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ANNUAL REPORT AND ACCOUNTS 2008

Risk management

Financial Soundness

Definition

Financial soundness risk has three key risk components covering liquidity and funding risk; capital risk; and financial & prudential regulatory reporting, disclosure and tax risk.

Liquidity and funding

Liquidity risk is defined as the risk that the Group does not have sufficient financial resources to meet its commitments when they fall due, or can secure them only at excessive cost. Funding risk is further defined as the risk that the Group does not have sufficiently stable and diverse sources of funding or the funding structure is inefficient.

In recent months, the strain in the financial systems has increased substantially, leading to a significant tightening in market liquidity with the threat of a more marked deterioration in the global economic outlook, and a consequent increase in recourse to liquidity schemes provided by central banks. Whilst various governments, including the UK Government, have taken substantial measures to ease the current crisis in liquidity, such as the measures announced in the UK on 8 October 2008 and 13 October 2008, there can be no assurance that these global measures will succeed in improving the funding and liquidity of the markets in which the major banks, including Lloyds Banking Group, operate.

Consistent with regulatory requirements, the Banking and Insurance parts of the Group manage their liquidity independently on a standalone basis. Liquidity for all UK based banking business is managed centrally. Liquidity for International banking entities are managed on a standalone basis Liquidity risk in the Insurance business is managed at business unit level and is not considered further in this section.

Risk appetite

Liquidity and funding risk appetite for the banking businesses is set by the board and reviewed on an annual basis. It is reported through various metrics that enable the Group to manage liquidity and funding constraints. The chief executive, assisted by the group asset and liability committee and its sub-committee the senior asset and liability committee, regularly reviews performance against risk appetite. The board reviews liquidity and funding risk on a quarterly basis.

Exposure

Liquidity exposure represents the amount of potential outflows in any future period less committed inflows. Liquidity is considered from both an internal and regulatory perspective.

Measurement

A series of measures are used across the Group to monitor both short and long term liquidity including: ratios, cash outflow triggers, and stress test survival period triggers. Strict criteria and limits are in place to ensure marketable securities are available as part of the portfolio of highly liquid assets.

Mitigation

The Group mitigates the risk of a liquidity mismatch in excess of its risk appetite by managing the liquidity profile of the balance sheet through both short-term liquidity management and long-term funding strategy. Short-term liquidity management is considered from two perspectives; business as usual and crisis liquidity, both of which relate to funding in the less than one year time horizon. Longer term funding is used to manage the Group’s strategic liquidity profile which is determined by the Group’s balance sheet structure. Longer term is defined as having an original maturity of more than one year.

The Group’s funding and liquidity position is underpinned by its significant retail deposit base, accompanied by appropriate funding from the wholesale markets. A substantial proportion of the retail deposit base is made up of customers’ current and savings accounts which, although repayable on demand, have traditionally in aggregate provided a stable source of funding. Additionally, the Group accesses the short-term wholesale markets to raise inter-bank deposits and to issue certificates of deposit and commercial paper to meet short-term obligations. The Group’s short-term money market funding is based on a qualitative analysis of the market’s capacity for the Group’s credit. The Group has developed strong relationships with certain wholesale market segments, and also has access to central banks and corporate customers, to supplement its retail deposit base.

The ability to deploy assets quickly, either through the repo market or through outright sale, is also an important source of liquidity for the Group’s banking businesses. The Group holds sizeable balances of high grade marketable debt securities set out in the Financial risk management section of the financial statements which can be sold to provide, or used to secure, additional short term funding should the need arise from either market counterparties or central bank facilities (ECB, Federal Reserve, Bank of England). During the year the Group increased its stock of liquid assets by £47 billion to £63 billion (2007: £16 billion), which includes government securities, mortgage backed securities, corporate and other debt securities.

Monitoring

Liquidity is actively monitored at business unit and Group level at an appropriate frequency. Routine reporting is in place to senior management and through the Group’s committee structure, in particular the group asset and liability committee and the senior asset and liability committee which meet monthly. In a stress situation the level of monitoring and reporting is increased commensurate with the nature of the stress event. Liquidity policies and procedures are subject to independent oversight.

