change is known exactly. The tenant can also give a month's notice and leave. The reset date and the exit date are two different dates about one contract, and knowing one of them tells nothing at all about the other. A bank's balance sheet is thousands of contracts with exactly that property, and so it gets matched on two axes.

Axis one asks when the money leaves. The question is about cash: on any given day, is enough coming in to cover what is going out? The cash question is what the bank's maturity ladderThe table that asks when cash leaves, bucket by bucket, from the shortest period to the longest. is for, and Vindhya sets it out in eight buckets it numbers LB1 to LB8, from the first fortnight out to beyond five years. Get this axis wrong and the bank runs out of cash. Running out of cash is the failure that kills a bank in days rather than years.

Axis two asks when the rate changes. The question is about pricing: when the level of interest rates moves, how much of each side follows it, and how quickly? The pricing question is what the bank's repricing ladderThe table that asks when the rate on a balance changes, bucket by bucket, whether or not the balance itself goes anywhere. is for, in eight buckets numbered RB1 to RB8. Get this axis wrong and the bank does not run out of cash at all. The bank simply earns less than it planned, or the value of what it holds falls further than the value of what it owes, and both of those show up in a report rather than at a counter.

ONE DEPOSIT BOOK, TWO QUESTIONS, TWO COMPLETELY DIFFERENT PICTURES Vindhya Commercial Bank Limited, invented. The bright green marks where the same Rs 36,000 crore of current and savings balances is placed. AXIS ONE: WHEN DOES THE MONEY LEAVE? The maturity ladder, buckets LB1 to LB8 AXIS TWO: WHEN DOES THE RATE CHANGE? The repricing ladder, buckets RB1 to RB8 Rs 34,200 crore Rs 1,800 crore 5.0 per cent of it LB1 LB2 LB3 LB4 LB5 LB6 LB7 LB8 shortest longest Rs 36,000 crore the whole of it, in one bucket RB1 RB2 RB3 RB4 RB5 RB6 RB7 RB8 soonest latest SAME MONEY. SAME MONTH. SAME BANK. TWO PICTURES. Neither table is wrong. They are placed differently because a question about when cash walks out is not a question about when a rate resets.
Set side by side, the same Rs 36,000 crore appears as a sliver at the front and a slab at the back in the cash table, and as one solid block in the middle of the pricing table, which is what it looks like when a single balance is answering two unrelated questions.
Try it out

What are the two axes a bank matches its balance sheet on?

Why can a bank not simply match every asset to a liability of the same length?

Here is the question every reader asks at this point, and it deserves a straight answer rather than a shrug. If the mismatch causes all this trouble, why not fund a ten year loan with a ten year deposit and be done with it? Somebody could build that bank. Such a bank would be extremely safe and it would be pointless.

Think about the street corner. A moneylender who borrows from one person on Monday and lends the identical amount to another person on Monday, for the identical period, at the identical date, is not really doing anything except passing an envelope along and taking a small fee for the trouble. People need something different from a bank on each side. Depositors want their money available; borrowers want years. The bank stands between two populations who want opposite things, and the whole of its economic reason to exist is that it is willing to hold the difference between them. The willingness to hold that difference is what people mean by maturity transformation, and it is managed rather than removed.

THE MISMATCH IS NOT THE PROBLEM, IT IS THE PRODUCT Vindhya Commercial Bank Limited, invented. Bar lengths are illustrative of typical duration and are not a measured figure. THE BANK AS IT IS THE PERFECTLY MATCHED BANK the transformation WHAT IT OWES, short WHAT IT HOLDS, long The gap is the risk and the earnings Managing it is the job. Removing it is not. nothing here WHAT IT OWES WHAT IT HOLDS Very safe, and nobody needs it Depositors wanted access. Borrowers wanted years. Rs 2,880 CRORE OF NET INTEREST INCOME COMES OUT OF THE LEFT-HAND SHAPE A 3.00 per cent net interest margin on Rs 96,000 crore of assets, for one year, at this invented bank. Flatten the shape and part of that margin goes with it.
Putting the two shapes together shows why nobody builds the safe version: the shaded difference on the left is simultaneously the exposure the bank has to manage and the reason anybody pays it, and squaring the two bars on the right empties the box without leaving anything in its place.
Try it out

A bank matches every asset exactly to a liability of the same maturity. What has it done to itself?

Who actually does the matching, and what does that committee decide?

