2017年-FSB全球金融稳定委员会_Funding_Strategy_Elements_of_an_Implementable_Resolution_Plan_23页_506kb

Summary of Funding Strategy Elements of an Implementable Resolution Plan

Core Content

The Financial Stability Board (FSB) published a consultative document on 13 November 2017 to provide additional guidance on the development of an implementable resolution funding plan for Global Systemically Important Banks (G-SIBs). The document is part of the FSB's ongoing work to operationalise resolution strategies and plans, building on existing guidance such as the Key Attributes and Basel Committee liquidity standards.

The resolution funding plan is a critical component of the broader resolution plan and aims to ensure that adequate temporary funding is available to support the orderly resolution of a G-SIB. This includes addressing liquidity stress, identifying funding sources, and coordinating between home and host authorities.

Main Points

1. Firm Capabilities

G-SIBs must have the capability to:

• Monitor and report liquidity sources, uses, and positioning.
• Estimate funding needs in resolution scenarios.
• Identify and mobilise collateral across the group.
• Manage asset encumbrance and understand how it may impact resolvability.

These capabilities should be aligned with Basel standards and include tools for:

• Tracking intraday liquidity flows.
• Managing contractual mismatches in funding.
• Calculating unencumbered assets available for resolution funding.
• Forecasting collateral requirements under different stress scenarios.

2. Development of the Resolution Funding Plan by Authorities

Home resolution authorities are responsible for:

• Ensuring the resolution funding plan is consistent with the firm’s contingency funding plan and recovery plan.
• Assessing liquidity stress in the run-up to resolution.
• Identifying foreign currency liquidity needs.
• Using the firm's monitoring capabilities to inform the funding strategy and funding need estimates.

The resolution funding plan should be reviewed annually and discussed by the Crisis Management Group (CMG). It should also incorporate more conservative assumptions than those used in the LCR stress scenarios to ensure preparedness.

3. Firm Assets and Private Funding Sources

G-SIBs must be able to:

• Mobilise unencumbered assets as collateral.
• Assess the availability and size of private funding sources.
• Improve the willingness of private counterparties to provide funding during resolution.

Authorities should also consider the availability of firm assets under different failure scenarios and ensure that private funding is readily accessible.

4. Temporary Public Sector Backstop Funding

Temporary public sector funding mechanisms should be:

• Identified and tested in advance.
• Aligned with the preferred resolution strategy.
• Sequenced appropriately with exit strategies in place to avoid moral hazard.

G-SIBs should also have access to ordinary central bank facilities and payment and settlement systems, particularly for material operating entities not in resolution.

5. Information Sharing and Coordination

Authorities must:

• Clearly allocate responsibilities between home and host authorities.
• Facilitate cooperation and information sharing to ensure the timely provision of resolution funding.
• Address impediments to coordination, including legal and regulatory barriers in foreign jurisdictions.

Key Elements of the Resolution Funding Plan

• Methodology for estimating liquidity needs: Should enable ex ante liquidity estimation, capture legal and operational obstacles, and model counterparty behavior.
• Monitoring and reporting: Must include granular liquidity tracking, especially in stressed situations, and daily/real-time reporting.
• Collateral identification: Firms must be able to identify, measure, and mobilise eligible collateral, including less liquid assets.
• Interaction with contingency and recovery plans: Resolution plans should draw on existing liquidity management frameworks and incorporate more conservative assumptions.
• Foreign currency liquidity: Authorities should develop strategies for accessing funding in foreign currencies.
• Public sector backstop mechanisms: Must be pre-identified, tested, and have clear exit strategies.
• Coordination and information sharing: Essential for cross-border resolution, especially when accessing host jurisdiction backstop funds.

Conclusion

This consultative document aims to enhance the operational feasibility of resolution funding plans for G-SIBs. It outlines a comprehensive set of funding strategy elements that cover firm capabilities, authority involvement, funding sources, and coordination mechanisms. The FSB invites feedback on these elements and seeks input on potential challenges, improvements, and additional actions to support the development and implementation of resolution funding plans.

Responses are due by Friday, 2 February 2018.