Liquidity Risk Management Checklist

Pull the current liquidity risk management policy from the board book and confirm the last board approval date. Most regulators expect annual board review at minimum; flag if the policy is older than 12 months or predates a material balance-sheet shift (deposit run, M&A, new charter activity).

Verify the Asset/Liability Committee charter names current officers — CEO, CFO, Treasurer, CRO, Chief Lending Officer — and that quorum rules and meeting cadence (typically monthly) match what's actually happening. Stale charters with departed officers are a common exam finding.

Refresh the CFP early-warning indicators, named action playbooks, and the cascading funding source order (on-balance-sheet HQLA → FHLB advances → Fed discount window → brokered deposits). Post-2023 exam guidance places heavy weight on operational readiness — pledged collateral pre-positioned, BIC arrangements tested, contact lists current.

Review the basic surplus, loan-to-deposit, non-core funding dependence, and net non-core funding ratios against the board-set tolerance bands. Document any limit excursions in the prior quarter and the ALCO's ratification.

Confirm who is authorized to draw on the FHLB line, pledge to the discount window, and access brokered deposits — and at what dollar threshold management vs. ALCO vs. board approval kicks in. Authority memos signed within the past year.

Model a firm-specific event — adverse exam, ratings downgrade, social-media-driven deposit flight. Use the post-SVB calibration: 30-day uninsured deposit runoff at minimum 40-50% for stress, with day-1/week-1 acceleration. Capture the funding gap by bucket (overnight, 7-day, 30-day, 90-day).

Apply systemic stress assumptions: brokered market closes, FHLB advance haircuts widen, securities market liquidity for Level 2 collateral degrades. Reference the FFIEC liquidity guidance and the most recent supervisory stress assumptions for the institution's asset tier.

Compare modeled deposit decay against last quarter's actual experience by product (DDA, savings, MMDA, retail CD, brokered CD, public funds). Update non-maturity deposit assumptions; document the rationale. Models that haven't been recalibrated since the 2022-2023 rate cycle are stale.

Walk ALCO through the survival horizon under each scenario, the size of the largest cumulative net cash outflow, and any limit breaches. Capture the disposition in the minutes — approval, approval with named remediation, or return for revision.

Address the ALCO's specific concerns — typically tighter runoff assumptions, additional scenarios, or a longer survival horizon — and bring the revised pack to the next ALCO meeting.

Pull the securities portfolio and bucket holdings: Level 1 (cash, central bank reserves, Treasuries, Ginnie Mae); Level 2A (agency MBS, GSE debt at 15% haircut); Level 2B (investment-grade corporate, equities at 50% haircut). Exclude pledged-and-encumbered securities — common error inflates the buffer.

Reconcile pledged loan collateral and securities collateral with the FHLB's reported max credit limit. Confirm the blanket lien filing is current and that the loans tagged as eligible actually meet FHLB's collateral schedule (e.g., 1-4 family residential, owner-occupied CRE within LTV bands).

Run a non-borrowing test pledge through the Federal Reserve's BIC (Borrower-in-Custody) program or DI (Discount and PSR Risk) system. Post-2023, supervisors expect institutions to demonstrate operational readiness, not just paper capacity. Document the test date, collateral pledged, and lendable value confirmed.

For LCR-subject institutions ($250B+), reconcile HQLA numerator and 30-day net cash outflow denominator against the FR 2052a inputs. For community banks, calculate basic surplus (net liquid assets divided by short-term liabilities) per the regulator's formula.

Trigger the CFP playbook: notify the board chair and primary regulator, draw on FHLB or Fed lines per the approval ladder, freeze non-essential outflows, and convene daily ALCO huddles until the buffer is restored. Document each action with timestamp and authorizing officer.

Segment deposits by FDIC/NCUSIF coverage status, by depositor industry (tech, crypto, real estate, public funds), and by top-20 depositor concentration. Post-SVB exam focus: % of total deposits that are uninsured plus the concentration of the largest 10 depositors.

Compare brokered and listing-service deposits to the policy cap and to the regulatory definition under 12 CFR 337.6. Confirm reciprocal deposit treatment and IDI affiliate sweep classifications. Brokered concentration above 10% of total deposits typically draws exam scrutiny.

Lay out FHLB advances, brokered CDs, sub-debt, and any repo by maturity bucket. Flag rollover concentration in any 30-day window above the policy threshold and confirm that maturing wholesale funding has either committed replacement capacity or HQLA backstop.

Touch base with FHLB account officer, primary correspondent banks, and top public-funds depositors. The point is operational — confirm contacts, wire instructions, and that no relationship has changed status. A surprise during a stress event is the failure mode.

Prepare Schedule RC-E (deposits), RC-K (averages), and RC-O (deposit insurance) inputs. For LCR/NSFR-subject institutions, prepare the FR 2052a daily/monthly tape. Reconcile to the GL before submission — Call Report restatements are a finding magnet.

Recalculate available stable funding (ASF) and required stable funding (RSF) factors per the final rule. Confirm the ratio is comfortably above 100% and matches the policy floor. Document any quarter-over-quarter drift greater than 5 percentage points.

File via FFIEC CDR (Call Report) and the Reserve Bank's E-Apps portal as applicable. Confirm filing receipt, retain the confirmation, and circulate to CFO and CCO. Late filings after the 30-day Call Report deadline carry per-day civil money penalties.

Internal audit (or co-sourced auditor) tests model validation, limit monitoring, CFP testing, and reporting accuracy against policy. Findings tracked to closure with named owner and target date — repeat findings across cycles are an MRA signal.

Lodge signed ALCO minutes, the quarterly liquidity package, stress test results, and the CFP attestation in the board book repository. Examiners pull this set first — gaps signal weak governance regardless of the underlying balance sheet.