Asset liability management is not a spreadsheet and it is not a person. Asset liability management is a standing meeting with a mandate, and at Vindhya that meeting is the asset liability management committee, numbered G4 in the bank's own governance list. G4 has 9 members, it meets every month, and it is chaired by the chief executive. A chief executive in the chair shows how the bank rates the meeting: this is not a technical review passed down to a specialist. Devendra Achar, head of treasury, sits on it and runs the day to day position between meetings.

Now the part people skip. G4 does not compute the measures. The measures are computed by people with models, and G4 reads them. G4 does one thing nobody else in the bank does: it sets the behavioural assumptions those measures are computed on. Two of them matter enormously and run through the rest of this guide: the average life the bank assumes for its Rs 36,000 crore of non-maturity deposits when it works out what a rate move does to value, and the share of that same Rs 36,000 crore the bank places in the shortest maturity bucket LB1. Both are decisions. Neither is a measurement. Both are taken by the 9 people in that room, once a month.

Compare that with the board risk management committee, numbered G2. G2 has 5 members, 3 of them independent directors, meets six times a year, is chaired by an independent director, and sets every limit the bank runs against, L1 through L12. So one committee sets the assumptions and a different committee sets the tests. Hold that thought.

What a matching paper has to contain

A committee is only as good as the paper in front of it, and a matching paper has four fixed parts. Three of them get written every time because their absence is obvious. The fourth goes missing constantly. Its absence looks like tidiness rather than thinness.

THE FOUR PARTS OF A MATCHING PAPER, AND THE ONE THAT GOES MISSING The monthly paper to committee G4 at Vindhya Commercial Bank Limited, invented. The structure is the teaching point, not any figure in it. 1 THE POSITION Where the two sides stand this month, bucket by bucket, on both axes in 2 THE LIMITS IT RUNS AGAINST Limits L8, L9, L10 and L12, each with what is running against it in 3 WHAT CHANGED SINCE THE LAST MEETING Movement in each bucket, and the reason somebody gives for it in 4 THE ASSUMPTIONS EVERY FIGURE DEPENDS ON The deposit life, the slotting share, and what each figure would be without them often left out A PAPER WITHOUT PART FOUR READS LIKE A MEASUREMENT Parts one to three are numbers. Part four is what the numbers rest on. Drop it and every judgement in the pack arrives dressed as a fact.
Reading the four rows downward shows where the weakness sits: the three parts made of figures are always written because their absence is visible, while the part that records what the figures rest on is the only one whose omission makes the pack look cleaner rather than thinner.
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What is a behavioural assumption, and why does an answer depend on one?

An ordinary savings account makes the point. The holder can empty it this afternoon and nobody can stop them. The question worth asking is how much of it has actually moved in the last three years. For most households the honest answer is very little, and the balance that has sat there through two job changes and a wedding is behaving nothing like money that is about to leave. Contractually available and behaviourally likely to leave are two entirely different claims, and a ladder needs the second one.

The gap between the two claims is where a behavioural assumptionA decision about how money will actually move when the contract does not say, made by named people at a named meeting. lives. The bank cannot read the answer off a contract, so somebody decides it, and the deciding is called slottingPlacing a balance into a time bucket in a table, which is a judgement wherever the contract is silent about the date. when it puts a balance into a bucket of a table. A behavioural assumption is not a forecast anybody can check tomorrow. Vindhya's own model inventory numbers the behavioural deposit life model V1 and records it as one of three models never put through validation. The honest reason is uncomfortable: how long a deposit stays is only observable over years, so V1 cannot be tested next Tuesday.

So the bank is placing Rs 36,000 crore, being 46.9 per cent of its deposits, using a judgement it cannot check quickly, taken monthly by 9 people. Say it plainly and it sounds alarming. The practice is not alarming, only unavoidable. Every bank on earth does this, and the only question that separates a well run one from a badly run one is whether the judgement is written down, attributed to a named committee, and shown beside every number it decides.

Try it out

A savings account is repayable on demand. Why is the whole savings book not slotted into the shortest bucket?

Why does the same Rs 36,000 crore sit in four tables four different ways?

The part worth carrying away needs its warning first. The four tables ask four different questions, so one deposit book is treated four completely different ways inside one bank in one month, and all four treatments are correct. A reader who meets the second treatment without that warning concludes somebody has made a mistake, and nobody has.

