Funds Transfer Pricing – Methods and Benefits
CA. Pankaj Bankar
The author is a member of the Institute. He can be reached at bankarpankaj100@gmail.com and eboard@icai.in.
Funds Transfer Pricing (FTP) is an important management accounting technique used by Banks. The primary objective of FTP mechanism is to assess Bank’s profitability at micro level and establish the formal mechanism for asset pricing with due weightage on liquidity risk. FTP provides critical strategic input to the management to take decisions with respect to expanding or scaling down business segment/ product/customer segment.
Objectives of FTP
Emergence of liquidity risk during 2008 Global Financial Crisis (GFC) led to the wide use of FTP mechanism among Banks. In the pre-crisis world, the liquidity risk was taken for granted as abundant liquidity was always present. However, during the crisis this assumption turned faulty. This led to deposit runs, credit crunch, rise in cost of funds, defaults, fire-sale of assets to raise liquidity etc. Thus, liquidity became scarce and costly. Few financial institutions collapsed and many severely impacted.
Further, it was noted that not only liquidity and interest rate risk (IRR) were not effectively managed by Banks but also not considered for the asset pricing. This led to mispricing for many lending transactions as the required costs were not passed to the lending units. Also, the borrowing units were not given their due benefits based on the funding mix. Hence, the need to assess and pass on the required costs, benefits and risks to the business units emerged strongly in the post crisis world.
FTP mechanism attempts to adequately address these risks within the Bank along with appropriate asset pricing based on the liquidity costs across different maturities.
Traditionally, Banks measure their profitability based on several matrices. These include Net Interest Income (NII), Net Interest Margin (NIM), Return on Assets (ROA) and Return on Equity (ROE). Though these matrices are important, they fail to provide micro level view of the profitability. For example, the profitability of the Branch/Region/Zone or Business Vertical/Segment/Product/Customer cannot be assessed from these matrices. The assessment of profitability at granular level is essential to understand the profitable branches, segments, products, customers or relationship managers. This will act as a strategic input to the senior management to take various business decisions with respect to expansion, scaling down, incentive structures, customer relationships etc. This becomes more important considering the increasing competition, regulations and increasing regulatory capital requirements.
FTP ensures the necessary costs and benefits are allocated to the respective business units, products and transaction, enabling objectivity in performance monitoring along with granularity.
FTP Mechanism – How It Works?
Banks are in the business of borrowing and lending. They incur interest costs on the borrowed funds (Cost of Funds (CoF)) and they earn interest income on the lending (Yield). Banks typically borrow short term funds and lend for long term assets. This is called maturity transformation where the short maturity liabilities are transformed into long maturity assets. This typical business structure leads to different risks to Bank. The lending segment generates credit risk for Bank and the borrowing activities leads to liquidity risk and IRR. The profitability every asset created through lending transaction is subject to the behaviour of these risks till the life of the asset.
“Banks typically borrow short term funds and lend for long term assets. This is called maturity transformation where the short maturity liabilities are transformed into long maturity assets.”
Bank may do good on the credit risk side but may get hurt from the volatility in the interest rates or lack of funding due to credit crunch in the market. At other times, exactly opposite scenario can emerge. Hence, profitability of the Bank is subject to the management of these risks. FTP mechanism ensures the onus of risks are apportioned to the right risk owners and adequately considered during transaction level pricing.
Under FTP mechanism, Bank is divided into three segments, viz., liquidity generators, liquidity users and Central Funding Unit (CFU). Liquidity generators raise funds from the market in the form of deposits or debt (Example, Branch accepting deposits from customers). Liquidity users lend funds to the retail and corporate customers also invests the money in different financial instruments (Example, Home Loan or Personal Loan division of Bank). CFU is made responsible to handle maturity mismatches (which leads to liquidity risk) and IRR. CFU generally forms part of the Treasury/ ALM division of Bank.
The funds raised by liquidity generators are notionally transferred to the CFU at the Transfer Pricing (TP) rate (will be discussed shortly). The funds received by CFU are in turn notionally transferred to the liquidity users for onward lending at TP rate. TP rate received by liquidity generators is known as transfer credit and the TP rate paid by the liquidity users is known as TP charge.
