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1、USD High Value PaymentsTrends and Industry UpdatesVito SabatelliDirectorUSD HVPOpage 2OverviewOperating Hours?21 hour business day begins at 21:00(day before value date)and ends at 18:30(value date)NYT?Extended day allows overlap with business hours in Asia and EMEA?Implemented on May 17,2004?Averag
2、e daily volumes:534,000 transactions for$2.7 Trillion?25 participants account for 50%of total volume and 67%of total value?Mainly domestic transactionsReal-time Gross Settlement System?Owned and Operated by the Federal Reserve Banks(12)managed out of NY FRB?Connects over 9500 participants,nationwide
3、?Participants can be on-line or off-linepage 3Federal Reserve DistrictsAtlantaBostonChicagoClevelandDallasKansas CityMinneapolisNew YorkPhiladelphiaRichmondSt.LouisSan FranciscoThe first two digits of an ABA number denotes the Fed District the participant is resident inpage 4MechanicsReserve Balance
4、:$100,000,000-$25,000,000$75,000,000$25,000,000$25,000,000Reserve Balance:$100,000,000+$25,000,000$125,000,000 Participant AParticipant BFedwireMechanicsPayment is settled on a cash basis with a predetermined intraday credit line1.Debit against the sending Fedwire participants:-Balance in its reserv
5、e account or-Its debit cap2.Credit to the receiving Fedwire participants reserve account3.All completed payments are final and irrevocablepage 5Managing the banks liquidity?Each payment is settled on a cash(balance)and/or a credit(Debit Cap)basis?Credit discipline is controlled through Debit Cap and
6、 charging for Daylight Overdraft.?If a payment requires Debit Cap,the Federal Reserve Bank will calculate and charge daylight overdraft fees on the outstanding balances on a minute by minute basis at an annual rate of 36 basis points(simple interest)?Large dollar payment activity is very scarce in t
7、he early morning.Only large banks tend to participate in these hours?CLS?CHIPS pre-fundingLiquiditypage 6ResiliencyThree Data Centers Aid In Disaster Recovery?Primary processing site with on-site backup?“Hot”backup facility with on-site backup?“Warm”backup facility?Hundreds of miles apart,different
8、regions of the US(Northeast,Southeast,and Southwest)Contingency Testing?Four tests a year?High volume participants are required to take part in three tests with at least one utilizing their backup sitepage 7OverviewMulti-lateral Net Clearing System?Private sector real time USD payment system?Operate
9、d by The Clearing House in New York?11 owner banks 46 participants from 20 countries?85%of payments are completed by 12:00,NYT?CHIPS payments are final and irrevocableOperating Hours20 hour business day begins at 21:00(day before value date)and ends at 17:00(value date),NYTExtended day overlaps with
10、 business hours in Asia and EMEA?Cutoff time is 17:00?Implemented on May 17,2004Average daily volumes:over 363,000 transactions for$2.1 trillionpage 8MechanicsParticipation in each days clearing begins with a pre-funding payment via FedwirePayment Release:?Debit against the sending participants avai
11、lable balance or?Net against all incoming payment(s)to the sending participant regardless of which banks are sending?Therefore,netting can be bi-lateral or multi-lateralTo avoid liquidity gridlocks or credit risks,each participant may not have more than twice their prefunding balance in its account
12、at any one time.Balance:$15,000,000Pay-in:$20,000,000Pay-out:$32,000,000Net:$3,000,000$32,000,000$10,000,000$40,000,000$20,000,000Balance:$0Pay-in:$72,000,000Pay-out:$10,000,000Net:$62,000,000Balance:$55,000,000Pay-in:$10,000,000Pay-out:$60,000,000Net:$5,000,000page 9LiquidityLiquidity(Managing the
13、banks cash position)?Opening position has to be pre-funded by a Fedwire payment.?Liquidity is re-cycled within the system over 500 times-total pre-funding balance of$3.5 billion?Supplemental funding?At 5:00 p.m.,all remaining unsettled payments are netted among participants and settled via Fedwire.?
