This part outlines the methods
used to provide intraday credit to ensure the smooth functioning of
payment and settlement systems, while controlling credit risk to the
Reserve Banks associated with such intraday credit. These methods
include voluntary collateralization of intraday credit, a limit on
total daylight overdrafts in institutions’ Federal Reserve accounts,
and a fee for uncollateralized daylight overdrafts. This part also
provides a fee waiver to limit the impact of collateralization on
depository institutions that use relatively small amounts of intraday
credit.
To assist institutions in implementing this part of the
policy, the Federal Reserve has prepared two documents: the
Overview
of the Federal Reserve’s Payment System Risk Policy on Intraday Credit (Overview) and the
Guide to the Federal Reserve’s Payment System
Risk Policy on Intraday Credit (Guide).
32 The Overview summarizes the Board’s policy on the provision
of intraday credit, including net debit caps, daylight overdraft fees,
and the fee waiver. This document is intended for use by institutions
that incur only small amounts of daylight overdrafts. The Guide explains
in detail how these policies apply to different institutions and includes
procedures for completing a self-assessment and filing a cap resolution,
as well as information on other aspects of the policy.
9-1013
A. Daylight Overdraft Definition and Measurement
A daylight overdraft occurs when an institution’s
Federal Reserve account is in a negative position during the business
day.
33 The Reserve
Banks use an ex post system to measure daylight overdrafts in institutions’
Federal Reserve accounts. Under this ex post measurement system, certain
transactions, including Fedwire funds transfers, FedNow funds transfers,
book-entry securities transfers, and net settlement transactions,
are posted as they are processed during the business day. Other transactions,
including ACH and check transactions, are posted to institutions’
accounts according to a defined schedule. The following table presents
the schedule used by the Federal Reserve for posting transactions
to institutions’ accounts for purposes of measuring daylight overdrafts.
Procedures for Measuring Daylight Overdrafts34 Opening Balance (Previous Business Day’s Closing
Balance)
Post throughout the business day:
- +/− FedNow funds transfers
+/− Fedwire funds transfers
35
- +/− Fedwire book-entry securities transfers
+/− Fedwire book-entry automated claim adjustments
36
- +/− National Settlement Service entries
- + Fedwire book-entry interest and redemption
payments on securities that are not obligations of, or fully guaranteed
as to principal and interest by, the United States37
- + Electronic payments for matured coupons and
definitive securities that are not obligations of, or fully guaranteed
as to principal and interest by, the United States.38
The term “interest and redemption payments” refers to
payments of principal, interest, and redemption on securities maintained
on the Fedwire Securities Service.
The Reserve Banks will post these transactions, as directed
by the issuer, provided that the issuer’s Federal Reserve account
contains funds equal to or in excess of the amount of the interest
and redemption payments to be made. In the normal course, if a Reserve
Bank does not receive funding from an issuer for the issuer’s interest
and redemption payments by the established cut-off hour of 4:00 p.m.
eastern time on the Fedwire Securities Service, the issuer’s payments
will not be processed on that day.
Post at 8:30
a.m. eastern time:
- +/− Term deposit maturities and accrued interest
- +/− Government and commercial ACH transactions,
including return items39
- +/− Commercial check transactions, including
returned checks40
- + Treasury checks, postal money orders, local
Federal Reserve Bank checks, and savings bond redemptions in separately
sorted deposits; these items must be deposited by the latest applicable
deposit deadline preceding the posting time
- + Advance-notice Treasury investments
- − Penalty assessments for tax payments from
the Treasury Investment Program (TIP).41
Post at 8:30 a.m. eastern time and hourly, on the
half-hour, thereafter:
- +/− Main account administrative investment
or withdrawal from TIP
- +/− Special Direct Investment (SDI) administrative
investment or withdrawal from TIP
- + 31 CFR part 202 account deposits from TIP
- + Credit corrections amounting to
$1 million or more42
- + Credit adjustments amounting to
$1 million or more43
- − Uninvested paper tax (PATAX) deposits from
TIP
- − Main account balance limit withdrawals from
TIP
- − Collateral deficiency withdrawals from TIP
- − 31 CFR part 202 deficiency withdrawals from
TIP.
Post at 8:30 a.m., 1:00 p.m., and 6:30 p.m.
eastern time:
− Main account Treasury withdrawals from TIP.