Funds Transfer Pricing Operational Flow
The profitability of the liquidity generators is the difference between TP credit and CoF whereas the profits of the liquidity users are simply the difference between the Yield and TP charge paid. CFU profits are difference between the TP charge and TP credit.
FTP mechanism ensures centralization of liquidity risk and IRR in the CFU of the Bank. CFU takes the responsibility of these risks and relieves the business segments (both assets and liabilities) from the possible stress caused in the profitability due to constant changes in the liquidity conditions and interest rates. This model ensures that spreads of business units are protected from the inception of the transaction. The risk of possible fluctuation in the spread due to changes in the liquidity and interest rates in future are assumed by the CFU. Hence, business segments are relieved from unnecessary stress and thus can focus on their core business strength.
How TP Rates Are Determined?
Determination of TP rates is the crucial component of the FTP mechanism. If these are not determined with proper methodology and rationale then the whole purpose of the FTP will fail. The TP rates for liquidity generators (TP credit) and liquidity users (TP charge) are different. The steps involved in determining TP rate include identification of appropriate market benchmark and adjustment to the rates by relevant market/internal factors.
1. TP Rate for Liquidity Generators
The concept of opportunity cost is applied to determine this rate. For example, if a Branch would not have raised funds from the depositors (say @3%), then the Bank would have had required to raise the funds from the money market at the prevailing rates (say@5%). These money market rates are used by CFU to determine TP rates to be credited to liability unit.
In money market, the benchmark rate for short term funding (up to 1 year) is MIBOR. In case of funding in foreign currency, the benchmark rate is LIBOR. If the funding is medium to long term then G-Sec Yield for the equivalent maturity can be used as benchmark. Bank can select appropriate benchmarks based on its liability profile and credit rating. It may use single benchmark or average of two benchmark. For example, Bank may use average for MIBOR and T-Bill rates for determining TP rate for 3-month Fixed Deposit raised by Branch.
Further, the funds mobilized by liquidity generators have different maturity profiles. Apart from short term and long-term maturities, the nature of maturities may differ based on the funding source. For example, Fixed Deposits have contractual maturity but CASA does not have any fixed maturity as customer can withdraw money at any time. Hence, to arrive at the TP rate, adequate consideration of the behavioural pattern of the funding source is imperative.
Thus, the TP rate for the liquidity generators is determined based on the appropriate benchmark available in the money market and the maturity profile of the funding source.
2. TP Rate for Liquidity Users & Key Adjustments
Determination of TP rates for assets units requires some adjustments to the TP rate determined for liquidity generators. These adjustments include negative carry for the CRR/SLR maintenance, costs incurred for maintaining liquidity cushion, embedded optionality in terms of prepayment of loans and liquidity premium. Let’s understand them one by one:
Negative Carry for CRR / SLR Maintenance
Funds mobilized from depositors are subject to CRR/SLR requirements in India. Due to these requirements, Bank is subject to negative carry as the yield on the CRR/SLR reserves are generally lower than the market yields. Hence, the TP rates need to be adequately adjusted to accommodate this negative carry.
Liquidity Cushion & LCR Costs
Liquidity costs are incurred to maintain and manage liquidity cushion (Example, High-quality liquid assets, maintaining LCR ratio, contingency funding plans). These costs need to be adjusted to calculate the TP charge.
Embedded Prepayment Optionality
The customer who borrows funds from the Bank receives an embedded option as part of the contract to prepay the loan before the contractual maturity of the term. The funds received before the contractual maturity creates IRR for the Bank. Hence, CFU should be based on the past behaviour of the prepayments, consider this for adjustments to TP rate to be charged to liquidity users.
Liquidity Premium
Sometimes, Bank may find it difficult to raise funds at reasonable costs due to market or internal factors. Bank may face this difficulty across all funding sources and maturities or few depending on the specific situation prevalent. This situation may arise either due to worsening liquidity conditions in the market or bank specific factors (Example, credit rating downgrade, deposit run). CFU should take these factors into consideration and levy liquidity premium to the liquidity users.
These are important adjustments that are performed to determine the TP rate to be charged to liquidity users. Here, we should note that the adjustments discussed above for both TP credit and TP charge are not exhaustive. Bank may have additional adjustments based on the rates offered by competition, economic outlook, desired funding/asset profile, repricing frequency, basis risk, transaction costs etc.