The tableThe question it asksWhere the Rs 36,000 crore goes
The maturity ladder, buckets LB1 to LB8When does the cash actually leave?5.0 per cent into the shortest bucket LB1, being Rs 1,800 crore, and the remaining Rs 34,200 crore spread across the long buckets LB5 to LB8
The repricing ladder, buckets RB1 to RB8When does the rate on it change?The whole Rs 36,000 crore in bucket RB5, over one to three years
The economic value computationWhat does a rate move do to the value of the two sides?The whole Rs 36,000 crore given an average behavioural life of 0.5 years
The thirty day coverage computationHow much of it walks out in a severe thirty days?A blended 16.2 per cent assumed to run off, being Rs 5,820 crore

The fourth row is the one that surprises people, so here is where its number comes from. Vindhya's own thirty day assumptions treat the two halves of the non-maturity book differently: 7.5 per cent of the Rs 26,400 crore of savings balances, being Rs 1,980 crore, and 40.0 per cent of the Rs 9,600 crore of current balances, being Rs 3,840 crore. The two add to Rs 5,820 crore of assumed outflow. Divided by the Rs 36,000 crore book, the blended assumption is 16.2 per cent. Every one of those factors is this invented bank's own working number. None of them is a requirement, a market convention or a figure anybody must use, and what an Indian bank actually applies is a matter for the source named below.

The first row and the fourth row are the pair that does the teaching, so put them beside each other. The cash table assumes Rs 1,800 crore of that deposit book leaves in the first fortnight; the thirty day computation assumes Rs 5,820 crore of it leaves inside a month. The second assumption is 3.23 times the first as a rate, and the two differ by Rs 4,020 crore. Both sit in papers going to the same committee. Both are right. The first is the bank's view of an ordinary fortnight and the second is the bank's view of a severe month, and a reader who does not know that has every reason to think one of the two is a typing error.

ONE DEPOSIT BOOK OF Rs 36,000 CRORE, FOUR TABLES, FOUR TREATMENTS Vindhya Commercial Bank Limited, invented, at month 12. Every factor shown is the bank's own working number and none of them is a requirement. 1 THE MATURITY LADDER, LB1 TO LB8 Asks: when does the cash actually leave? LB1 LB2 LB3 LB4 LB5 LB6 LB7 LB8 Rs 1,800 crore in LB1 Rs 34,200 crore across LB5 to LB8 2 THE REPRICING LADDER, RB1 TO RB8 Asks: when does the rate change? off the top RB1 RB2 RB3 RB4 RB5 RB6 RB7 RB8 Rs 36,000 crore in RB5 alone Same scale as the card at left, so it runs off it 3 THE ECONOMIC VALUE COMPUTATION Asks: what does a rate move do to value? where the repricing table puts it 0 0.5 yr 1 yr 2 yr 3 yr Rs 36,000 crore at an average life of 0.5 years Set by committee G4, computed by model V1 4 THE THIRTY DAY COVERAGE COMPUTATION Asks: how much walks out in a severe month? Rs 5,820 crore, a blended 16.2 per cent Rs 1,800 crore, what card 1 assumes Rs 5,820 crore assumed out inside thirty days 7.5 per cent on savings plus 40.0 per cent on current FOUR TABLES. FOUR TREATMENTS. ONE Rs 36,000 CRORE. ALL FOUR DEFENSIBLE. Card 1 assumes Rs 1,800 crore of that book leaves in a fortnight. Card 4 assumes Rs 5,820 crore of it leaves in a severe month. That is 3.23 times the rate and a Rs 4,020 crore difference, and neither of them contradicts the other: one card is asking about an ordinary fortnight and the other about a severe month.
Placed in one frame, the four cards make the awkwardness visible rather than arguable: the same deposit book is a sliver in one table, a slab in the next, half a year of life in the third and Rs 5,820 crore of assumed flight in the fourth, and nothing about any card is wrong.
Try it out

How many different treatments does the same Rs 36,000 crore of non-maturity deposits get across this bank's own four tables?

There is one more thing worth noticing about the third card. The economic value computation gives that deposit book an average life of half a year. The repricing ladder puts the identical money in a bucket that runs from one year to three. The bank's own two tables therefore disagree about the same deposits by a factor of somewhere between two and six, and no document anywhere in the institution reconciles them. The measure that sits on top of the 0.5 year assumption, the change in the economic value of what the bank holds against what it owes, is computed separately. A number of that importance rests on an assumption 9 people set at a monthly meeting.