44
Post by 9:15 a.m. eastern time:
- + U.S. Treasury and government agency Fedwire
book-entry interest and redemption payments45
- + Electronic payments for U.S. Treasury and
government-agency matured coupons and definitive securities.46
Post beginning at 9:15 a.m. eastern time:
− Original issues of Treasury securities.
47
Post at 9:30 a.m. eastern time and hourly, on
the half-hour, thereafter:
- + Federal Reserve Electronic Tax Application
(FR-ETA) value Fedwire investments from TIP.
Post at 11:00 a.m. eastern time and hourly thereafter:
- + Currency and coin deposits.
Post at 12:30 p.m. eastern time and hourly,
on the half-hour, thereafter:
- + Dynamic investments from TIP.
Post by 1:00 p.m. eastern time:
- +/− Commercial check transactions, including
returned checks
- +/− Government and commercial FedACH SameDay
Service transactions, including return items48
- + Same-day Treasury investments.
Post at 5:00 p.m. eastern time:
- +/− Government and commercial FedACH SameDay
Service transactions, including return items49
- + Treasury checks, postal money orders, and
savings bond redemptions in separately sorted deposits; these items
must be deposited by the latest applicable deposit deadline preceding
the posting time
- + Local Federal Reserve Bank checks; these
items must be presented before 3:00 p.m. eastern time.
Post at 5:30 p.m. eastern time:
- +/− Commercial check transactions, including
returned checks.
Post at 6:00 p.m. eastern time:
- +/− Government and commercial FedACH SameDay
Service transactions, including return items50
Post at 6:30 p.m. eastern time:
51
- + Penalty abatements from TIP.
Post at the close of the Fedwire Funds Service and
the FedNow Service:
52
- +/− All other transactions. These transactions
include the following: currency and coin shipments; noncash collection;
term-deposit settlements; Federal Reserve Bank checks presented after
3:00 p.m. eastern time but before 3:00 p.m. local time; foreign check
transactions; small-dollar credit corrections and adjustments; term
deposit settlements; and all debit corrections and adjustments. Discount-window
loans and repayments are normally posted after the close of the Fedwire
Funds Service as well; however, in unusual circumstances a discount
window loan may be posted earlier in the day with repayment 24 hours
later, or a loan may be repaid before it would otherwise become due.
Equals:
Closing Balance.
9-1013.5
B. Collateral
To help meet
institutions’ demand for intraday balances while mitigating Reserve
Bank credit risk, the Board sets forth this policy whereby the Reserve
Banks supply intraday balances and credit predominantly through explicitly
collateralized daylight overdrafts to healthy depository institutions.
53 This policy offers pricing incentives
to encourage greater collateralization (see section II.C.). To avoid
disrupting the operation of the payment system and increasing the
cost burden on a large number of institutions using small amounts
of daylight overdrafts, the use of collateral is generally voluntary.
54
Collateral eligibility and margins remain the
same for PSR policy purposes as for the discount window.
55 Unencumbered collateral can be used to collateralize
daylight overdrafts.
56 In-transit securities
are eligible collateral to pledge for PSR purposes at Reserve Banks’
discretion.
57 All collateral must be acceptable to the Reserve Banks.
9-1014
C. Pricing
Under the voluntary collateralization regime, the fee for collateralized
overdrafts is zero, while the fee for uncollateralized overdrafts
is 50 basis points. The two-tiered fee for collateralized and uncollateralized
overdrafts is intended to provide a strong incentive for a depository
institution to pledge collateral to its Reserve Bank to reduce or
eliminate the institution’s uncollateralized daylight overdrafts
and associated charges for its use of intraday credit.
Reserve Banks charge institutions
for daylight overdrafts incurred in their Federal Reserve accounts.
For each two-week reserve-maintenance period, the Reserve Banks calculate
and assess daylight overdraft fees, which are equal to the sum of
any daily uncollateralized daylight overdraft charges during the period.
Daylight overdraft fees for uncollateralized overdrafts
(or the uncollateralized portion of a partially collateralized overdraft)
are calculated using an annual rate of 50 basis points, quoted on
the basis of a 24-hour day and a 360-day year. The effective daily
rate equals the annual rate divided by 360.
58 An institution’s daily daylight
overdraft charge is equal to the effective daily rate multiplied by
the institution’s average daily uncollateralized daylight overdraft.