Further, these adjustments can result in either positive or negative margins to be added or subtracted from to the TP rate for respective business units, which can, in turn, increase or decrease both the transfer cost of loans and the transfer income on deposits. For example, negative market adjustments may be considered if there is sharp move in the benchmarks compared to the market deposit rates because of extraneous factors.
FTP Methodological Approaches
There are different approaches to implement FTP in a Bank:
1. Matched Maturity Approach (Gold Standard)
This approach involves determining FTP rates based on the marginal costs (based on appropriate benchmarks), liquidity costs, maturity profile of assets and liabilities along with certain market and internal adjustments. Further, these rates are applied at transaction level. This approach is more logical and used widely across Banks.
2. Average Cost Approach
Under this approach, average cost of the funds is calculated and is charged to the asset generators. The CoF is calculated for all funds taken together i.e. for the pooled funds, without specific consideration of maturity profile of funding sources. The performance of the liquidity generators is assessed by comparing the budgeted CoF with actual CoF, while performance of liquidity users is assessed based on the spread earned over and above the CoF.
3. Net Funding Approach
Business Unit raises funds and deploys it simultaneously. For example, Branch raising funds and providing loans in the local area/region. Hence, no distinction in terms of asset and liability units is made. Central Treasury lends funds to deficit units and mobilizes funds of surplus units. Business performance is assessed based on NIM achieved by the respective business unit against the budgeted NIM.
4. Benchmark-Linked Approach
Under this approach, liquidity generators transfer the funds to CFU and receive TP credit. CFU transfers the funds to liquidity users and levy TP charge. The TP rates are determined based on CoF and market benchmarks.
Average Cost and Net Funding Approach are simple to implement in comparison with Matched Maturity Approach. These approaches do not need efficient IT infrastructure to implement FTP mechanism in Bank. However, these approaches do not consider marginal CoF based on market benchmarks, liquidity costs, maturity profile of the assets and liabilities, internal/external adjustments. Hence, these approaches fail to pass on the appropriate costs, benefits and risks to the liquidity generators and users. Further, the IRR and liquidity risks are not objectively managed under these approaches. Benchmark linked approach is bit superior compared to these approaches but still it does not consider other factors which are factored in in the Matched Maturity approach.
FTP Mechanism – Key Participants & Governance
The important stakeholders and their roles and responsibilities are briefly discussed below:
1. Liquidity Generators
They are responsible for raising funds from for the Bank. The funds can be raised from depositors in form of CASA and Term Deposits or from market in form certificate of deposit, bulk deposits, call, repo, term loans, NCDs, debentures, external borrowings etc. Branches raise funds from depositors whereas Treasury unit of the Bank raise funds from the market. The objective of the liquidity generators should be to raise funds with adequate consideration of CoF, funding mix, diversity of borrowers and maturity profile of the assets generated by Bank.
2. Liquidity Users
They are responsible to deploy funds generated in the profitable assets for the Bank. These assets can be advances/loans or investments. Different lending divisions across the Bank provide loans to its retail and corporate customers for different end use. These loans can be secured or un-secured, short or long term, floating or fixed, amortized or un amortized. The Treasury division of the Bank invests funds in government and corporate securities.
3. Central Funding Unit (CFU)
This unit is generally part of Treasury or ALM department depending on the reporting structure within Bank. It manages the liquidity risk and IRR for the Bank arising out of the maturity mismatches between assets and liabilities. It monitors the market benchmarks, maintains liquidity cushion and determines the FTP rates.
4. Finance and Planning Division
Finance division is responsible for implementation of the FTP within Bank. It coordinates with liquidity generators, liquidity users and CFU to ensure smooth functioning of the FTP mechanism. It ensures the FTP rates are finalized after taking inputs and concurrence from all business units. It monitors and reviews the lending or borrowing transactions which are not in line with the defined FTP rates and seeks required justifications from the respective business units. Finance division is responsible for setting up the business budget along for each business segment, product category, branch. It is also responsible for performance monitoring and reporting.
