By Julie Stackhouse, Executive Vice President
This post is part of a series titled “Supervising Our Nation’s Financial Institutions.” The series, written by Julie Stackhouse, executive vice president and officer-in-charge of supervision at the St. Louis Federal Reserve, appears at least once each month.
Last month, we addressed the examiner's process for reviewing and rating bank earnings. This month, we examine the fifth component of the safety and soundness rating system for banks (called CAMELS): liquidity. The first component that we addressed was capital adequacy, followed by asset quality, management and earnings. After liquidity, the remaining component is sensitivity to market risk. See Stackhouse, Julie. “The ABCs of CAMELS.” St. Louis Fed On the Economy, July 24, 2018.
To understand the importance of liquidity, it is important to remember that a fundamental purpose of a bank is to redeploy consumer and business deposits and other liabilities into loans requested by other consumers and businesses. Because loans and deposits may not pay off (or mature) at the same time, the bank must manage its liquidity. Stated simply, liquidity is the ability of bank management to meet deposit outflows while continuing to fund demand for loans.
Banks accept deposits—typically called “core” deposits—from consumers and small businesses. For the most part, the federally insured portion of these deposits tends to be stable, lower cost than other funding sources and less sensitive to rising interest rates.
Banks can also supplement funding needs through other sources called “noncore” or wholesale funds. Examples include:
Noncore funding sources are often short term in nature and may be sensitive to interest rate changes, depending on maturity. Examiners closely review the strategies of banks with an unusually heavy reliance on noncore funding sources. In such a situation, examiners will typically request a comprehensive contingency funding plan that contains a strategy for addressing funding shortfalls should a bank’s financial health come under stress.
Banks generate earnings primarily by making loans. However, many loans are comparatively long term in nature relative to sources that fund them. For that reason, banks maintain other assets on their balance sheets that can quickly be converted into cash to meet expected and unexpected withdrawals or a loss of funding sources. These assets are considered sources of liquidity and include:
Examiners review the structure of a bank’s assets and liabilities, as noted above. They also examine a bank’s liquidity policies, procedures and management information systems, including the efforts of bank management to test hypothetical deposit outflows under a variety of assumptions, like a changing interest rate environment.
Banks that perform well in these scenarios typically exhibit a sufficient level of asset liquidity, a high reliance on core deposits, and adequate or better funds management practices. Examiners will rate the liquidity of these banks as strong (1) or satisfactory (2).
On the other hand, banks with low levels of liquid assets, a high reliance on noncore/wholesale funding sources and weak funds management practices raise more concerns. As such, examiners will rate the liquidity of such banks as needs improvement (3), deficient (4) or critically deficient (5). Banks in these situations are typically required to develop plans to improve liquidity and to submit those plans to regulators for review.
1 The first component that we addressed was capital adequacy, followed by asset quality, management and earnings. After liquidity, the remaining component is sensitivity to market risk. See Stackhouse, Julie. “The ABCs of CAMELS.” St. Louis Fed On the Economy, July 24, 2018.