Entire Act

F. Contingency Funding Plan (CFP)

42. A Contingency Funding Plan, or CFP, is a compilation of policies, procedures and action plans for responding to severe disruptions to a Bank’s ability to meet its liabilities as they fall due or its ability to fund some or all of its activities quickly and at a reasonable cost. In order to comply with the requirements in BBR Rule 9.10 on Contingency Funding Plan, a bank’s CFP must:


(a) list the events or circumstances that will lead the Bank to put any part of the plan into action;


(b) set out available potential contingency funding sources and the amount of funds a Bank estimates can be derived from these sources;


(c) estimate the lead time needed to tap additional funds from each of the contingency sources;


(d) set out the extent to which the plan relies upon:


(i) asset sales, using assets as Collateral on secured funding (including repurchase agreements), securitising its assets or otherwise reducing its assets;


(ii) modifying the structure of, or increasing, its liabilities; and


(iii) the use of committed facilities; and


(e) contain clear administrative policies and procedures that will enable the Bank to manage the implementation of the plan, including:


(i) the roles and responsibilities of senior management, including who has the authority to invoke the CFP;

(ii) the names, location and contact details of members of the team responsible for implementing the plan;


(iii) the details of who is responsible for contact with the Bank’s head office (if appropriate), analysts, investors, external auditors, media, significant customers, regulators and others; and


(iv) the mechanisms that enable senior management and the Governing Body to receive relevant, accurate, comprehensive, timely and reliable management information.


43. The CFP should provide a framework with a high degree of flexibility so that a Bank can respond quickly in a variety of situations. The CFP should assist the Bank to manage a range of scenarios of severe liquidity stress that include both Bank-specific and more generalised market-wide stress, as well as the potential interaction between them


44. The CFP's design, plans and procedures should be closely integrated with the Bank’s ongoing analysis of Liquidity Risk and with the results of the scenarios and assumptions used in stress tests. The CFP should, for each of the tested scenarios, demonstrate that the Bank has sufficient liquid financial resources to meet its liabilities over a range of different time periods, including intraday. A Bank must ensure that its CFP accounts for:


(a) the impact of stressed market conditions on its ability to sell or securitise assets;


(b) the link between asset liquidity and funding liquidity;


(c) second round and reputational effects related to execution of contingency funding measures; and


(d) the potential to transfer liquidity across Group entities, borders and lines of business, taking into account legal, regulatory, operational and time zone constraints.


45. Key aspects of CFP testing include ensuring that roles and responsibilities are appropriate and understood, confirming that contact information is up to date, proving the transferability of cash and collateral (especially across borders and entities) and ensuring that the necessary legal and operational documentation is in place to execute the plan at short notice. The Bank should also test key assumptions regularly, such as its ability to sell or repo certain assets or periodically draw down credit lines.


46. A Bank should ensure effective coordination between teams managing issues surrounding liquidity crises and business continuity. Liquidity crisis team members and alternates should have ready access to CFPs on-site and off-site.

Management of Encumbered Assets

47. In relation to BBR Rule 9.13, the limit for encumbered assets is intended to mitigate the risks arising from excessive levels of encumbrance in terms of:


(a) the effect on the Bank’s cost of funding; and


(b) the implications for the sustainability of its long-term liquidity position