NSFR: Impact on Banks’ Business Model depends on National Characteristics of Asset and Liability Markets

The Net Stable Funding Ratio (NSFR) shall be implemented as a binding minimum ratio from 2018 on. It is defined as available stable funding (ASF) divided by required stable funding (RSF). Its supervisory monitoring started in 2014, according to European CRR-Regulation. Currently, the Basel Committee on Banking Supervisory revises it’s consultation on the final calibration of the NSFR dating from January 2014. Analysis suggests that National characteristics of Asset and Liability Markets matter and shall be taken into account defining a standardised ratio.

One goal of the NSFR is to allow for a better governance of liquidity risk stemming from maturity transformation of less than one year: Banks are required to hold an adequate portion of stable funding sources such as deposits or bond market financing, or even capital, instead of relying on short-term wholesale funding.

In addition to liquidity risk, the NSFR adresses the risk of increased leverage: Analysis shows that the increased leverage in the forefront of the Financial Crisis was often not financed by capital but by short-term wholesale funding. As the NSFR defines different levels of available and required stable funding, balance sheet growth is limited as long as it is based on non stable funding. For example, the available stable funding differs between regulatory capital which enjoys a 100 percent available stable funding (ASF) weight while stable non-maturity deposits receive a 95 percent ASF weight. In contrast, funding from a financial institution with residual maturity less than six months has a 0 percent ASF. Similarly, liquid assets enjoy lower required stable funding (RSF) factors while illiquid assets are assigned higher RSF factors.

This strong impact on asset liability management requires a careful calibration of the stability factors. As Gobat/Yanase/Maloney (IMF, WP/14/106) state, „changes in ASF and RSF factors for important asset and liability components make a substantial difference in the final NSFR figure, underlining the importance of having a proper calibration at the national level.“ One way to balance between the goal implementing a standardised single rule on European level and the flexibility required to take national characteristics into account, „is to allow for some “guided discretion,” particularly by allowing countries to apply more stringent parameters.“ For example „Supervisors will need to take a cautious approach in designing the deposit weights for the NSFR, as deposit stability characteristics will most likely vary among jurisdictions, depending on market and institutional factors.“

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