Policy Instruments To Lean Against The Wind In Latin America1
  • 1 0000000404811396https://isni.org/isni/0000000404811396International Monetary Fund
  • | 2 0000000404811396https://isni.org/isni/0000000404811396International Monetary Fund

This paper reviews policy tools that have been used and/or are available for policy makers in the region to lean against the wind and review relevant country experiences using them. The instruments examined include: (i) capital requirements, dynamic provisioning, and leverage ratios; (ii) liquidity requirements; (iii) debt-to-income ratios; (iv) loan-to-value ratios; (v) reserve requirements on bank liabilities (deposits and nondeposits); (vi) instruments to manage and limit systemic foreign exchange risk; and, finally, (vii) reserve requirements or taxes on capital inflows. Although the instruments analyzed are mainly microprudential in nature, appropriately calibrated over the financial cycle they may serve for macroprudential purposes.

Abstract

This paper reviews policy tools that have been used and/or are available for policy makers in the region to lean against the wind and review relevant country experiences using them. The instruments examined include: (i) capital requirements, dynamic provisioning, and leverage ratios; (ii) liquidity requirements; (iii) debt-to-income ratios; (iv) loan-to-value ratios; (v) reserve requirements on bank liabilities (deposits and nondeposits); (vi) instruments to manage and limit systemic foreign exchange risk; and, finally, (vii) reserve requirements or taxes on capital inflows. Although the instruments analyzed are mainly microprudential in nature, appropriately calibrated over the financial cycle they may serve for macroprudential purposes.

III. Liquidity Requirements for Macroprudential Purposes

This note describes the main features and effects of the new policies based on liquidity ratios that adjust for stress scenarios. In particular, the note reviews the Basel III liquidity requirements. In addition, Annex 1 discusses recent selected country experiences with similar measures in Australia, Colombia, Chile, and New Zealand.

A. Motivation

There is agreement that illiquidity amplified the depth and severity of the global crisis and needs more attention (IMF, 2011a and 2010a; Gorton and Metrick, 2010; Shin, 2010; or Brunnermeir, 2009). The excess reliance on wholesale and cross border funding, which are less stable funding alternatives, contributed to the inability of multiple financial institutions to roll-over financial needs during the crisis (IMF, 2010a). Furthermore, excessive leverage in the financial system and short-term foreign debt have been identified as main determinants of sharp output collapses in emerging markets (Blanchard et al., 2010 and Berkman et al., 2009).

Liquidity risk management has become a regulatory priority, both from a micro and macro prudential angle. Its goals are to build up liquidity buffers and improve the structure and resilience of funding in banks and the financial system as a whole. Thus, by making banks and the system more resilient to a downturn, and by minimizing the adverse effects of runoffs and fire sales, liquidity risk managements can help reduce systemic risk. Furthermore, since liquidity regulations may increase the cost of funding they may also help dampen the credit cycle in the upswing. Achieving these goals involves identifying, measuring, monitoring and controlling liquidity risk. More generally, it requires ensuring stable funding sources, generating predictable flow of funds, reducing asset/liability maturity mismatches, and avoiding spillovers across the financial system.

Liquidity is the ability of a bank to fund increases in assets and meet obligations as they come due without incurring unacceptable losses (BCBS (2008) or Brunnermeir (2009)). Liquidity risk materializes if the institution is unable to convert assets into cash, or fails to procure enough funding.2 Even, if funding is available, it may be too costly, thus affecting the institution’s current and future stream of incomes and capital.

The concept of liquidity has various dimensions: funding liquidity, market liquidity and liquidity crisis. Funding liquidity is the ability to raise cash (or cash equivalents) either borrowing or through the sale of an asset; Market liquidity relates to the ability to trade an asset or financial instrument at short notice with little impact on its price. This is turn can take several forms: tightness, depth, immediacy, and resilience. Tightness refers to the difference between buy and sell prices, e.g., bid-ask spreads. Depth refers to the size of transactions that can be executed without altering the price. Immediacy refers to the speed at which orders can be executed, and resilience to the ease with which prices return to normal after temporary disturbances. Finally, a sudden and prolonged evaporation of both market and funding liquidity may have systemic consequences for the stability of the financial system leading to “liquidity crisis” or “systemic liquidity shortfalls” (IMF, 2011a). These are often episodes in which agents’ endogenous responses generate an unwillingness to bear risk, i.e., “liquidity black holes” (Shin, 2010).

