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AcadiFi
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LiquidityCFP_Maya2026-01-16
frmPart IILiquidity RiskRisk Governance

What should a contingency funding plan include and how are escalation triggers designed?

FRM II discusses the Contingency Funding Plan (CFP) as a critical liquidity risk management tool. I know it's basically the liquidity emergency playbook, but what specific elements should it contain, and how do you set the early warning triggers that activate different stages?

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A Contingency Funding Plan (CFP) is a predefined action plan that a bank activates when facing actual or potential liquidity stress. It bridges the gap between normal liquidity management and crisis — laying out exactly what to do, who decides, and in what order as conditions deteriorate.

Key Components of a CFP:

1. Governance and Roles:

  • Identify the Liquidity Crisis Management Team (LCMT)
  • Define authority levels — who can activate each stage?
  • Establish communication protocols (internal and external)
  • Assign responsibilities: treasury, risk, communications, legal, trading desks

2. Early Warning Indicators (EWIs):

EWIs are metrics that signal deteriorating liquidity conditions before a full crisis develops:

IndicatorGreenAmberRed
Wholesale funding cost (vs benchmark)< 25bps25-75bps> 75bps
Retail deposit outflow (weekly)< 0.5%0.5-2.0%> 2.0%
Unsecured funding availabilityNormal accessReduced tenorsMarket closed
LCR level> 120%100-120%< 100%
Credit rating on reviewStable outlookNegative outlookDowngrade
Repo haircut increasesNone5-15%> 15%

3. Staged Escalation Framework:

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4. Action Menus by Stage:

Each stage has predefined actions with estimated liquidity impact:

  • Stage 1: Increase daily monitoring, review maturing wholesale funding, pre-position collateral at central bank, reduce new lending commitments
  • Stage 2: Sell Level 2 HQLA, draw down committed credit facilities, reduce discretionary outflows, begin communicating with key depositors
  • Stage 3: Sell Level 1 HQLA, access central bank standing facilities, implement deposit retention programs, notify regulators
  • Stage 4: Emergency asset sales (accept fire-sale prices), request emergency central bank assistance, implement full communication strategy

5. Quantification:

For each action, estimate:

  • Liquidity generated ($ amount)
  • Time to execute (hours/days)
  • Cost (spread widening, P&L impact)
  • Dependencies (market conditions, counterparty willingness)

6. Testing:

CFPs must be tested regularly (at least annually) through:

  • Tabletop exercises with the LCMT
  • Simulation exercises using historical or hypothetical scenarios
  • Testing of operational readiness (can you actually sell $5B of Treasuries in 4 hours?)

Exam Tip: FRM II tests the multi-stage nature of CFPs, the concept of early warning indicators, and the progression from monitoring to action as conditions worsen.

Practice liquidity contingency planning in our FRM community.

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