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How far would one assumption have to move before a limit is breached?

Everything so far has been description. Now watch the assumption do actual work, on the first of the four treatments and on the smallest of the four numbers.

Vindhya's shortest maturity bucket LB1, covering the first fortnight, shows inflows of Rs 7,200 crore against outflows of Rs 9,600 crore. The gap is minus Rs 2,400 crore, being 25.0 per cent of that bucket's outflows. The bank's own limit L9, set by committee G2, says the negative gap in LB1 does not exceed 28.0 per cent of that bucket's outflows. So the bucket sits at 89.3 per cent of its limit and the paper reports it as comfortable. Of the Rs 9,600 crore of outflows in that bucket, Rs 1,800 crore is there for no reason other than that committee G4 decided to put 5.0 per cent of the non-maturity deposit book into it. The other Rs 7,800 crore is contractual: term deposits maturing, borrowings falling due, payments the bank has committed to.

Now change nothing on the balance sheet. Not one rupee moves, not one customer does anything, not one contract is signed. Move only the slotting share, and call the amount the committee places in LB1 the slotted amount.

The buildAt the bank's own 5.0 per centAt the point the cap is reached
LB1 outflows other than the slotted deposits, held stillRs 7,800 croreRs 7,800 crore
Slotted amount from the Rs 36,000 crore deposit bookRs 1,800 croreRs 2,200 crore
LB1 outflowsRs 9,600 croreRs 10,000 crore
LB1 inflows, held stillRs 7,200 croreRs 7,200 crore
LB1 gapminus Rs 2,400 croreminus Rs 2,800 crore
Gap as a share of the bucket's outflows25.0 per cent28.0 per cent
The cap in limit L9, the bank's own28.0 per cent28.0 per cent
Utilisation of limit L989.3 per cent100.0 per cent
The slotting share this implies5.0 per cent6.1111 per cent

The second column takes three lines of algebra. With a slotted amount of Rs A crore, outflows are 7,800 plus A and the gap is 600 plus A, so the ratio the limit tests is (600 plus A) divided by (7,800 plus A). Setting that equal to 0.28 gives 600 plus A equals 2,184 plus 0.28A, so 0.72A equals 1,584 and A is Rs 2,200 crore. The forward check: outflows Rs 10,000 crore, gap minus Rs 2,800 crore, and 2,800 over 10,000 is 28.0 per cent to the rupee.

The whole distance between comfortable and breached is 1.1111 percentage points of a behavioural assumption, being Rs 400 crore of a Rs 36,000 crore deposit book. Be precise about what happens at the crossing itself. At exactly 6.1111 per cent the utilisation is exactly 100.0 per cent, the cap reached rather than exceeded, and anything beyond it is a breach. One committee, meeting monthly, moving one judgement by a hair, takes another committee's limit from a number nobody looks at twice to a number that has to be reported, explained and remediated. Nothing on the balance sheet has changed.

Try it out

The bank slots 5.0 per cent of its non-maturity deposits into the shortest bucket and sits at 89.3 per cent of limit L9. How far would that assumption have to move for the limit to reach its cap?

Play with it

Move one assumption and watch a comfortable limit reach its cap

One control: the amount of the Rs 36,000 crore non-maturity deposit book that committee G4 places in the shortest maturity bucket LB1, from Rs 0 crore to Rs 4,320 crore. One consequence: the LB1 negative gap as a share of that bucket's outflows, shown against the 28.0 per cent cap in limit L9. Everything else is held still: inflows stay at Rs 7,200 crore, the other Rs 7,800 crore of LB1 outflows stays where it is, and no other bucket moves. One control at a time is a simplification: a real ladder would move in several places at once. The default sits on the locked case at Rs 1,800 crore slotted, being 5.0 per cent, giving LB1 outflows of Rs 9,600 crore, a gap of minus Rs 2,400 crore, a ratio of 25.0 per cent and limit L9 at 89.3 per cent utilisation. The single crossing of the cap is at Rs 2,200 crore, being 6.1111 per cent, where outflows are Rs 10,000 crore and the gap is minus Rs 2,800 crore. The ratio rises all the way along, so there is exactly one crossing and no second one further out. Anywhere other than the locked Rs 1,800 crore, the slotted amount is a dial setting and is not a figure from the case.

