BAS September 2022 Presentations
Funding Concentrations
(FDIC RD Memo May 2019)
Include if > 10% total assets: • Any type of wholesale funding (brokered deposits, listing service deposits, FHLB borrowings, other borrowings, public funds) • Aggregate large depositors (> 2% of total deposits) Examiner judgement:
• Uninsured deposits • High ‐ rate deposits
Note: Some items not considered “non ‐ core” could be cited as a concentration, and certain items considered “non ‐ core” would not be cited.
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Analyzing Liquidity
Quantitative Amount of liquid assets Off ‐ balance sheet funding available (tied to AQ/Capital) Amount of wholesale funding UBPR ratios (liquidity pages 10 & 10A, capital ratios page 11) Past sources and uses
Qualitative (Risk Management)
Corporate governance Policies/procedures (including Contingency Funding Plan) Risk measurement and monitoring systems (e.g. cash flow projections & stress tests) Maintaining diverse funding sources Internal routines and controls
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