Policy makers can manage idiosyncratic and systemic liquidity risks by imposing limits over traditional liquidity indicators and managing them in a countercyclical manner whenever necessary.3 For instance this is the case with traditional liquidity,4 core funding, noncore funding, or leverage ratios. Additional tools such as reserve requirements on deposits can also been employed (IMF, 2010b and Garcia et al, 2011). 5 At the systemic level, new methodologies are only recently being proposed, but work is required in this area (see IMF, 2011a).

Traditionally, liquidity ratios have been measured under normal circumstances rather than under stressed conditions. To address this shortcoming, some countries (e.g., New Zealand and Colombia) have improved the monitoring and control tools of liquidity risk, extending them to include crisis-like stress scenarios. The new Basel III framework has also complemented the global regulatory banking standards with a set of stressed liquidity requirements: the Liquidity Coverage Ratio (LCR) and Net Stable Funding Ratio (NSFR).6

Despite their usefulness, a more formal macroprudential framework is required to deal with systemic liquidity risk. Indeed, although the measures covered in this note should help strengthen liquidity management and the funding structure of individual banks—thus enhancing the stability of the banking sector—they are microprudential in nature. They are not designed to mitigate systemic liquidity risks where the interaction of financial institutions can result in the simultaneous inability of institutions to access sufficient liquidity and funding liquidity under stress. Under such circumstances a regulation that would charge and institution for its contribution to systemic liquidity risk becomes more evident. However, robust methodologies for measuring systemic liquidity risk are only being proposed at this stage (IMF, 2011a).

B. The Liquidity Coverage Ratio (LCR)

The LCR is as tool to make banks less susceptible to potential short-term disruptions in accessing funding. Specifically, its goal is to ensure banks have liquidity to survive one month of stressed funding conditions. Therefore the LCR identifies the amount of unencumbered (i.e. not pledged and not held as a hedge for any other exposure), high quality, liquid assets that can be employed to offset expected cash outflows over a 30-day horizon (Table A.1). The ratio of these two components must exceed 100 percent. The LCR will be in observation starting in 2011, and will be introduced as a minimum standard in 2015.

Its main components are: a stress-test scenario, the definition of high quality assets, and the bank’s expected cash outflow over a one-month period (see Annex Table A.1 for details).

  • The stress scenario considers a downgrade in the institution’s credit rating, a run-off of retail deposits, disruptions in secure and unsecured funding capacity, disruption in the market that affect the quality of collateral, and unscheduled draws on credit and liquidity facilities. Of course, banks are expected to have their own stress tests to assess the level of liquidity they should hold beyond this minimum supervisory requirement.

  • The high liquid assets must guarantee a liquidity-generating capacity in periods of severe idiosyncratic, either by selling the asset or through secured borrowing, and in case of severe market stress they should be eligible for operations by central banks (e.g., overnight facilities). They also must satisfy fundamental, market, and operational features that allow them to be easily and immediately converted into cash at little or no loss value. The stocks of liquid assets that satisfy the previous characteristics are then weighted according to their liquidity.7

  • Finally, the net expected cash flow is difference between cumulative expected cash outflows and cumulative expected cash inflows in the specified stress test scenario in the period under consideration. In other words, it is the net cumulative liquidity mismatch position under stress measured at the test horizon. The cumulative expected cash outflow multiplies outstanding balances of various categories or types of liabilities and off-balance sheet commitments by rates at which they are expected to run off or be drawn down. The cumulative expected cash inflow multiply outstanding balances of various categories of contractual receivables by rates at which they are expected to flow under the stress scenario up to an 75 percent of total expected cash outflows.

C. Net Stable Funding Ratio (NSFR)

The NFSR has been introduced as a complement to the LCR with the goal of addressing longer-term structural maturity liquidity mismatches in banks balance sheets. It promotes medium and long-term bank funding by setting a minimum acceptable amount of “stable funding” based on the liquidity characteristics of a bank’s assets over a one-year horizon.8 The NSFR will be introduced in 2018 after an observation period starting in 2011.

The NSFR is defined as the ratio between available stable funding and required stable funding. Its main components are the stress scenario and the definitions of stable, available, and required funding. Operationally stable funding sources are given greater weight, while assets that require funding are adjusted by a factor (or haircut) depending on their expected liquidation value. Once taken this into account the ratio must exceed 100 percent (see Annex Table A.2 for details).