Rs 0 CRORE SLOTTEDRs 1,800 CRORE, THE LOCKED CASERs 4,320 CRORE SLOTTED
The presets land on nothing slotted, on half the locked assumption, on the locked Rs 1,800 crore, on the Rs 2,200 crore where the cap is exactly reached, and on two settings beyond it.
ONE ASSUMPTION, ONE LIMIT, AND THE SHORT DISTANCE BETWEEN THEM Vindhya Commercial Bank Limited, invented. Limit L9 and its 28.0 per cent cap are the bank's own and neither is a requirement. 0 10 20 30 40 LB1 gap as a share of LB1 outflows, per cent BREACH ZONE LIMIT L9 CAP, 28.0 PER CENT the locked case: Rs 1,800 crore, 5.0 per cent the cap is reached at Rs 2,200 crore being 6.1111 per cent of the deposit book 0 1,080 2,160 3,240 4,320 Rs crore of the Rs 36,000 crore deposit book placed in bucket LB1 The thirty day computation assumes Rs 5,820 crore of the same book leaves, being 16.2 per cent, which is off the right of this scale LB1 OUTFLOWS Rs 9,600 crore LB1 INFLOWS Rs 7,200 crore, held still LB1 GAP Rs 2,400 crore dark green is the Rs 7,800 crore that does not move, bright green is the slotted deposits 25.0%
SLOTTED INTO LB1
Rs 1,800 crore
LB1 GAP
Rs 2,400 crore
GAP OVER OUTFLOWS
25.0 per cent
LIMIT L9 UTILISATION
89.3 per cent

Loading.

Educational illustration. Every figure is Vindhya Commercial Bank Limited's own invented number: the Rs 36,000 crore deposit book, the Rs 7,200 crore of LB1 inflows, the Rs 7,800 crore of other LB1 outflows and the 28.0 per cent cap in limit L9. None of them is a requirement, a market figure or a fact about any real bank. Amounts are held in whole rupees and shown in Rs crore.
Value at Risk and What It Hides teaches you to compute value at risk three ways, interpret the figure, and say precisely what it refuses to describe.

How does a limit set by one committee end up decided by another committee's assumption?

Both halves of the problem are now in place, and they belong together. The assumption that decides where the LB1 gap sits is set by committee G4, monthly, chaired by the chief executive. The limit that tests it, L9, is set by committee G2, six times a year, chaired by an independent director. The paper G2 reads carries the output of G4's decision and never the decision itself. G2 sees a bucket at 89.3 per cent utilisation. G2 does not see, anywhere in its pack, the sentence that says this number rests on a 5.0 per cent slotting judgement and would reach its cap at 6.1111 per cent.

THE NUMBER TRAVELS BETWEEN THE TWO COMMITTEES. THE JUDGEMENT DOES NOT. Vindhya Commercial Bank Limited, invented. Both committees are properly constituted and both papers are correct. PATH ONE: THE ASSUMPTION, DECIDED EVERY MONTH COMMITTEE G4 9 members, monthly chaired by the chief executive DECIDES THE ASSUMPTION 5.0 per cent placed into LB1 a 0.5 year deposit life for value THE NUMBER THAT COMES OUT LB1 gap at 25.0 per cent of outflows and one line in a monthly pack the number travels the judgement behind it never travels with it PATH TWO: THE TEST, SET SIX TIMES A YEAR COMMITTEE G2 5 members, six times a year 3 of them independent directors SETS THE TEST limit L9, a 28.0 per cent cap limit L8, on value READS THE UTILISATION 89.3 per cent, and calls it comfortable with no line of sight to the input NO SINGLE COMMITTEE SEES BOTH DECISIONS IN ONE PAPER
Following the two lanes across shows the shape of the problem exactly: one arrow carries a figure downward between the committees while the dashed line beside it carries nothing, so the body testing the number never meets the judgement that produced it.

Every control worked, every paper was correct, and the institution was still blind in one specific place

There is no person at fault here. Committee G4 was properly constituted and took its decision at a scheduled meeting with the chief executive in the chair. The assumption was recorded. The computation built on it was arithmetically correct. Committee G2 was properly constituted, read a correct paper, and reached a reasonable conclusion from what was in front of it. Nobody misled anybody and nothing was hidden.

The problem is not a missing control but a missing connection, and that is what a structural gapA weakness that exists between two mandates rather than inside either one, so no control inside either mandate can find it. means: a weakness that lives between two mandates rather than inside either one. G4 is not testing anything, so no control inside G4 can find it. G2 is not setting the assumption, so no control inside G2 can find it. The bank's forty two control findings for the year, every one of them real, contain nothing about this, and they are right not to. No control failed.