An institution’s average daily uncollateralized daylight
overdraft is calculated by dividing the sum of its negative uncollateralized
Federal Reserve account balances at the end of each minute of the
regularly-scheduled business day by the total number of minutes in
the 24-hour business day. A negative uncollateralized Federal Reserve
account balance is calculated by subtracting the unencumbered, net
lendable value of collateral pledged from the total negative Federal
Reserve account balance at the end of each minute. Each positive end-of-minute
balance in an institution’s Federal Reserve account is set to equal
zero. Fully collateralized end-of-minute negative balances are similarly
set to zero.
The daily daylight overdraft charge is reduced by a fee
waiver of $150, which is primarily intended to minimize the burden
of the PSR policy on institutions that use small amounts of intraday
credit. The waiver is subtracted from gross fees in a two-week reserve-maintenance
period.
59
Certain institutions are subject to a penalty fee and
modified daylight overdraft fee calculation as described in section
II.F. The fee waiver is not available to these institutions.
609-1015
D. Net Debit Caps (Uncollateralized Intraday Credit
Capacity)
Each institution incurring uncollateralized
daylight overdrafts in its Federal Reserve account must adopt a net
debit cap, that is, a ceiling on the total uncollateralized daylight
overdraft position that it can incur during any given day. An institution’s
cap category and capital measure determine the size of its net debit
cap. Specifically, the net debit cap is calculated as an institution’s
cap multiple times its capital measure: Net debit cap = cap multiple
× capital measure.
Cap categories and their associated cap levels, set as
multiples of an institution’s capital measure, are listed below:
NET DEBIT CAP
MULTIPLES
Cap category |
Cap multiple |
High
|
2.25 |
Above average
|
1.875 |
Average
|
1.125 |
De minimis
|
0.4 |
Exempt-from-filing61
|
$10 million or 0.20 |
Zero
|
0 |
Pledging collateral does not increase an institution’s
net debit cap, although certain institutions may be eligible to obtain
additional collateralized capacity in excess of their net debit caps
(see section II.E). For the treatment of overdrafts that exceed the
net debit cap, see section II.G.
While capital measures differ, the net debit cap provisions
of this policy apply similarly to foreign banking organizations (FBOs)
and to U.S. institutions. Consistent with practices for U.S.-chartered
depository institutions, the Reserve Banks will advise home-country
supervisors of the daylight overdraft capacity of U.S. branches and
agencies of FBOs under their jurisdiction, as well as of other pertinent
information related to the FBOs’ caps. The Reserve Banks will also
provide information on the daylight overdrafts in the Federal Reserve
accounts of FBOs’ U.S. branches and agencies in response to requests
from home-country supervisors.
1. Eligibility An institution must have regular access
to the discount window in order to adopt a net debit cap greater than
zero. Granting a net debit cap, or any extension of intraday credit,
to an institution is at the discretion of the Reserve Bank. As detailed
in the following matrix, an institution’s eligibility to adopt and
maintain a positive net debit cap depends on the institution’s creditworthiness
as determined by (1) its Prompt Corrective Action (PCA) designation
62 or FBO PSR capital category,
63 and (2) the supervisory rating.
ELIGIBILITY
CRITERIA FOR REQUESTING A POSITIVE NET DEBIT CAP
ELIGIBILITY CRITERIA FOR REQUESTING A POSITIVE
NET DEBIT CAP |
PCA designation/FBO PSR capital category |
Supervisory rating64 |
Strong |
Satisfactory |
Fair |
Marginal or unsatisfactory |
Well capitalized/highly
capitalized
|
Eligible |
Eligible |
Eligible |
Ineligible (zero net debit cap) |
Adequately capitalized/sufficiently
capitalized
|
Eligible |
Eligible |
Eligible |
Ineligible (zero net debit cap) |
Undercapitalized
|
May be eligible subject to a full assessment of creditworthiness |
May be eligible subject to a full assessment of creditworthiness |
Ineligible (zero net debit cap) |
Ineligible (zero net debit cap) |
Significantly
or critically undercapitalized/intraday credit ineligible
|
Ineligible (zero net
debit cap) |
Ineligible (zero net
debit cap) |
Ineligible (zero net
debit cap) |
Ineligible
(zero net debit cap) |
As described further in section II.D.2.a, an institution
seeking to establish a net debit cap category of high, above average,
or average must perform a self-assessment of its own creditworthiness,
intraday funds management and control, customer credit policies and
controls, and operating controls and contingency procedure. An institution
that performs a self-assessment will be deemed ineligible for a positive
net debit cap if its self-assessment results in the lowest possible
rating for any one of the four components of the self-assessment process.
