The typology of EU banks’ CFPs is highly diverse, both in terms of their level of detail and their exact components. The typical CFP consists of a set of liquidity measures, internal procedures, responsibilities and lines of authority to be activated under liquidity stress. CFPs exist at the group level and/or the entity level, but many CFPs seem to cover only parts of the organisation, both in terms of geographic exposure and business areas. ... Given the diversity and complexity of practices, supervisors and central banks need to enhance their understanding of individual CFPs.
In the BSC’s opinion, it is also important that CFPs take into account potentially destabilising second-round effects on markets from liquidity-saving measures and/or asset sales, particularly in the case of large institutions.
Although recent events indicate that CFPs have proved useful in establishing chains of command, a large number of banks failed to activate their CFPs. In some cases, this was blamed on the reputational costs of doing so. The BSC considers it important that potential reputational challenges associated with the activation of CFPs be overcome, as otherwise they substantially reduce the usefulness of an important liquidity crisis management tool. While most of the areas in need of improvement identified by the BSC could be addressed in the short term, it is likely that improvements addressing best-practice model developments (such as the inclusion of second-round effects or more integrated views of liquidity, credit and market risk) or the adoption of guidelines can be addressed only in the medium term.