The cost is not a loss. The failure is one of decision quality, and it is worth naming exactly: a board level committee accepted a position as comfortable without being told what the position was most sensitive to. Whether the same shape sits behind limit L8 on the value side, where G4 sets the 0.5 year deposit life and G2 holds the limit, is left to the subject that computes that measure. The shape is identical.

FIVE THINGS THAT WORKED, AND THE ONE PLACE NONE OF THEM LOOKS Vindhya Commercial Bank Limited, invented. Nothing in the row below is a failure, which is the point of drawing it. Committee G4 properly constituted The assumption written down The computation arithmetically right Committee G2 properly constituted 42 findings raised elsewhere AND THE ONE INPUT THAT DECIDES THE ANSWER IS STILL NOT IN THE PAPER THAT TESTS IT It is not inside the first mandate, which sets assumptions and tests nothing. It is not inside the second, which sets tests and assumes nothing. A control can only look where it has been pointed, and nobody has a mandate that points at the space between two mandates.
Five green ticks above one dark panel is the honest picture of this weakness: it survives precisely because every checkable thing checks out, and the space it lives in belongs to neither committee that could have closed it.
Try it out

Which committee is at fault for the gap between the assumption and the limit it decides?

The fix is unglamorous and cheap. The fix is a single line added to part four of the paper: this figure is computed on a 5.0 per cent slotting assumption set by committee G4 on such and such a date, and it reaches its cap at 6.1111 per cent. No new committee, no new system, no new model. One sentence, placed beside the number it explains, in the pack of the body that reads it.

Breaking Into Quants Bootcamp — Fin Maverick

Who is accountable when the funding side concentrates?

Everything above has been about the asset side being long and the liability side being short. There is a second thing that goes wrong on the liability side and it has nothing to do with timing: the funding gets concentrated. At month 12 Vindhya has two live breaches of exactly that shape, and both of them have the same name attached.

Limit L10, the bank's own, caps wholesale funding at 20.0 per cent of total liabilities. Total liabilities are the Rs 96,000 crore balance sheet less Rs 7,680 crore of equity, being Rs 88,320 crore, so the cap in rupees is Rs 17,664 crore. Running against it are Rs 11,520 crore of wholesale term deposits plus Rs 8,400 crore of borrowings, being Rs 19,920 crore, or 22.6 per cent of liabilities. Divide the rupees rather than the percentages and utilisation is 112.8 per cent. The breach is B3, first crossed in month 11 at 21.4 per cent, and its cause is plain: retail term deposits ran off and the bank replaced them with certificates of deposit.

Limit L12 caps the top twenty depositors at 12.0 per cent of total deposits, being Rs 9,216 crore of the Rs 76,800 crore deposit book. The top twenty actually hold Rs 11,136 crore, being 14.5 per cent, so utilisation is 120.8 per cent. The breach is B4, crossed in month 10 when one state undertaking placed Rs 1,440 crore in a single deposit. Both breaches are concentrations in how the bank funds itself, one by funding type and one by depositor, and both were still open at month 12. Two breaches left open is not slackness. A breach caused by the structure of a balance sheet does not run off by itself the way a trading position does.

And both carry a name. Devendra Achar, head of treasury, is the risk ownerThe single named person accountable for a breach, so that the breach has an address rather than sitting with a department. of B3 and B4. Think about what a named owner changes. A table saying wholesale funding is at 22.6 per cent is information. A table saying wholesale funding is at 22.6 per cent, against a 20.0 per cent limit, and Devendra Achar is accountable for bringing it back, is an obligation with a person at the end of it.

TWO FUNDING BREACHES, ONE ADDRESS Vindhya Commercial Bank Limited, invented, at month 12. Both limits are the bank's own and neither is a requirement. BREACH B3, ON LIMIT L10 Wholesale funding share Cap Rs 17,664 crore, 20.0 per cent of liabilities Running Rs 19,920 crore, 22.6 per cent 112.8 per cent utilisation, crossed month 11 BREACH B4, ON LIMIT L12 Top twenty depositor share Cap Rs 9,216 crore, 12.0 per cent of deposits Running Rs 11,136 crore, 14.5 per cent 120.8 per cent utilisation, crossed month 10 RISK OWNER: DEVENDRA ACHAR, HEAD OF TREASURY Accountable for both, and both still open at month 12 A structural breach does not run off the way a trading position does, which is why these two are the ones still standing.
Drawing the two cards converging on one dark box makes the accountability visible rather than implied: two separate limits, two separate months, two separate causes, and a single person whose job it is to bring both back inside.
Try it out

Limits L10 and L12 are both breached. What do they have in common besides being open?