  • The stress scenario considers a significant decline in profitability or solvency arising from heighted credit, market or operational risk, or other risk exposures; a downgrade in debt, counterparty credit or deposit rating by a nationally recognized credit rating organization; and an event which calls into question the reputation or credit quality of the institution. Extended borrowing from the central bank lending facilities outside regular open market operations are not considered in the ratio.

  • The stable funding includes those types and amounts of equity and liability financing expected to be reliable sources of funding over one-year horizon under conditions of stress. The available stable funding (ASF) is defined as the total amount of capital; preferred stock with maturity greater than one year; secured and unsecured borrowings and liabilities (including deposits) with effective maturities of one year or greater; proportion of stable wholesale funding, nonmaturity deposits, and/or term deposits with maturities of less than one year expected to stay with the institution for an extended period in an idiosyncratic stress event. The ASF assigns the carrying value of an institution’ equity and liabilities to one of five categories and then multiplies it by a weighting factor.

  • Finally, the required stable funding (RSF) for assets and off-balance sheet exposures is measured using supervisory assumptions on the broad characteristics of the liquidity risk profiles of an institution’s assets, off-balance sheet exposures and selected activities. It is calculated as the sum of assets held and funded by the institution and off-balance sheet activity (or potential liquidity exposure) each of which is adjusted by a factor. The factor aims at capturing the amount of the asset that cannot be monetized through sale or use of collateral in a secured borrowing on an extended basis during a liquidity event lasting one year.

D. Quantitative and Economic Impact of LCR and NSFR

Because banks have different alternatives to accommodate and fulfill the proposed liquidity requirements, evaluating their economic impact is not straightforward. The LCR and NSFR will force some banks to lengthen their term funding. This might lead to an increase in the average spread charged on the entire loan portfolio. Intuitively, average interest rates spreads may widen as liquidity requirements force banks to shift away from cheap short term funding and towards more expensive but stable longer term funding. To maintain profitability (i.e., return on equity) banks are likely to compensate for the higher operational costs by increasing the average spread charged on their entire loan portfolio. Credit supply may also decline, in particular long term, as banks find fulfilling the maturity mismatch more costly.

Evidence shows that a significant number of banks in the BCBS member countries have liquidity shortfalls and will have to lengthen the maturity of their short- and long-term funding (BCBS, 2010b). In particular, the BCBS reports an average LCR of 83 percent for large banks and 98 percent for the remaining banks in its sample by end 2009. This implies a liquidity shortfall of EUR 1.7 trillion for the system. The NSFR for the same group of banks was 93 and 103 percent, respectively, an estimated shortfall of stable funding of EUR 2.9 trillion. These estimates are in line with those found by the IMF in a recent study (IMF, 2011a).

The cost to meet the NSFR is sensitive to the definition of the ratio, assumptions about the composition of banks’ assets and liabilities, and estimates of the returns of different assets and the costs of different liabilities. This information is not disclosed in banks’ financial statements. However, a sense of the costs involved is provided by a recent study that uses the data collected by the BCBS for its Quantitative Impact Study. According to it, banks will have to increase average lending spreads by 24 bps for banks to converge to the required NSFR (King, 2010). The study also finds that the spread declines to 12 bps or less when additional measures adopted in Basel III are included. The reason is that holding higher quality investment lowers the risk weighted assets and, thus capital adequacy requirements.

There are concerns about the ability of the NSFR to signal failures due to liquidity problems. Although it is recognized that the NSFR may have some capacity to signal future liquidity problems, evidence suggests that it would have done so inconsistently prior to the 2007–08 crisis (IMF, 2011a). Although, estimates show that the average NSFR worsened in 2008—slightly falling below 0.95—and improved slightly in 2009; and that liquidity problems surfaced in half of the banks with a NSFR ratio below 80 percent.; its weakness arises because failed banks are found to be evenly distributed across the range of estimated NSFRs for a cross-section of 60 globally oriented banks in 20 countries and three regions (Europe, North America, and Asia).

E. Conclusions

Liquidity requirements are a fundamental microprudential policy tool that can contribute to minimize systemic risk. These measures should improve the resilience of individual institutions and minimize liquidity systemic risks. On the one hand, they help improve the funding structures of banks in good times, thus reducing their exposure to unforeseen liquidity shocks (e.g., fire sales) or to spillovers that may arise in turbulent market times. On the other hand, they can reduce the procyclicality of the financial cycle by increasing the cost of funding. As such, liquidity requirements can be a useful complement to help contain financial and economic excess under the current external financial conditions.