9-1016
2. Cap Categories The policy defines the following six cap categories, described
in more detail below: High, above average, average, de minimis, exempt-from-filing,
and zero. The high, above average, and average cap categories are
referred to as “self-assessed” caps.
a.
Self-assessed. In order to establish a
net debit cap category of high, above average, or average, an institution
must perform a self-assessment of its own creditworthiness, intraday
funds management and control, customer credit policies and controls,
and operating controls and contingency procedures.
65 For domestic institutions, the assessment of creditworthiness is
based on the institution’s supervisory rating and PCA designation.
66 For U.S. branches and agencies of FBOs that are based in jurisdictions
that have implemented capital standards substantially consistent with
those established by the Basel Committee on Banking Supervision, the
assessment of creditworthiness is based on the institution’s supervisory
rating and its FBO PSR capital category.
67 An institution may perform a full assessment of its creditworthiness
in certain limited circumstances—for example, if its condition has
changed significantly since its last examination or if it possesses
additional substantive information regarding its financial condition.
Additionally, U.S. branches and agencies of FBOs based in jurisdictions
that have not implemented capital standards substantially consistent
with those established by the Basel Committee on Banking Supervision
are required to perform a full assessment of creditworthiness to determine
their ratings for the creditworthiness component. An institution performing
a self-assessment must also evaluate its intraday funds-management
procedures and its procedures for evaluating the financial condition
of and establishing intraday credit limits for its customers. Finally,
the institution must evaluate its operating controls and contingency
procedures to determine if they are sufficient to prevent losses due
to fraud or system failures. The Guide includes a detailed explanation
of the self-assessment process.
Each institution’s board of directors must review that
institution’s self-assessment and recommended cap category. The process
of self-assessment, with the board of directors review, should be
conducted at least once in each twelve-month period. A cap determination
may be reviewed and approved by the board of directors of a holding
company parent of an institution, provided that (1) The self-assessment
is performed by each entity incurring daylight overdrafts, (2) the
entity’s cap is based on the measure of the entity’s own capital,
and (3) each entity maintains for its primary supervisor’s review
its own file with supporting documents for its self-assessment and
a record of the parent’s board of directors review.
68
In applying these guidelines, each institu
tion should
maintain a file for examiner review that includes (1) Worksheets and
supporting analysis used in its self-assessment of its own cap category,
(2) copies of senior management reports to the board of directors
of the institution or its parent (as appropriate) regarding that self-assessment,
and (3) copies of the minutes of the discussion at the appropriate
board of directors meeting concerning the institution’s adoption of
a cap category.
69
As part of its normal examination, the institution’s examiners
may review the contents of the self-assessment file.
70 The objective of this
review is to ensure that the institution has applied the guidelines
appropriately and diligently, that the underlying analysis and method
were reasonable, and that the resultant self-assessment was generally
consistent with the examination findings. Examiner comments, if any,
should be forwarded to the board of directors of the institution.
If an examiner has concerns, the Reserve Bank would decide whether
to modify the cap category. For example, if the institution’s level
of daylight overdrafts constitutes an unsafe or unsound banking practice,
the Reserve Bank would likely assign the institution a zero net debit
cap and impose additional risk controls.
The contents of the self-assessment file will be considered
confidential by the institution’s examiner. Similarly, the Federal
Reserve and the institution’s examiner will hold the actual cap level
selected by the institution confidential. Net debit cap information
should not be shared with outside parties or mentioned in any public
documents; however, net debit cap information will be shared with
the home-country supervisor of U.S. branches and agencies of foreign
banks.
The Reserve Banks will review the status of any institution
with a self-assessed net debit cap that exceeds its net debit cap
during a two-week reserve-maintenance period and will decide if additional
action should be taken (see section II.G.).
b.
De minimis. Many institutions incur relatively
small overdrafts and thus pose little risk to the Federal Reserve.