Daily monitoring and control processes are in place to address both statutory and prudential liquidity requirements. In addition, the framework has two other important components:

  • Firstly, Lloyds Banking Group stress tests its potential cash flow mismatch position under various scenarios on an ongoing basis. The cash flow mismatch position considers on-balance sheet cash flows, commitments received and granted, and material derivative cash flows. Specifically, commitments granted include the pipeline of new business awaiting completion as well as other standby or revolving credit facilities. Behavioural adjustments are developed, evaluating how the cash flow position might change under each stress scenario to derive a stressed cash flow position. Scenarios cover both Lloyds Banking Group name specific and systemic difficulties. The scenarios and the assumptions are reviewed at least annually to gain assurance they continue to be relevant to the nature of the business.
  • Secondly, the Group has a contingency funding plan embedded within the Group Liquidity Policy Statement which has been designed to identify emerging liquidity concerns at an early stage, so that mitigating actions can be taken to avoid a more serious crisis developing.

The information reviewed by the group executive committee, group asset and liability committee and senior asset and liability committee includes analysis set out in
table 1.7.

TABLE 1.7: GROUP BALANCE SHEET

31 December
2008
£bn

31 December
2007
£bn

2008
%
growth

Assets

Loans and advances to customers

242.7

209.8

15.7

Wholesale assets

72.5

57.7

25.6

Banking assets

315.2

267.5

17.8

Total assets

436.0

353.3

23.4

Liabilities

Non-bank deposits

170.9

156.6

9.1

Wholesale funding*

141.4

105.1

34.5

Total Funding

312.3

261.7

19.3

Total liabilities and shareholders equity

436.0

353.3

23.4

*Excludes repos.

Group Retail and Wholesale Funding Mix

Wholesale assets comprise balances arising from banking business and include loans and advances to banks, trading and other financial assets at fair value through profit and loss and available for sale assets. Non-bank deposits comprise balances arising from banking businesses and include customer accounts.

The group balance sheet has grown by 23.4 per cent during the year. The funding for this has been primarily raised in the wholesale markets with customer deposit growth of £14.4 billion.

Wholesale funding has been analysed between that monitored by the London Treasury operations and the Group’s overseas Treasury operations. The wholesale funding shown excludes any repo activity.

The composition and quality of wholesale deposits are reguarly reviewed by management and comprises deposits from corporates and government agencies that roll over on a regular basis and are reinvested.

TABLE 1.8: WHOLESALE FUNDING*

As at
31 December 2008
£bn

As at
31 December 2008
%

As at
31 December 2007
£bn

As at
31 December 2007
%

Bank

27.9

8.9

28.6

10.9

Non-bank

48.7

15.6

39.5

15.1

Wholesale deposits

76.6

24.5

68.1

26.0

Certificates of deposit

27.9

8.9

11.3

4.3

Medium term notes

15.8

5.1

9.1

3.5

Commercial paper

19.9

6.4

17.6

6.7

Securitisation

9.8

3.1

13.3

5.1

Subordinated liabilities

15.9

5.1

11.9

4.5

London Treasury operations

165.9

53.1

131.3

50.1

Other Treasury operations

45.2

14.5

31.8

12.2

Total

211.1

67.6

163.1

62.3

*Table 1.8 excludes repo balances.

TABLE 1.9: RESIDUAL MATURITY OF LONDON TREASURY WHOLESALE FUNDING

As at
31 December
2008
£bn

As at
31 December
2008
%

As at
31 December
2007
£bn

As at
31 December
2007
%

Less than one year

127.8

77.0

107.0

81.5

One to two years

5.7

3.5

5.0

3.8

Two to five years

18.1

10.9

11.1

8.5

More than five years

14.3

8.6

8.2

6.2

Total

165.9

100.0

131.3

100.0

Other Treasury operations include those businesses that are run on a standalone basis in jurisdictions outside London to support local banking businesses often in different time zones. The residual maturity profile of these operations is less than one year.