More generally, stressed liquidity requirements help with the identification, measurement, monitoring, and control of liquidity risk. In this regard, the Basel III liquidity framework i.e. the LCR and NSFR, along with the BCBS “Principles for sound liquidity risk management and supervision” (BCBS, 2008) provide a minimum standard for liquidity risk and sets a higher standard for bank-specific analysis, governance, and supervision.

The experiences with liquidity risk frameworks in Australia, Colombia and New Zealand are practical avenues for the immediate implementation of policies aiming at identification, measure, monitor, and control of liquidity risk under stress conditions (see Annex).

Although the impact of these requirements are moderate, the evidence suggests that larger banks are more likely to be affected, rather than smaller ones which tend to be funded with deposits.9 On average these measures are likely to lead to a moderate increase in average interest rates. In the case of New Zealand funding costs relative to the policy rate increased by an equivalent policy tightening of 100–150 basis points. Whatsoever their final impact will depend on its interaction with other measures, including those of Basel III.

More generally, it must be kept in mind that the liquidity requirements describe here are microprudential in nature, and are not specifically designed to address systemic risk. As such, a framework to mitigate system wide, or systemic risk, is highly desirable. However, developing such framework is not straight forward. In the mean time, a well calibrated LCR and NSFR would contribute to the liquidity and funding stability of banks. Nonetheless, to minimize systemic risk, special consideration will have to be taken as to whether these requirements should vary over the cycle or across institutions.

Finally and looking forward, it is important to examine mechanisms to deal with liquidity risks that could take place outside the regulatory perimeter, and how to ring-fence the core financial system from problems arising outside the perimeter. In this respect, more work is required to strengthen the disclosure of detailed information on various liquidity risk measures inside and outside the financial system.

Annex 1. Country Experiences: New Zealand, Colombia, Chile, and Australia

New Zealand

The Reserve Bank of New Zealand (RBNZ) introduced in April 2010 liquidity rules aimed at increasing the bank’s resilience to funding and liquidity shocks of the sort experienced in 2008–09. These rules, which resemble the BCBS ratios, are the Liquidity Mismatch Ratio (LMR) and Core Funding Ratio (CFR) (Annex Tables 3 and 4).10

Their goal is primarily a microprudential one aimed at increasing the banks’ resilience to funding and liquidity shocks. Nonetheless they can also to dampen credit growth during an economic boom by limiting the ability of banks to resort to cheaper short-term off-shore funding markets to support rapid credit expansion (RBNZ, 2010b). Furthermore, they should ensure i) robust liquidity positions measured over short and long horizons, ii) induce robust internal arrangements for liquidity management, and iii) provide clear and useful information to the public and supervisory authorities about liquidity risk and its management.

Full compliance of the policies require banks to shift from short-term (mostly off-shore) funding to long-term maturities or retail deposits. The RBNZ considers that the shift to longer-term funding will tend to increase lending rates (10–20 bps) for any given policy rate depending on the difference in spreads between short- and long-term wholesale funding and how those funding spreads change through the cycle. Nonetheless evidence shows that their announcement increased the banks’ willingness to pay more to attract retail deposits.11 As a result bank funding costs relative to the policy rate increased by an equivalent policy tightening of 100bps, which in turn led to an increase in lending rates relative to benchmark rates (Box 1.9 in IMF, 2010d and Jang, 2010).

Currently all banks in the system comply with the minimum liquidity requirements.

Indeed, the LMR are well above the regulatory minimum of zero. They also hold comfortable funding buffers which exceed the current minimum requirements for the CFR of 65 percent as well as the expected new requirement of 75 percent (Figure A.1 and Annex Table 4).12

Figure A.1:
Figure A.1:

New Zealand, Liquidity Requirements

Citation: IMF Working Papers 2011, 159; 10.5089/9781455297726.001.A003

Source: Reserve Bank of New Zealand.1 Defined as the mismatch dollar amount to total funding. See text for further details.2 Core funding ratio defined as the one-year core funding dollar amount to total loans and advances. See text for further details.