To ease the burden on these small overdrafters of engaging in the
self-assessment process and to ease the burden on the Federal Reserve
of administering caps, the Board allows institutions that meet reasonable
safety and soundness standards to incur de minimis amounts of daylight
overdrafts without performing a self-assessment.
71 An institution may incur daylight overdrafts of up to 40 per
cent of its
capital measure if the institution submits a board of directors resolution.
An institution with a de minimis cap must submit to its
Reserve Bank at least once in each 12-month period a copy of its board
of directors resolution (or a resolution by its holding company’s
board) approving the institution’s use of intraday credit up to the
de minimis level. The Reserve Banks will review the status of any
institution with a de minimis net debit cap that exceeds its net debit
cap during a two-week reserve-maintenance period and will decide if
additional action should be taken (see section II.G.).
c.
Exempt-from-filing. Institutions that only rarely incur daylight overdrafts in their
Federal Reserve accounts that exceed the lesser of $10 million or
20 percent of their capital measure are excused from performing self-assessments
and filing board of directors resolutions with
their Reserve Banks.
72 This dual test of dollar
amount and percent of capital measure is designed to limit the filing
exemption to institutions that create only low-dollar risks to the
Reserve Banks and that incur small overdrafts relative to their capital
measure.
The Reserve Banks will review the status of an exempt
institution that incurs overdrafts in its Federal Reserve account
in excess of $10 million or 20 percent of its capital measure on more
than two days in any two consecutive two-week reserve-maintenance
periods. The Reserve Bank will decide whether the exemption should
be maintained, the institution should be required to file for a cap,
or counseling should be performed (see section II.G.). The Reserve
Bank will assign the exempt-from-filing net debit cap.
d. Zero. Some institutions
that could obtain positive net debit caps choose to have zero caps.
Often these institutions have very conservative internal policies
regarding the use of Federal Reserve intraday credit. If an institution
that has adopted a zero cap incurs a daylight overdraft, the Reserve
Bank counsels the institution and may monitor the institution’s activity
in real time and reject or delay certain transactions that would cause
an overdraft. If the institution qualifies for a positive cap, the
Reserve Bank may suggest that the institution adopt an exempt-from-filing
cap or file for a higher cap if the institution believes that it will
continue to incur daylight overdrafts or overdrafts in excess of its
assigned cap limit.
In addition, a Reserve Bank may assign an institution
a zero net debit cap. Institutions that may pose special risks to
the Reserve Banks, such as those without regular access to the discount
window, those incurring daylight overdrafts in violation of this policy,
those that are ineligible for intraday credit based on their supervisory
rating and PCA designation/FBO PSR capital category (see section II.A),
or those that are otherwise in weak financial condition are generally
assigned a zero cap (see section II.F). Recently chartered institutions
may also be assigned a zero net debit cap.
Certain institutions with zero caps, including institutions
that have been involuntarily assigned a zero cap by a Reserve Bank,
may be eligible to request collateralized capacity from their Reserve
Bank (see sections II.E).
9-1017
3. Capital Measure As described
above, an institution’s cap category and capital measure determine
the size of its net debit cap. The capital measure used in calculating
an institution’s net debit cap depends upon its chartering authority
and home-country supervisor.
a. U.S.-chartered institutions. For institutions
chartered in the United States, net debit caps are multiples of “qualifying”
or similar capital measures that consist of those capital instruments
that can be used to satisfy risk-based capital standards, as set forth
in the capital adequacy guidelines of the federal financial regulatory
agencies. All of the federal financial regulatory agencies collect,
as part of their required reports, data on the amount of capital that
can be used for risk-based purposes—“risk-based” capital for commercial
banks, savings banks, and savings associations and total regulatory
reserves for credit unions. Other U.S.-chartered entities that incur
daylight overdrafts in their Federal Reserve accounts should provide
similar data to their Reserve Banks.
b.
U.S. branches and agencies of foreign banks. For U.S. branches and agencies of foreign banks, net debit caps
on daylight overdrafts in Federal Reserve accounts are calculated
by applying the cap multiples for each cap category to the FBO’s U.S.
capital equiva
lency measure.
73 U.S. capital equivalency is
equal to 10 percent of worldwide capital for FBOs.
74
An FBO that is highly capitalized
75 may be eligible for a streamlined procedure (see
section II.E.) for obtaining additional collateralized intraday credit
under the maximum daylight overdraft capacity provision.