TABLE 1.10: RECONCILIATION OF AMOUNTS SHOWN ABOVE WITH THE STATUTORY BALANCE SHEET

2008


London Treasury
Functions
£bn


Other
Treasury
Functions
£bn


Repos
£bn


Other
Retail
£bn


Statutory
Balance
Sheet
£bn

Non-bank
(Customer deposits)

48.7

21.0

101.2

170.9

Deposits from banks

27.9

13.7

24.9

66.5

Debt securities
in issue and trading and other liabilities at fair value through profit or loss

73.4

9.1

82.5

Subordinated liabilities

15.9

1.4

17.3

Total

165.9

45.2

24.9

101.2

337.2

2007

London Treasury Functions
£bn

Other
Treasury Functions
£bn

Repos
£bn

Other Retail
£bn

Statutory
Balance Sheet
£bn

Non-bank
(Customer deposits)

39.5

18.5

98.6

156.6

Deposits from banks

28.6

9.8

0.7

39.1

Debt securities
in issue and trading and other liabilities at fair value through profit or loss

51.3

3.5

54.8

Subordinated liabilities

11.9

11.9

Total

131.3

31.8

0.7

98.6

262.4

Capital

Capital risk is defined as the risk that the Group has insufficient capital to provide a sufficient resource to absorb predetermined levels of losses or that the capital structure is inefficient.

Risk appetite

Capital risk appetite is set by the board and reported through various metrics that enable the Group to manage capital constraints and shareholder expectations. The chief executive, assisted by the group asset and liability committee, regularly reviews performance against risk appetite. The board formally reviews capital risk on an annual basis.

Exposure

A capital exposure arises where the Group has insufficient regulatory capital resources to support its strategic objectives and plans, and to meet external stakeholder requirements and expectations. The Group’s capital management policy is focused on optimising value for shareholders.

Measurement

The Group’s regulatory capital is divided into tiers defined by the European Community Banking Consolidation Directive as implemented in the UK by the Financial Services Authority’s General Prudential Sourcebook. Tier 1 capital comprises mainly shareholders’ equity, tier 1 capital instruments and minority interests, after deducting goodwill, other intangible assets and 50 per cent of the net excess of expected loss over accounting provisions and certain securitisation positions. During the year the FSA has defined core tier 1 capital. Accounting equity is adjusted in accordance with FSA requirements, particularly in respect of pensions and available-for sale assets. Tier 2 capital comprises qualifying subordinated debt after deducting 50 per cent of the excess of expected loss over accounting provisions, and certain securitisation positions. The amount of qualifying tier 2 capital cannot exceed that of tier 1 capital. Total capital is reduced by deducting investments in subsidiaries and associates that are not consolidated for regulatory purposes. In the case of Lloyds TSB Group, this means that the net assets of its life assurance and general insurance businesses are excluded from its total regulatory capital.

A number of limits are imposed by the FSA on the proportion of the regulatory capital base that can be made up of subordinated debt and preferred securities. The unpredictable nature of movements in the value of the investments supporting the long-term assurance funds could cause the amount of qualifying tier 2 capital to be restricted because of falling tier 1 resources. The Group seeks to ensure that even in the event of such restrictions the total capital ratio will remain adequate.

The FSA sets Individual Capital Guidance (ICG) for each UK bank calibrated by references to its Capital Resources Requirement (CRR), broadly equivalent to 8 per cent of risk weighted assets and thus representing the capital required under Pillar 1 of the Basel II framework.

Also a key input into the FSA’s ICG setting process (which addresses the requirements of Pillar 2 of the Basel II framework) is each bank’s Internal Capital Adequacy Assessment Process. The FSA’s approach is to monitor the available capital resources in relation to the ICG requirement. The Group has been given an ICG by the FSA and the board has also agreed a formal buffer to be maintained in addition to this requirement. Any breaches of the formal buffer must be notified to the FSA, together with proposed remedial action. No such notification has been made in 2008. The FSA has made it clear that each ICG remains a confidential matter between each bank and the FSA.

In the context of the current market conditions the FSA has made further statements to explain the approach it has taken to the capital framework these include core tier 1 and tier 1 targets under stressed conditions.

The Group has developed procedures meant to ensure that compliance with both current and potential future requirements are understood and that policies are aligned to its risk appetite.

In addition to the regulatory framework, the Group also operates an internal capital framework.

Mitigation

The Group is also able to raise equity either via a rights issue, placing or an open offer. A share placing was undertaken in September and the board also announced in October a further placing and open offer to shareholders as part of its participation in the recapitalisation of the banking sector. The Group is able to raise funds by issuing subordinated liabilities. The cost and availability of subordinated liability finance are influenced by credit ratings. A reduction in these ratings could increase the cost and could reduce market access.