14、Remaining balance is returned or paid via Fedwire,typically between 5:00 and 5:30 PMpage 10ResiliencyThree Data Centers Aid In Disaster RecoveryWithin New York region:?Primary processing site with on-site backupOutside of Northeast US:?“Hot”backup facility?“Hot”backup facility with on-site backupCon
15、tingency Testing?4 Times a Yearpage 11Background?Message format,content,and business usage all vary widely across different large value payment systems,globally?This may cause situations where at least one party in the payment chain cannot fulfill their business needs when making a large value cross
16、-border payment?Corporate clients,particularly,need remittance information within their wires?Lack of uniformity can result in lost or truncated data as well as message incompatibility throughout various large value payment systemsMessage Format Issuespage 12Payment-Message InteroperabilityNew Forma
17、ts?ISO 20022 UNIFI(UNIversal Financial Industry message scheme)is intended to provide a toolkit for the development of universal XML financial messages to meet the needs of the financial services industry?There are currently six ISO 20022-type messages that are applicable to both CHIPS and Fed payme
18、nts.?Within the new format there would be mandatory and optional fields that pertain to Fedwire and those that would not be needed for Fedwire.?Expansion to 9000 characters permits increased message sizeAssuming that:?The Fed adopts ISO 20022 outright or?Retains the current proprietary format yet pr
19、ovides compatibility with ISO 20022Issues would Include:?Adding or eliminating fields to existing USD wire transfer formats?Changing certain USD wire transfer business practices?Minor changes to the ISO 20022 standardRecent Research and Mapping Efforts(Fed,CHIPS,SWIFT,ISO 20022)page 13Payments Inter
20、operabilityFree text for additional information about the remittance payment.Remittance Free TextAn additional document reference number to describe the remittance payment.When using an invoice for the primary remittance identification information,one might also choose to include a related purchase
21、order number or other specified document number in this field.Secondary Remittance Document InformationThe amount and reason for any additional adjustment deducted from the gross amount of the document being paid.Additional free text to describe the adjustment.Adjustment InformationThe amount of any
22、 negotiated discount deducted from the gross amount of the invoice(or other document).Amount of Negotiated Discount The actual amount being paid for the invoice(or other document).Actual Amount PaidThe gross amount of the invoice(or other document).Gross Amount of Remittance DocumentThe date of the
23、invoice(or other document).Date of Remittance DocumentThe type and identification number of the document being paid(i.e.,an invoice or other specified document).Primary Remittance Document Information The name,address and identification number of the remittance beneficiary.Remittance BeneficiaryThe
24、name,address and account number of the remittance originator.Remittance OriginatorDescriptionCategory NameStandard Remittance Data In Scope page 14Next StepsRemittance Standards?CHIPS and Fed to continue to work with participants to increase support?Incorporate solution with Cover Payment Requiremen
25、ts(MT202Cov)?Finalize decision and adoption of new standards?Prepare specifications and implementation plansGlobal Interoperability?Continue efforts within LVPS Group to ensure global support and interoperability?First meeting in SIBOS 2007?Second Meeting in Paris April 2008?Each LVPS operator to qu
26、estion their participants about interoperability issuespage 15BenefitsUniversal Benefits?“Standards Neutral”to work with many formats?Common data elements also in other formats and globally compatible with ISO 20022 XML format?Provide corporations with more information in each wire transfer message?
27、Explains purpose of payments and facilitates end-to-end straight through processing?Increased OFAC filtering and money laundering controlsDeutsche Banks Response?DB has been an active participant and key driver in meetings held to discuss the ISO 20022 standard at both CHIPS and Fed committee meetin
28、gs?DB responded to CHIPS survey covering interoperability issues?Since DB routinely executes complex cross-border wire transfers on behalf of our Corporate and FI customers,we are in full support of the interoperability initiative-including remittance standard?DB will build the capability to transmi
29、t these standard data elements either to or from our corporate and FI customers if such a decision is madepage 16Current PSR PolicyCurrent Strategy?Federal Reserve charging overdraft fees encourages institutions to minimize their exposure?This leads to late day payment strategies aimed at minimizing
30、 FRB overdraft costs?Late day payment strategies may increase operational risk(e.g.,Systems may go down at 5:00PM leaving payments in queue)Proposed strategy?Explicitly recognizes central banks role in providing increased intraday balances by providing credit facilities?Allows intraday credit to hea
31、lthy depository institutions predominantly through collateralized daylight overdrafts?Collateralized overdrafts will virtually eliminate the day to day risk to Federal Reserve Bank?May lead to different late day payment strategies due to greater willingness to operate in overdraftpage 17Overview of
32、Proposed PSR Policy Changes150 bps136 bpsPenalty fee for ineligible institutionsStreamlined process for certain FBOs up to a limit;minor changes for all institutionsAdditional collateralized capacity above net debit cap for self-assessed institutionsMax capTwo-week average limit is eliminated;adjust
33、ed policy for single-day limitTwo-week average limit and higher single-day limitNet debit cap$150 biweeklyUp to$25 biweeklyFee waiverDeductible is eliminated.Replaced by zero fee for collateralized daylight overdrafts and increased fee waiver 10 percent of an institutions capital measureDeductible 5
34、0 basis points 36 basis pointsFee for uncollateralized daylight overdraftsZero fee 36 basis points Fee for collateralized daylight overdraftsAdditional provision that explicitly applies collateral pledged by healthy institutions to daylight overdrafts in their Reserve Bank accountsRequired for probl
35、em institutions and institutions with max caps only.Collateral eligibility and margins same as discount windowCollateral Proposed policyCurrent policypage 18Voluntary Collateralization?Allows securities held at FRB to offset the daylight overdraft charges?Provides credit risk reduction to Reserve Ba
36、nks?Provides banks with flexibility in crisis and peak liquidity days?Reduces Incentives to queue payments?Increase daylight overdraft fee to 50bp from 36 bp for uncollateralized daylight overdrafts?Serves as incentive to increase pledged collateralA Closer Look at Proposed PSR ChangesMax Caps&FBOs?