9-1018
E. Collateralized Intraday Credit Capacity
Subject to the approval of its administrative Reserve
Bank, an eligible institution may pledge collateral to secure collateralized
daylight overdraft capacity in addition to uncollateralized capacity
from its net debit cap.
76 The resulting combination of uncollateralized and collateralized
capacity is known as the maximum daylight overdraft capacity (max
cap) and is defined as follows: Maximum daylight overdraft capacity
= net debit cap + collateralized capacity.
77
Once approved, the Reserve Bank will monitor the institution
to ensure that it does not exceed its max cap. Pledging less collateral
reduces an institution’s effective maximum daylight overdraft capacity
level, but pledging more collateral does not increase the maximum
daylight overdraft capacity above the approved max cap level.
1. Eligibility An institution that wishes to expand its daylight overdraft capacity
by pledging collateral should consult with its administrative Reserve
Bank. A domestic institution is eligible to request collateralized
intraday credit if its PCA designation is “undercapitalized,” “adequately
capitalized,” or “well capitalized.”
78 Similarly, an FBO is eligible to request collateralized
intraday credit if its FBO PSR capital category is “undercapitalized,”
“sufficiently capitalized,” or “highly capitalized.”
79 Provided that it meets these capitalization requirements,
an institution may be eligible to request collateralized capacity
even if the institution is not eligible to adopt a positive net debit
cap (see section II.D.1).
2. General Procedure for Requesting Collateralized Capacity If an institution is requesting collateralized capacity
for the first time, it must submit a resolution from its board of
directors indicating its board’s approval of the requested max cap.
Increases to collateralized capacity previously approved by Reserve
Banks will also require a board of directors resolution. In most cases,
an institution will not have to provide to a Reserve Bank a business
case justifying its request for collateralized capacity. However,
an institution must provide a business-case justification if:
- • The institution requests a max cap in excess
of its capital measure multiplied by 2.25; or
- • The administrative Reserve Bank exercises
discretion to require that the institution submit a business-case
justification due to recent developments in the institution’s condition.
Once a Reserve Bank has approved an institution’s collateralized
capacity, the collateralized capacity will remain in place, without
the need for further action by the institution, provided that the
institution maintains the eligibility standards outlined above.
3. Streamlined Procedure for Certain FBOs An FBO that is highly capitalized
80 and has a self-assessed net debit cap may request
from its Reserve Bank a streamlined procedure to obtain a maximum
daylight overdraft capacity. These FBOs are not required to provide
documentation of the business case or obtain a board of directors
resolution for collateralized capacity in an amount that exceeds its
current net debit cap (which is based on 10 percent worldwide capital
times its cap multiple), as long as the requested total capacity is
100 percent or less of worldwide capital times a self-assessed cap
multiple.
81 In
order to ensure that intraday liquidity risk is managed appropriately
and that the FBO will be able to repay daylight overdrafts, eligible
FBOs under the streamlined procedure will be subject to an initial
and periodic review of liquidity plans that are analogous to the liquidity
reviews undergone by U.S. institutions.
82 If an eligible FBO requests
capacity in excess of 100 percent of worldwide capital times the self-assessed
cap multiple, it would be subject to the general procedure.
9-1019
F. Special Situations
Under
the Board’s policy, certain institutions warrant special treatment
primarily because of their charter types. As mentioned previously,
an institution must have regular access to the discount window and
be in sound financial condition in order to adopt a net debit cap
greater than zero. Institutions that do not have regular access to
the discount window include Edge and agreement corporations, bankers’
banks that are not subject to reserve requirements, limited-purpose
trust companies, government-sponsored enterprises (GSEs), and certain
international organizations. Institutions that have been assigned
a zero cap by their Reserve Banks are also subject to special considerations
under this policy based on the risks they pose. In developing its
policy for these institutions, the Board has sought to balance the
goal of reducing and managing risk in the payment system, including
risk to the Federal Reserve, with that of minimizing the adverse effects
on the payment operations of these institutions.
Regular access to the Federal Reserve discount
window generally is available to institutions that are subject to
reserve requirements. If an institution that is not subject to reserve
requirements and thus does not have regular discount-window access
were to incur a daylight overdraft, the Federal Reserve might end
up extending overnight credit to that institution if the daylight
overdraft were not covered by the end of the business day. Such a
credit extension would be contrary to the quid pro quo of reserves
for regular discount-window access as reflected in the Federal Reserve
Act and in Board regulations. Thus, institutions that do not have
regular access to the discount window should not incur daylight overdrafts
in their Federal Reserve accounts.
