Collateral Pools: Best Practices Moderator : Hon. Steve McCoy, Georgia State Treasurer Speakers : Hon. Young J. Boozer III, Alabama State Treasurer Craig Leyton, Director, Wells Fargo Securities Mara Holley, Executive Vice President, Wells Fargo Bank Mike Nevins, Head of Government Banking, JP Morgan Jeffrey Sirota, Market Strategist, Government Banking, JP Morgan
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Collateral Pools: Best PracticesPublic Sector Collateral Management Model - Introduction What Is a Public Sector Collateral Management Model? A set of laws, regulations and rules that
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Collateral Pools: Best PracticesModerator:
Hon. Steve McCoy, Georgia State Treasurer
Speakers:Hon. Young J. Boozer III, Alabama State Treasurer
Craig Leyton, Director, Wells Fargo SecuritiesMara Holley, Executive Vice President, Wells Fargo BankMike Nevins, Head of Government Banking, JP Morgan
Jeffrey Sirota, Market Strategist, Government Banking, JP Morgan
A F E
Security for Alabama Funds EnhancementYoung Boozer, State Treasurer
History
•That Fateful Call
•The Headlines
•We have a problem
•Get a solution
The Process•Pledging Statute
•Under Pledged•Over Pledged
•Bank Group Organized
•Other States
•Best Result
The Solution
•SAFE
•Enacted 2001
•Going Strong
SAFE: DescriptionStatute: Title 41, Chapter 14A, Code of Alabama
(effective January 1, 2001)
Participants• Board of Directors• SAFE Staff• Alabama Banks• Alabama Public Depositors• Custodian
SAFE Program Rules
Monthly Reporting by Banks
Summary Report (as of 9.30.17)
Avg. Public Deposit Pool (in millions)
$11,710Less FDIC(in millions)
$881Net Avg. Public Deposits (in millions)
$10,829Total Public Entities 5,435Total # of QPDs 150Coverage Ratio - Net Avg. Deposits 92.94%Coverage Ratio - Total Actual Deposits 85.94%
Every State Approaches Collateralization of Deposits…Differently
Across 50 states, there are effectively more than 50 different collateral programs. Each of the following collateral program variables can be unique for each program:
1. How an institution qualifies as a Qualified Public Depositor 2. Pledging methodology: Direct to client OR
Pool Mandatory or optional
Contingent or Non Contingent Liability
Contingent pledge % requirements
Contingent rating agencies
3. Contracts/Agreements required Pool participants to sign contract
4. Qualified custodian criteria State choice OR
QPD choice
5. Margin of collateral pledged to support deposit balances Client Types within a State can be different
Tiers for non contingent liability
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6. Types of securities eligible to pledge Haircuts to specific types
Acceptability of In-state vs out-of-state bonds
Rating requirements (CUSIP vs. Parity)
Maturity dates requirements
7. Who approves processing of collateral to: Pledge
Release
Substitute
8. Reporting requirements Frequency
Data requirements
Method (email/online)
9. Auditing requirements
AK100%
NM50%
AZ102%
TX100-110%
CA110%
CO102%
UT0-110%
NV102%
IA*100%
IL100%
AR100%
ID0-100%
IN0-
100%*
MI0-
100%
MN 110%
WI100%
MT50%
ND110%
NE102% OH
105%
WA*50 %
OR*40%
WY100%
SD100%
KS100%
TN100%*
AL*70-
115%
VA105%
MS*GA25-100%
PA100%
SC102%
NY102%/105%
NC 110%
25-150%
FL*
OK100%
MO100%
105%
LA 100%
KY100%
WV100%
MD100%
DE102%
DC102%
NJ*5-100%
CT110%
RI102%
ME105%
MA102%
VT102%
NH100%
HI100%
Yellow (22) = Pooled Asterisk* (10) = Contingent Liability Green (26) = Non Pooled Bold (8) = Software/Electronic Reporting Green & Yellow (3) = Pool/Non-Pool Options
Collateralization Programs by State
Centrally managed pool Jan
2018
Does Not Take Additional Differences Into Consideration:1. Eligible Collateral Types2. Collateral Movement3. Custodian
Steve McCoy, State TreasurerGeorgia Office of the State Treasurer
November 30, 2017
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• Large banks concern about high cost of collateral for publicdeposits given Basel III.
• Georgia previously offered only two options for publicdeposits collateralization – dedicated accounts and singlebank pools. Both required 110% collateral.
• Public depositors need safety of deposits and to minimizebanking fees.
• Simply reducing collateral requirements not acceptable dueto higher risk.
Why Contingent LiabilityCollateral Pool?
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• State Treasurer, Banking Commissioner, and GeorgiaBankers Association built a consensus among banks andlocal government associations for the need for legislation toestablish the SDP, to reduce collateral in exchange for acontingent guarantee among all banks in the pool.
• Legislation was introduced on January 21, 2016, passed theHouse (162-1), the Senate (51-3), and sent to the Governoron March 29.
• OST worked with a task force to develop the SDP Policywhich was approved by the State Depository Board andbecame effective on July 1, 2017.
• SDP Policy and program details located at http://sdp.azurewebsites.us/.
Georgia SDP Legislation
• Mandatory Participants are banks accepting public depositsin Georgia and have ≥ $50B in assets.
• Voluntary Participants are banks accepting public depositsin Georgia and have < $50B in assets that apply and areaccepted.Acceptance is conditioned upon financial criteria and
State Depository Board approval.Approved banks receive one year certificates subject to
annual renewal.The board may reject renewals at its discretion.
• Participating banks are required to secure all Georgia publicdeposits by the SDP (unless exempted).
Georgia SDP Participants
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• The SDP has 4 Tiers determining collateral level: Tier I25%; Tier II 50%; Tier III 75%; and, Tier IV 110%.
• The Tier for each bank is determined quarterly and basedon financial condition.
• The State Treasurer, in consultation with BankingCommissioner, may increase required collateral up to 125%for any or all banks in order to proactively respond todeteriorating credit conditions.
Georgia SDP Collateral Requirements
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• Participating banks may pledge securities permitted by theSDP Policy. The State Depository Board is empowered toexpand or contract eligible collateral. Currently, thefollowing securities are permitted:
• Treasuries, Agencies, SBA Pass-throughs, some AgencyMortgage Backs
• GA municipal bonds (BBB); Out of State Municipals (A)with 25% limit
• State-issued Private Placements with Treasurer’sapproval.
• Letters of Credit from the Federal Home Loan Bank areaccepted as Eligible Collateral.
Georgia SDP Eligible Collateral
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• Mandatory and Voluntary Participants are obligated tomake public depositors whole from any loss of depositssecured by the SDP.
• Each depository’s share of any shortfall liability will beassessed on a pro-rata basis.
• The contingent liability obligation continues for 12 monthsafter a Voluntary Bank leaves the pool or a Mandatory Bankceases to hold public deposits in Georgia.
Georgia SDP Contingent Liability
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• OST maintains overall oversight and responsibility for theSDP.
• OST contracts with Georgia Bankers Association to carryout certain administrative duties.
• Participating banks assessed fees to cover costs ofadministering SDP.
• Depositories report required information including publicdeposits, collateral, depositors, etc. in a secure, web-basedplatform.
• Public and internal reports are generated in the sameplatform.
Georgia SDP Oversight & Reporting
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Sample 30-day SDP Report
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P U B L I C S E C T O R C O L L A T E R A L M A N A G E M E N T M O D E L :
C O N S I D E R A T I O N S F O R D I S C U S S I O N