37、Streamlined Max Cap procedure for qualifying Foreign Bank Operators(DB is an FBO)?Max cap can be up to 100%of worldwide capital times the capital multiple?Reserve Bank will review financial and supervisory information,prior to approval?Retain single-day cap but eliminate two week average cappage 19D
38、Bs ResponseTesting New PSR Changes?We are currently in the process of evaluating the potential effects of the PSR changes on our business?We are analyzing potential cost saving benefits of the new policy by reviewing past months overdraft balances and charges and applying the new pricing guidelines?
39、The network team is also analyzing data and working with productmanagement to derive new payment strategies in order to hedge our credit risk to maximize the benefits of the PSR policy changes?We worked in conjunction with the Payment Risk Committee and theWholesale Customer Advisory Group to determ
40、ine the potential effects of the new policy on USD payments?We participated in the drafting of a joint response to the FRB outlining the pros and cons of the new policy(as seen by the US Banking community)page 20Patriot ActUS Patriot Act of 2001?Post 9/11 legislation enacted by United States?Designe
41、d to strengthen USAs anti-terrorism efforts?Provides broad new powers to combat global and domestic terrorist activity?Includes laws and regulations that cover correspondent banking accounts domiciled in USA for non-US banksUS Bank Requirements Include:?Taking steps to ensure correspondent banking a
42、ccounts are not being used to provide services to shell banks?Keeping records of the owners of non-US banks that are provided correspondent banking accounts?Obtaining non-US banks appointment of US Agent For Service of Process?Obtaining KYC information about clients and their business activitiespage
43、 21Patriot Act ComplianceNon-US Bank Requirements Include:?Providing ownership information to US correspondent banks?Appointing US Agent for Service of Process?Indicating whether or not it provides services to Shell BanksPenalty for Non-Compliance Includes:?Immediate closing of non-US banks correspo
44、ndent banking accounts in USAPatriot Actpage 22OFAC Details?The enforcement arm of the US Treasury is the Office of Foreign Assets Control?It stipulates that banks operating in the US are required to review all financial transactions and to interdict payments destined for specially designated nation
45、als as defined by Treasurys sanctions guidelines.?In Money Transfer all payments and receipts are screened against the OFAC list?Transactions identified as restricted payments are referred for review and action?Currently,we have in excess of 20,000 entities we are required to filter forOFACpage 23AM
46、L Risk Assessments&Due Diligence?Each new client receives an AML risk assessment?The higher the risk,the greater the amount of due diligence required.All high risk customers must receive“Enhanced Due Diligence.”?Financial institutions are required to verify the identity of the clients?For non-US ban
47、ks,financial institutions must obtain foreign bank certifications(313/319,USA PATRIOT Act).?Prohibit dealings with shell banks?Govern accounts with non-US banks?Require certain ownership information?Designate an agent in the US for service of legal process?US regulators require financial institution
48、s to develop risk-based AML programs?Standard components of AML methodologies for assessing risk include:geographic location,products and services utilized,means of exchange,corporate formations,industries engaged,and associated persons.AML Risk Assessmentspage 24Suspicious Activity ReportingThe fol
49、lowing characterize the legal and regulatory elements of SARs:?Filed with FinCEN(Financial Crimes Enforcement Network),a bureau of the US Treasury?Must be filed 30 days from date of detection?They are a safe-harbor for institution against claims by the party that was the subject of the SAR?Confident
50、iality Protection:The institution will never be required to reveal the fact that a SAR has been filed?Prohibition against disclosure:Strict rules prohibiting disclosure to any outside party(the SAR subject,client,media)?Categories for filing are broad and,?Standard of proof is low(“reason to suspect