Colombia

The Colombian supervisory authority introduced in April 2009 a liquidity risk management system (SARL due to its name in Spanish).13 The system aims at identifying, measuring, controlling, and monitoring liquidity risk in the trading book and on and off credit institutions’ balance sheet. The system defines a liquidity risk weekly reporting standard of mandatory compliance with no mandatory limits (Annex Table 5). However, credit institutions and upper-level financial cooperatives may design a system with their own models as long as they are consistent with the guidelines set by the supervisory authority.

Taking advantage of SARL the central bank’s financial stability report presents a liquidity risk indicator (IRL) along with additional stress test scenarios. The evidence shows that there are no liquidity shortages in the system i.e. negative IRLs across banks in the system (Figure A.2, left-hand side). Furthermore, only marginal effects were found under a stress scenario in which commercial banks face over the benchmark a deposit run equivalent to 4 percent of current and savings accounts (Figure A.2, right-hand side). Of course, an issue that arises here is how to calibrate the stress scenario.

Figure A.2:
Figure A.2:

Colombia, Liquidity Risk Indicator

Citation: IMF Working Papers 2011, 159; 10.5089/9781455297726.001.A003

Source: Banco de la Republica.Note: Horizontal axis correspond to indiidual banks.1 Ratio of the liquidity gap and total assets ajusted for market liquidity. See text for further details. Execise performed on January 10,2011.2 The stress scenario is a deposit run of 4% of current and savings accounts. See text for further details.

Chile

In its most recent Financial Stability Report, the Central Bank of Chile calculates some approximations of the LCR and NSFR. Its findings show that the Chilean banking system exceeds the minimum requirements (Central Bank of Chile, 2010). It is worth noticing that these estimates have been disclosed despite regulations being based on Basel I.

Australia

The LCR requires financial institutions to hold a large enough stock of high quality liquid assets—normally marketable securities such those issued by governments or by low risk corporate—to offset net cash flows over a 30-day time period. However, for different reasons (e.g., fiscal prudence) these securities are in short supply in Australia.14 To address this situation the Basel III incorporates alternative treatments for the holding of liquid assets. One option is to allow banking institutions to establish a contractual committed liquidity facility provided by the central bank—subject to a fee—that would count toward the LCR requirement.

The Reserve Bank of Australia (RBA) and the Australian Prudential Regulation Authority (APRA) decided on December 2010 that an authorized deposit-taking institution (ADI) would be able to establish a committed secure liquidity facility with the RBA. This facility would be sufficient in size to cover any shortfall between the ADI’s holdings of high-quality liquid assets and the LCR requirement. The qualifying collateral for the facility will comprise all assets eligible for repurchase transactions with the RBA under normal market operations.

The RBA will charge a market-based commitment fee on all institutions who have established a facility with the Bank (i.e. those ADIs to which the Bank has made a funding commitment). This market-based fee will be designed to provide institutions with broadly the same incentives to prudently manage their liquidity as their counterparts in jurisdictions where there is ample supply of high quality liquid assets in their domestic currency. However further details about the design of the fee have yet to be determined. Only the larger ADIs (around 40) will be eligible for the facility and will have to demonstrate to APRA that all steps have been taken to meet their LCR requirements through their own balance sheet management before relying on the RBA facility. The details of the RBA liquidity facility and APRA’s prudential standard on liquidity risk management will be subject to consultation during 2011 and 2012.

Annex Table 1:

The Liquidity Coverage Ratio (LCR)

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Source: IMF staff on the basis of BCBS.
Annex Table 2:

Net Stable Fundig Ratio (NSFR)

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Source: IMF staff on the basis of BCBS.
Annex Table 3:

New Zealand—Liquidity Mismatch Ratios (LMR)

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Source: IMF staff on the basis of RBZN. Note: Ratio is consistent with the BCBS’s Liquidity Coverage Ratio.

Up to a maximum amount from any other provider of 3 percent of total’s bank funding; and a maximum amount from all providers together of 9 percent of the bank’s total funding.

Applying increasing percentages depending on the size.

Other than revolving facilities.

Annex Table 4:

New Zealand - Core Funding Ratio (CFR)

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Source: IMF staff on the basis of RBZN. Note: Ratio is consistent with the BCBS’s Net Stable Funding Ratio.

Including subordinated debt and related party funding.

Annex Table 4:

Colombia—Liquidity risk management system (SARL)

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Source: IMF staff on the basis of Banco de la Republica.1 TES-haircut refer to the haircut applied by the central bank to its repo operations on Treasuries. For other securities the haircut is 20 percent.2 An additional haircut applies to the foreign currency component of their liquid assets (3.7 percent initially). This tries to adjust for exchange rate risk.