What can the committee actually do about a position it does not like?

A reader who has followed this far has a fair objection waiting. Committees, assumptions, limits and papers are all very well, but what does anybody actually do on the Monday after the meeting? The honest answer is that the list of levers is short, every one of them costs something, and knowing which lever moves which axis is most of the craft.

The leverWhich axis it movesWhat it costs
Lengthen the funding: take in longer term deposits, or borrow for longerBoth. The cash leaves later and the rate resets laterMoney borrowed for longer is dearer, so the margin narrows immediately and the benefit arrives slowly
Reprice the deposit book: change what is paid on savings and on term moneyBoth, and indirectly. Paying more attracts balances and changes how long they stayIt is paid on the whole book, not only on the new money, and that makes it the most expensive lever in the list
Change the shape of the asset side: sell or buy in the banking book, or change what gets lent and for how longBoth, slowlyIt competes directly with the lending business, which has its own targets and did not ask to be part of this
Use a derivative: an interest rate swap changes when a rate resets without any cash movingAxis two only, and cleanlyA counterparty, a contract and a position somebody now has to manage, priced and settled separately
Accept it, record it and report itNeitherNothing, when the position is inside appetite. Everything, when it is not and nobody says so

Read the second column and one thing jumps out: the derivative is the only lever that moves the pricing axis without disturbing the cash axis, and that alone explains why banks use them at all. Everything else on the list drags both axes at once. An asset liability management committee that wants to fix a repricing problem by lengthening its funding usually finds it has also changed a maturity bucket it was quite happy with. How a swap actually pays, how it is priced and what it settles into is covered separately; it earns its place in the table as the only entry with a single tick in one column.

Now apply that to the shortest bucket. Vindhya does not like a minus Rs 2,400 crore gap in LB1, so what closes it? Bringing inflows forward, by holding more of the buffer in instruments that mature inside the fortnight. Pushing outflows back, by lengthening the wholesale money that falls due in it, though that is exactly the funding whose concentration is already in breach as B3. Or holding more cash, the least earning thing the bank can do with a rupee. Changing the slotting assumption does not close it, and the difference between those two kinds of action is the single most useful distinction in the subject. Moving the assumption changes the measured number and changes nothing about the bank. Moving the funding changes the bank and, as a consequence, changes the number. A committee that reaches for the first when it means the second has not fixed anything; it has redecorated the report.

The monthly rhythm earns its keep here too. G4 meets twelve times a year and G2 six, so every position described here gets looked at by somebody roughly every four weeks and every limit gets reset roughly twice a year. The cadence is not decoration either. A funding shape takes months to change, so a committee meeting quarterly would be reacting to a position two quarters old, and a committee meeting weekly would be making structural decisions at the speed of noise.

How does anybody outside the bank read this?

An outsider sees none of this unless somebody asks for it, so how the asking is done is worth knowing. Four readers, four different questions.

A wholesale lender deciding whether to place money with Vindhya reads the ladder and then asks what the ladder rests on. The competent version of that conversation lasts one question: what average behavioural life is the bank using on its non-maturity deposits, who set it, and when did they last change it? A treasury that answers instantly, with a committee name and a date, is showing that the judgement is governed. A treasury that has to go and find out is showing something else.

An equity analyst asks which direction the bank is managed in. A rate rise helps a bank whose assets reprice faster than its liabilities and hurts the value of a bank with long assets against short liabilities, and both of those can be true of the same institution at the same moment. So the question is not which number is right. The question is which of the two the bank steers by, and whether anybody has been shown both.

A large depositor should notice that concentration is a two sided fact. The state undertaking that placed Rs 1,440 crore with Vindhya in month 10 caused breach B4 without doing anything wrong. A corporate treasurer placing a deposit large enough to matter to the bank taking it is somebody else's concentration limit, and that is worth knowing before the bank starts pricing that deposit differently to reduce it.