Certain institutions are subject to a daylight-overdraft
penalty fee levied against the average daily daylight overdraft incurred
by the institution. These include Edge and agreement corporations,
bankers’ banks that are not subject to reserve requirements, and limited-purpose
trust companies. The annual rate used to determine the daylight-overdraft
penalty fee is equal to the annual rate applicable to the daylight
overdrafts of other institutions (50 basis points) plus 100 basis
points. The effective daily overdraft penalty rate equals the annual
penalty rate divided by 360.
83 The daylight-overdraft
penalty rate applies to the institution’s daily average daylight overdraft
in its Federal Reserve account. The daylight-overdraft penalty fee
for these institutions is charged in lieu of, not in addition to,
the daylight overdraft fee that applies to other institutions.
9-1020
1. Edge and Agreement Corporations84 Edge and agreement corporations should
refrain from incurring daylight overdrafts in their Federal Reserve
accounts. In the event that any daylight overdrafts occur, the Edge
or agreement corporation must post collateral to cover the overdrafts.
In addition to posting collateral, the Edge or agreement corporation
would be subject to the daylight-overdraft penalty rate levied against
the average daily daylight overdrafts incurred by the institution,
as described above.
This policy reflects the Board’s concerns that these institutions
lack regular access to the discount window and that the parent company
may be unable or unwilling to cover its subsidiary’s overdraft on
a timely basis. The Board notes that the parent of an Edge or agreement
corporation could fund its subsidiary during the day over Fedwire
or the parent could substitute itself for its subsidiary on private
systems. Such an approach by the parent could both reduce systemic
risk exposure and permit the Edge or agreement corporation to continue
to service its customers. Edge and agreement corporation subsidiaries
of FBOs are treated in the same manner as their domestically owned
counterparts.
9-1021
2. Bankers’ Banks85 Bankers’ banks are exempt from reserve requirements
and do not have regular access to the discount window. Bankers’ banks
should refrain from incurring daylight overdrafts and must post collateral
to cover any overdrafts they do incur. In addition to posting collateral,
a bankers’ bank would be subject to the daylight-overdraft penalty
fee levied against the average daily daylight overdrafts incurred
by the institution, as described above.
The Board’s policy for bankers’ banks reflects the Reserve
Banks’ need to protect themselves from potential losses resulting
from daylight overdrafts incurred by bankers’ banks. The policy also
considers the fact that some bankers’ banks do not incur the costs
of maintaining reserves as some other institutions and do not have
regular access to the discount window.
Bankers’ banks may voluntarily waive their exemption from
reserve requirements, thus gaining access to the discount window.
Such bankers’ banks are free to establish net debit caps and would
be subject to the same policy as other institutions that are eligible
to incur daylight overdrafts. The policy set out in this section applies
only to those bankers’ banks that have not waived their exemption
from reserve requirements.
9-1022
3. Limited-Purpose Trust Companies86 The Federal Reserve Act permits the Board to grant Federal
Reserve membership to limited-purpose trust companies subject to conditions
the Board may prescribe pursuant to the Act. As a general matter,
member limited-purpose trust companies do not accept reservable deposits
and do not have regular discount-window access. Limited-purpose trust
companies should refrain from incurring daylight overdrafts and must
post collateral to cover any overdrafts they do incur. In addition
to posting collateral, limited-purpose trust companies would be sub
ject to the same daylight-overdraft penalty rate as other institutions
that do not have regular access to the discount window.
9-1023
4. Government-Sponsored Enterprises and
International Organizations87 The Reserve Banks act as fiscal agents
for certain GSEs and international organizations in accordance with
federal statutes. These institutions, however, are not subject to
reserve requirements and do not have regular access to the discount
window. GSEs and international organizations should refrain from incurring
daylight overdrafts and must post collateral to cover any daylight
overdrafts they do incur. In addition to posting collateral, these
institutions would be subject to the same daylight-overdraft penalty
rate as other institutions that do not have regular access to the
discount window.