Calculated as the maximum percentage of net reduction in the sum of demand deposits that the respective institution may have faced from December 2006 up to the last day of the month immediately prior to the calculation.

1

Prepared by Camilo E. Tovar. Comments by J. Chan-Lau, C. Fernandez, G. Terrier, and R. Valdés are acknowledged.

2

Liquid securities should have certain properties such as being short term, backed by diversified portfolios, and immune from adverse selection when traded i.e. information-insensitive. However, notice that in episodes of liquidity crisis, information-insensitive debt can become information sensitive (Gorton and Metrick, 2010).

3

Liquidity provision at the international level is as aspect that is not considered here. Nonetheless, important advances have been made including, for instance, the mechanisms such as the IMF Flexible Credit Line (FCL).

4

Indicators that gauge the capacity of assets easily converted into cash to cover banks liabilities (e.g., current or quick liquidity ratios).

5

Liquidity requirements can also be linked to the degree of currency mismatches and its maturity. For instance, Mexico imposes a liquidity requirement to address short-term and medium term liquidity concerns that are linked to the currency mismatch and, which is also adjusted by the remaining maturity of this mismatch (see Banco de Mexico’s Circular 2019).

6

The BCBS(2010a,b,c and 2009a,b) has outlined other metrics for monitoring liquidity risk, including a contractual maturity mismatch, concentration funding, available encumbered assets, the LCR by currency, and a market-related tool for monitoring liquidity with little or no time lag (BCBS 2010a).

7

The LCR is expected to be met and reported in a single currency, but banks should meet liquidity needs in each currency. Thus a LCR by currency is expected to be monitored and reported to track currency mismatches.

8

In Brazil (and probably some other emerging markets), medium and long term funding may imply higher FX risks (issuance of bonds abroad).

9

However, in some EMEs this funding structure may not apply. In Brazil, for instance, large banks rely more on deposits than smaller banks.

10

Nonetheless there are relevant differences. First, to ensure that sufficient liquid assets are available to meet any cash flow gap throughout the month the RBNZ introduces a mismatch ratio covering cash flows over a week and over a month. Second, RBZN takes into consideration operational issues for small economies. For example, by taking into account that the definition of highly liquid assets in the LCR fails to recognize the limited range of available local assets for institutions to comply with the ratio, or by proxying run-off rates using a grading system that takes into account the amount of total funding provided by different entities. This also applies to the NSFR. Finally, the RBNZ has taken steps to minimize volatility in the market by setting factors that smooth the transition of financial instruments that change categories among the ASF (e.g., a long dated bond whose weight changes from 100 percent to 0 percent on the day its residual maturity falls below 1 year).

11

Market pressures and a change in bank’s internal preferred maturity profile were also part of the lengthening of funding and the consequent increase in spreads to the policy rate.

12

The RBNZ has left open the possibility of adjusting periodically the CFR, but recognizes the need to monitor it effects on the credit cycle before considering the merits of using it in a countercyclical manner.

13

The Sistema de Administración de Riesgo de Liquidez (SARL) was announced in May 2008. It applies to credit institutions, upper-grade financial cooperatives, trust companies and institutions that manage mutual funds or independent equity.

14

The LCR defines to categories of high quality liquid assets: Level 1 and Level 2 (see Annex Table 1). APRA has reviewed the range of marketable instruments denominated in Australian dollars against the Basel III criteria for high-quality liquid assets. The review has taken into account the amount of the instrument on issue, the degree to which the instrument is broadly or narrowly held, and the degree to which the instrument is traded in large, deep and active markets. APRA has given particular attention to the liquidity of the instrument during the market disruptions of the global financial crisis. Based on this review, APRA has determined that, as of February 2011 the only assets that qualify as Level 1 assets are cash, balances held with the Reserve Bank of Australia, and Commonwealth Government and semi-government securities; and there are no assets that qualify as Level 2 assets.

Policy Instruments to Lean Against the Wind in Latin America
Author: Mr. G. Terrier, Mr. Rodrigo O. Valdes, Mr. Camilo E Tovar Mora, Mr. Jorge A Chan-Lau, Carlos Fernandez Valdovinos, Ms. Mercedes Garcia-Escribano, Mr. Carlos I. Medeiros, Man-Keung Tang, Miss Mercedes Vera Martin, and W. Christopher Walker