5. Information Technology (IT)
IT division is responsible for the availability of adequate IT infrastructure used in FTP mechanism and its uninterrupted functioning. IT division should ensure the most of the critical procedures involved in the FTP (Example, fetching market benchmarks, calculating liquidity costs, assignment of FTP rates, exception approvals in case of breach of FTP rates etc.) are automated. It should be further responsible for the logical access management, change management, maintaining of audit logs and trails.
6. Market Risk Management
This division should monitor and report on the liquidity and IRR to the management. It should ensure business units are ensuring compliance with the Market Risk Management policy of the Bank.
7. Asset Liability Committee (ALCO)
Asset Liability Committee is responsible for setting up adequate governance framework in terms of FTP policy, reporting mechanism and exception management mechanism. It should have adequate oversight on the FTP mechanism, changing market scenarios, funding mismatches, level of liquidity / IRR risks. ALCO should have members from the respective business units to ensure fair representation. The discussion in the meetings and actions taken by ALCO should be regularly updated to Risk Management Committee/ Board.
8. Internal Audit
Internal Audit should perform periodic reviews to ensure adequate controls are in place and working effectively along with compliance with the FTP policy.
Benefits of FTP Mechanism
Some of the significant advantages of the effective FTP mechanism (viz. Matched Maturity approach) has been listed below:
Centralization of Risks
IRR and liquidity risks are centralized under FTP mechanism and managed by ALM desk. This leads to close monitoring and management of these risks by specialist function.
Controlled Maturity Mismatch
Liquidity users in Banks are generally inclined towards generating long term/illiquid assets if they are not charged for the liquidity risk undertaken. This leads to aggressive maturity transformations by liquidity generators, which in turn, leads to cashflow mismatches between assets and liabilities thereby exposing Bank to the structural liquidity risk. FTP mechanism discourages unhealthy maturity transformation as the illiquid assets are charged after due consideration of liquidity risk for the longer maturity.
Appropriate Pricing
FTP ensures that the pricing of products is based on the market benchmarks, maturity profile, cost of maintaining liquidity cushion and other risk factors. This ensures no undue benefits are received by business units in terms of lower CoF. Use of marginal CoF ensures that the pricing is performed based on the current rates rather than historical rates. Further, the pricing is performed for each transaction separately.
Funding Strategy
FTP not only identifies profitable /non profitable segments but also identifies the appropriate funding mix suitable for the Bank. For eg, the funding mix for a Bank predominantly in long term lending business (Example, infrastructure loans) will be substantially different from the Bank which is mainly into short term unsecured lending (Example, credit cards/personal loans). It helps management to drive the behaviour of the liquidity generators in terms of raising funds from different instruments in line with the product profile of the liquidity users.
Micro Level Performance Monitoring
FTP enables management to assess profitability at individual business segment, products, relationship manager and customer level. Margins earned by all business units become comparable as the FTP ensures allocation of CoF appropriately to business units. Further, due to centralized management of the liquidity risk and IRR, the performance of the individual units can be measured purely based on the factors in control of the business units.
Appropriate Targets
The granular visibility of performance helps management to set appropriate targets, KRAs and incentives for different business units, products and relationship manager.
Capital Allocation
Banks are required to maintain regulatory capital for every asset created. Further, the quantum of capital depends on the risk profile of the asset. FTP assists management to identify the profitable segments / products from not so profitable segments/products. This critical input enables management to allocate the costly and scarce capital to the areas which are profitable for banks. Thus, FTP mechanism leads to prudent allocation of capital.
Conclusion
FTP mechanism is an objective management accounting technique which is beneficial to Banks on multiple counts viz. appropriate pricing, effective risk management, correct performance monitoring, and prudent capital allocation decisions. Effective governing framework, availability risk related competencies, access to the relevant market information systems, effective internal IT infrastructure, detailed FTP procedures and comprehensive reporting mechanism will ensure smooth functioning of FTP mechanism in Banks.
References
- Occasional paper No 10. – Liquidity transfer pricing – Financial Stability Institute
- Liquidity Risk – Management and Supervisory Challenges – BCBS
- Principles for Sound Liquidity Risk Management and Supervision – BCBS
- Funds Transfer Pricing in Banks – CAFRAL
- Consultation Paper on CEBS’s Guidelines on Liquidity Cost Benefit Allocation (CP36) – CEBS