9-1024
5. Problem Institutions For institutions that are in weak financial
condition, the Reserve Banks will impose a zero cap. The Reserve Bank
will also monitor the institution’s activity in real time and reject
or delay certain transactions that would create an overdraft. Problem
institutions should refrain from incurring daylight overdrafts and
must post collateral to cover any daylight overdrafts they do incur.
9-1025
G. Monitoring
1. Ex Post Under the Federal Reserve’s ex post monitoring procedures, an institution
with a daylight overdraft in excess of its maximum daylight overdraft
capacity or net debit cap may be contacted by its Reserve Bank. Overdrafts
above the cap for institutions with de minimis, self-assessed, and
max caps may be treated differently, depending on whether the overdraft
is collateralized.
88 If the overdraft is fully
collateralized, the Reserve Bank may choose not to contact the institution
for up to two incidents per two consecutive two-week reserve-maintenance
periods (the total of four weeks).
Each Reserve Bank retains the right to protect its risk
exposure from individual institutions by unilaterally reducing net
debit caps, imposing (additional) collateralization or balance requirements,
rejecting or delaying certain transactions as described below, or,
in extreme cases, taking the institution offline or prohibiting it
from using Fedwire.
9-1026
2. Real Time A Reserve Bank will apply real-time monitoring
to an individual institution’s position when the Reserve Bank believes
that it faces excessive risk exposure, for example, from problem banks
or institutions with chronic overdrafts in excess of what the Reserve
Bank determines is prudent. In such a case, the Reserve Bank will
control its risk exposure by monitoring the institution’s position
in real time, rejecting or delaying certain transactions that would
exceed the institution’s maximum daylight overdraft capacity or net
debit cap, and taking other prudential actions, including requiring
(additional) collateral.
89 9-1027
3. Multi-District Institutions An institution maintaining merger-transition accounts
or an Edge or agreement corporation that accesses Fedwire through
master accounts in more than one Federal Reserve District is expected
to manage its accounts so that the total daylight overdraft position
across all accounts does not exceed the institution’s net debit cap. One
Reserve Bank will act as the administrative Reserve Bank and will
have overall risk-management responsibilities for an institution maintaining
master accounts in more than one Federal Reserve District. For domestic
institutions that have branches in multiple Federal Reserve Districts,
the administrative Reserve Bank generally will be the Reserve Bank
where the head office of the bank is located.
U.S. branches and agencies of the same foreign
bank (also referred to as an FBO family) are assigned one net debit
cap per FBO family. FBO families that access Fedwire through master
accounts in more than one Federal Reserve District are expected to
manage their accounts so that the daylight overdraft position in each
account does not exceed the capacity allocated to that account from
the FBO family’s net debit cap. The administrative Reserve Bank generally
is the Reserve Bank that exercises the Federal Reserve’s oversight
responsibilities under the International Banking Act.
90 The administrative Reserve Bank, in consultation with the management
of the foreign bank’s U.S. operations and with Reserve Banks in whose
territory other U.S. agencies or branches of the same foreign bank
are located, may recommend that these agencies and branches not be
permitted to incur overdrafts in Federal Reserve accounts. Alternatively,
the administrative Reserve Bank, after similar consultation, may recommend
that all or part of the foreign family’s net debit cap be allocated
to the Federal Reserve accounts of agencies or branches that are located
outside of the administrative Reserve Bank’s District; in this case,
the Reserve Bank in whose Districts those agencies or branches are
located will be responsible for administering all or part of this
policy.
919-1028
H. Transfer-Size Limit on Book-Entry Securities
Secondary-market book-entry securities transfers
on Fedwire are limited to a transfer size of $50 million par value.
This limit is intended to encourage partial deliveries of large trades
in order to reduce position building by dealers, a major cause of
book-entry securities overdrafts before the introduction of the transfer-size
limit and daylight-overdraft fees. This limitation does not apply
to either of the following:
- a. original issue deliveries of book-entry
securities from a Reserve Bank to an institution
- b. transactions sent to or by a Reserve Bank
in its capacity as fiscal agent of the United States, government agencies,
or international organizations.
Thus, requests to strip or reconstitute Treasury
securities or to convert bearer or registered securities to or from
book-entry form are exempt from this limitation. Also exempt are pledges
of securities to a Reserve Bank as principal (for example, discount-window
collateral) or as agent (for example, Treasury Tax and Loan collateral).