Monitoring

Capital is actively managed at an appropriate level of frequency and regulatory ratios are a key factor in the Group’s budgeting and planning processes with updates of expected ratios reviewed regularly during the year by the Group asset and liability committee. Capital raised takes account of expected growth and currency of risk assets. Capital policies and procedures are subject to independent oversight. Regular reporting of actual and projected ratios is made to the senior asset and liability committee and to the group asset and liability committee.

Capital ratios (Basel II)

 

31 December
2008
£m

 

31 December
2007
£m

Tier 1

   

Share capital and reserves

9,573

 

12,663

Regulatory post-retirement benefit adjustments

435

 

704

Other items

(108)

 

Available-for-sale revaluation reserve and cash flow hedging reserve

2,997

 

402

Goodwill

(2,256)

 

(2,358)

Other deductions

(1,099)

 

(929)

Core tier 1 capital

9,542

 

10,482

Preference share capital

1,966

 

1,589

Innovative tier 1 capital instruments*

3,169

 

1,474

Less: restriction in amount eligible

(976)

 

Total tier 1 capital

13,701

 

13,545

Tier 2

   

Undated loan capital

5,189

 

4,457

Dated loan capital

5,091

 

3,441

Innovative capital restricted from tier 1

976

 

Collectively assessed provisions

21

 

12

Available-for-sale revaluation reserve in respect of equities

8

 

12

Other deductions

(1,099)

 

(928)

Total tier 2 capital

10,186

 

6,994

Total tier 1 and tier 2 capital

23,887

 

20,539

Supervisory deductions

   

Life and pensions businesses

(4,208)

 

(4,373)

Other deductions

(550)

 

(491)

Total supervisory deductions

(4,758)

 

(4,864)

Total capital

19,129

 

15,675

£bn

 

£bn

Risk-weighted assets (unaudited)

   

Credit risk

149.7

 

127.2

Market and counterparty risk

8.5

 

5.3

Operational risk

12.3

 

10.1

Total risk-weighted assets

170.5

 

142.6

Risk asset ratios (unaudited)

   

Core tier 1

5.6%

 

7.4%

Tier 1

8.0%

 

9.5%

Total capital

11.2%

 

11.0%

*A firm is permitted to include innovative tier 1 capital in its tier 1 capital resources for the purposes of GENPRU1.2 (adequacy of financial resources) but is required to exclude these amounts from tier 1 for the purposes of meeting the main BIPRU firm Pillar 1 rules.

Financial and prudential regulatory reporting, disclosure and tax

The risk of reputational damage, loss of investor confidence and/or financial loss arising from the adoption of inappropriate accounting policies, ineffective controls over financial, prudential regulatory and tax reporting and the failure to disclose information on a timely basis about the Group.

Risk appetite

The risk appetite is set by the board and reviewed on an annual basis. It includes the avoidance of the need for restatement of published financial and prudential regulatory data, public disclosures about the Groups financial, including tax, performance and its legal constitution.

Exposure

Exposure represents the sufficiency of the Group’s policies and procedures to maintain adequate books and records to support statutory, prudential and tax reporting, to present and detect financial reporting fraud and to manage the Group’s tax exposure.

Mitigation

The Group maintains a system of internal controls, which are designed to be consistently applied, and to provide a reasonable assurance that transactions are recorded and undertaken in accordance with delegated authorities that permit the preparation and disclosure of financial statements, prudential regulatory reporting and tax returns in accordance with International Financial Reporting Standards, statutory and regulatory requirements.

Monitoring

The Group has in place a disclosure committee whose responsibility is to review all significant disclosures made by the Group and to assist the group chief executive and group finance director fulfill their responsibilities under the Listing Rules and regulations emanating from the Sarbanes-Oxley Act of 2002. A programme of work is undertaken and designed to support an annual assessment of the effectiveness of internal controls over financial reporting, in accordance with the requirements of section 404 of the US Sarbanes-Oxley Act; it also has in place an assurance mechanism over its prudential regulatory reporting; additionally, monitoring activities are designed to identify and maintain tax liabilities and to assess emerging regulation and legislation.

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