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?
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:
| Indicator | Green | Amber | Red |
|---|---|---|---|
| Wholesale funding cost (vs benchmark) | < 25bps | 25-75bps | > 75bps |
| Retail deposit outflow (weekly) | < 0.5% | 0.5-2.0% | > 2.0% |
| Unsecured funding availability | Normal access | Reduced tenors | Market closed |
| LCR level | > 120% | 100-120% | < 100% |
| Credit rating on review | Stable outlook | Negative outlook | Downgrade |
| Repo haircut increases | None | 5-15% | > 15% |
3. Staged Escalation Framework:
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.
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