And a household reader is inside these tables already. The balance sitting in a household savings account is part of somebody's Rs 36,000 crore, and a room of 9 people has decided how long it is likely to stay. A room of 9 people deciding is not sinister; it is the only way the account can pay anything at all. Money that had to be available in cash the instant it was asked for, with no assumption made about it, could not be lent to anybody, and an account that lends to nobody pays nothing.

What can asset liability management not fix?

A function with a clear mandate has a clear edge, and saying where the edge is protects the function from being blamed for things outside it. Four things sit outside.

Matching cannot make a badly chosen loan book good. Matching is about when money moves and when rates reset, not about whether the borrower pays. Vindhya's Rs 1,764 crore of non-performing advances is not an asset liability management problem and no amount of reslotting touches it.

Matching cannot conjure funding that is not there. Matching can change the shape of what is there, lengthen some of it, price some of it differently and refuse some of it. When the funding simply is not available, that is a different conversation with a different set of actions, and it belongs to the plan a bank keeps for exactly that.

Matching cannot make an assumption true. Placing Rs 34,200 crore of the deposit book in the long buckets LB5 to LB8 does not persuade a single depositor to stay. The table records a belief about behaviour; it does not cause the behaviour. The distance between recording a belief and causing it is the honest reason model V1 matters so much and can be tested so little.

And matching cannot decide how much exposure the bank wants. The board approves the appetite, committee G2 turns it into limits L1 to L12, and committee G4 works inside them. A committee that sets its own tests is not being governed, and the separation that creates the structural gap described here is also the separation that stops that happening. The fix is a line in a paper, not a merger of the two mandates.

India

What is named here, and where the version that binds actually lives

Any bank anywhere has two sides, two axes and somebody deciding the assumptions, so the mechanism above holds in any jurisdiction, and none of it binds a bank on its own. Where a standard does exist, its origin is the Basel Committee on Banking Supervision at the Bank for International Settlements, bis.org, and that is where the framing of interest rate risk in the banking book, the economic value and earnings measures, the liquidity coverage ratio and the net stable funding ratio comes from.

The rules that actually bind a bank operating in India are a separate question with a separate answer, set by the Reserve Bank of India at rbi.org.in: which balances may be treated behaviourally and within what caps, what must be computed, on what basis, how often, in what form and from what date. The global standard binds nobody by itself, so naming only the global standard is the error to avoid. Every ratio, factor, cap, share and limit above is Vindhya Commercial Bank Limited's own invented working number, including the 5.0 per cent slotting, the 0.5 year deposit life, the 7.5 per cent and 40.0 per cent thirty day assumptions and the 28.0 per cent cap in limit L9. Anything that binds should be confirmed at the source, along with the version date.

Matching is the function held above, and every measure it touches belongs somewhere else. The maturity ladder LB1 to LB8, the liquidity coverage ratio, the net stable funding ratio, the survival horizon and the contingency funding plan are all named and none of them computed; how each one is built, what it captures and what it quietly misses is the subject of liquidity. Interest rate risk in the banking book, the repricing ladder RB1 to RB8, the economic value of equity and earnings at risk are named and left uncomputed in the same way; they belong to market exposure. How either ladder is constructed is covered separately. A term deposit, a certificate of deposit and a government security are named and not explained; how an instrument pays is a separate subject again. The institution here is Vindhya Commercial Bank Limited. Nirjhar Industries Limited and its corporate treasury, a different institution with a different problem, hold the sequence around it and take it back afterwards.
Try it out

The liquidity coverage ratio and the economic value of equity are named above. What happens to them?

Debt Capital Markets Bootcamp — Fin Maverick

Sources

SourceDocumentSite
Reserve Bank of IndiaWhat actually binds a bank operating in India on interest rate risk in the banking book, liquidity coverage, stable funding, behavioural treatment of balances and large exposuresrbi.org.in
Bank for International SettlementsThe Basel Committee on Banking Supervision standards, named as the origin of the framing rather than as what binds anybodybis.org
Indian Banks AssociationBanking operational convention, including how a deposit account, a certificate of deposit and a committee calendar are customarily operatediba.org.in
Institute of Chartered Accountants of IndiaThe assurance and audit treatment of what a bank reports about its own position and the assumptions inside iticai.org
Ministry of Corporate AffairsThe Companies Act treatment of board committees, their constitution and what a board is accountable formca.gov.in

Vindhya Commercial Bank Limited, Nirjhar Industries Limited and Devendra Achar are invented.
Educational material. Not advice on any investment, tax, budget or market position.

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