Funds transfer pricing
Funds transfer pricing (FTP) is a process used in banking to adjust the reported performance of different business units of a bank. A bank could have different kinds of business units. The split of these units between deposit-raising units and funds-advancing units affects whether they receive a positive or negative revenue adjustment. Both borrowing and lending contribute to the performance of the bank as a whole. FTP is a mechanism to adjust these profitabilities to incorporate true funding costs.
An intermediary is created within the organisation usually treasury or central office. All the fund-raising units raise funds from the market at a particular rate and lend the same to the central office at a higher rate. All the lending units borrow the funds from the central office at a particular rate and lend the same to the borrowers at a higher rate. The central office rate is notional in nature and is aligned to market conditions. Thus for all the units there are two rates available to measure the performance. For a deposit-raising unit the difference between interest paid to the deposit-holders and interest receivable from central office is the contribution to the bank's profitability. For a lending division the difference between Interest payable to central office and the interest received from the borrowers is the contribution to the bank's performance.
FTP is therefore a revenue adjustment made to the bank's Balance Sheet to reflect the cost of funding.
For example, a business unit which manages funds for high-net-worth individuals will create cash which is held on deposit. That deposit will accrue interest and therefore the Wealth business unit's profits will have to be increased by the deposit interest which can easily be calculated by using the prevailing rate of interest.
This approach became problematic during the 2007/8 financial crisis because actual interest rates paid began to differ from published rates such as Libor or bank base rates vary. With poor credit availability, the profit adjustment made in favour of depositing business units was effectively understated. This had been less an issue when banks' borrowing costs were close to base rates or quoted rates such as LIBOR.
Failure to calculate FTP correctly can cause loans to be much less profitable than they initially appear and the fact that banks have extended unprofitable loans is a key factor in the recent financial crisis.
FTP has become important because banks are expected to state their funding costs accurately as a regulatory requirement, because funding costs affect a bank's liquidity reporting. Failure and bail-outs of banks has made reported liquidity a hot topic. FTP calculation is complicated by a number of factors which make calculation of the revenue adjustment necessarily difficult. Factors affecting funding cost include the length of time an asset or liability is repaid (Liquidity Term Premium), the extent to which an asset has been or can be securitised (which affects its liquidity) and the *behaviour* of customers in particular product/customer niches such as customers' propensity to withdraw long-term deposits at a penalty or to repay obligations such as mortgages early, all which affect real funding cost. This behaviour factor complicates the calculation of FTP and has required significant and expensive changes to banking systems. Balance sheets now incorporate new attributes for customer and product which were not previously significant reporting dimensions.
One important issue to be considered in calculating FTP is the need to value funding costs on an "at arms length" basis.
To understand "at arms length" one has to understand how relationships affect behaviour. Some conventional transfer pricing issues can be considered to explore this.
A good example is a father selling a home to his son. The value of such a transfer may not be considered to be the same as what would be achieved on the open market.Similarly businesses often manipulate sales of asset through inter-company trades to maximise profitability in low tax environments.
In banking terms the fact that a loan is made between business units may reflect agreed or contracted recognition of (too low in the financial crisis) costs rather than prevailing actual accurate funding costs and this is both an important audit concern and of taxation interest as transfer pricing affects where and in which business unit profit is reported.
As a result of the attention on funds transfer pricing that resulted from the 2007/2008 financial crises, the U.S. Federal Reserve, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency issued regulatory guidance for large banks formalizing an approach to funds transfer pricing for the first time. The guidance required a number of formalized processes including requiring large banks to prepare funds transfer pricing reports and a standardized funds transfer pricing process be implemented across the institution.
- "Five key points from the interagency funds transfer pricing guidance" (PDF). PwC Financial Services Risk and Regulatory Practice, March, 2016.
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