Contingency Funding Plan Template (Bank Liquidity, CRD Art. 86)

Contingency Funding Plan: [Bank name] [Plan year]

Contingency funding plan (CFP) for a credit institution: the early-warning indicators that show liquidity stress building, the stress stages and who decides at each one, the stress scenarios and survival horizon, the counterbalancing capacity (funding sources and the cash each can raise, after haircuts, and how fast), central bank readiness, the action playbook, communication, intraday and intragroup liquidity, and the testing programme. It is the plan a regulated bank keeps under EU Directive 2013/36/EU (CRD) Article 86, the US Interagency Policy Statement on Funding and Liquidity Risk Management (2010, with the July 2023 addendum on contingency funding plans) and, for US bank holding companies and intermediate holding companies above the Regulation YY thresholds, 12 CFR 252.34(f). It is not a corporate treasury plan: non-financial groups use Liquidity and Funding Plan (finance/liquidity-funding-plan). Basel Committee and PRA material is cited by name and number only; obtain the standard or law for the normative text. Replace every [bracketed] value and every row marked Example. This is a document format, not financial, legal, regulatory or accounting advice.

Document control

Approvals

Revision history

Contents

• 1. Purpose, scope and legal basis
• 2. Governance and decision rights
• 3. Liquidity risk profile and starting position
• 4. Early-warning indicators and triggers
• 5. Stress stages and escalation
• 6. Stress scenarios and survival horizon
• 7. Funding sources and counterbalancing capacity
• 8. Central bank facilities and operational readiness
• 9. Action playbook
• 10. Communication plan
• 11. Intraday, currency and intragroup liquidity
• 12. Testing and maintenance
• 13. Glossary and references
• Standard and licence note

1. Purpose, scope and legal basis

1.1 Purpose

This plan sets out how [Bank name] identifies an emerging liquidity stress, decides on a response and raises or preserves liquidity quickly enough to keep meeting its payment obligations as they fall due, in normal and stressed conditions, without breaching regulatory minimums. The plan is a decision tool rather than a description of liquidity management in general: day-to-day funding, transfer pricing and the buffer calibration live in the ILAAP and the liquidity risk policy, and this document refers to them instead of repeating them.

The plan has three outcomes. First, an early and objective signal: indicators with thresholds that trigger escalation automatically, so that the bank does not wait for judgement to catch up with events. Second, prepared actions: a ranked list of funding and balance-sheet actions with sizes, lead times, owners and preconditions already checked. Third, rehearsed people: named roles, deputies and contact paths that have been tested in a simulation within the last twelve months.

1.2 Scope

1.3 Legal and supervisory basis (as of 2026-10, check local law)

2. Governance and decision rights

2.1 Roles

2.2 Decision rights by stage

3. Liquidity risk profile and starting position

This section anchors the plan in the bank's actual funding structure. A CFP that is calibrated on generic outflow rates rather than the bank's own deposit base will either overstate or understate the risk. Describe the concentration of the funding base (largest depositors, uninsured balances, digital channels that allow very fast withdrawals, wholesale maturities) because these drive how quickly stress can develop. Since 2023, supervisors on both sides of the Atlantic have asked banks to consider faster, social-media-driven deposit runs than earlier calibrations assumed, so state the speed you assume and why.

3.1 Key metrics on the reference date

3.2 Funding profile

Check: 18,000 + 6,000 + 9,000 + 5,000 + 3,000 + 2,400 + 4,000 = 47,400, matching the ILAAP funding profile. Customer deposits in section 3.1 (EUR 33,000 million) are the sum of the three deposit rows. Central bank funding is zero on the reference date; available capacity is in section 8. Shares are rounded to one decimal place.

4. Early-warning indicators and triggers

Early-warning indicators (EWIs) are the first line of the plan. They should be forward-looking, observable at least daily for the fast ones, and calibrated so that an amber reading gives the bank time to act before the LCR or the internal survival horizon is hit. Group them into internal funding indicators, market indicators and macro or systemic indicators. For each, set an amber threshold (escalate and analyse) and a red threshold (propose a stage change). Breaches are judged together: one red indicator on a noisy series may be explained, while several amber readings in the same family are a pattern.

Calibrate thresholds from the bank's own history (for example the worst five-day deposit change in the last ten years), from peer episodes and from the stress scenarios in section 6. Document the calibration in the annex and repeat it annually. The same indicators, or a subset with tighter thresholds, feed the recovery indicators in Recovery Plan (finance/recovery-plan), so align the definitions.

4.1 Indicator catalogue

4.2 Breach handling

When an indicator turns amber, the owner confirms the data within two hours, records the reading in the EWI log and informs the group treasurer. The treasurer decides whether the reading reflects a data problem, a known one-off (such as a large customer moving funds on a pre-announced date) or a genuine signal. Two or more amber readings in the same family, or one red reading, trigger a proposal to declare Stage 1 or Stage 2 as set out in section 5. Each decision not to escalate is written in the log with its rationale, so that later review can test whether the bank ignored a warning.

5. Stress stages and escalation

The stages turn indicator readings into an organisational response. Entry criteria should be objective enough to be applied at 07:00 by the treasurer on duty, with judgement used to move faster rather than to delay. Exit criteria matter too: leaving a stage too early is a common error after a first wave of outflows calms down.

6. Stress scenarios and survival horizon

6.1 Scenario set

The bank runs the three internal scenarios of the ILAAP (idiosyncratic and market-wide over 120 days, combined over 90 days), in addition to the regulatory LCR. The idiosyncratic scenario assumes a loss of confidence in the bank alone (for example after a large fraud loss and a two-notch downgrade). The market-wide scenario assumes a general funding market disruption with falling collateral values. The combined severe scenario overlays both and is the binding scenario for the internal survival horizon limit.

6.2 Combined severe scenario (SCN-L03), cumulative to day 90

Check: 900 + 1,200 + 3,600 + 2,400 + 630 + 420 = 9,150; 9,150 minus 50 = 9,100. The undrawn committed facilities of EUR 4,200 million are the same off-balance-sheet amount as in the ILAAP NSFR and reverse stress calculations. Of the EUR 3,000 million short-term wholesale funding, EUR 2,400 million matures within the 90 days and is assumed not to roll. Loan repayments are assumed to be fully re-lent to protect the franchise, so they add no net inflow. The SME and corporate run-off reflects the concentration of rate-sensitive SME deposits noted in the ILAAP. A real plan models each deposit segment and each maturity separately and documents the source of every rate.

6.3 Survival horizon

The survival horizon is measured on the full counterbalancing capacity of EUR 8,500 million (Tiers A and B in section 7), as in the ILAAP Report (finance/ilaap-report). Between day 60 and day 90 cumulative outflows grow by 1,900; the remaining surplus of 1,300 is used after 30 x 1,300 / 1,900 = 20.5 days, so the survival horizon is about 80 days (60 + 20.5). That meets the risk appetite of 60 days with a margin of about 20 days but is shorter than the 90-day scenario, which is why section 9 lists actions that add capacity early in Stage 1. On HQLA alone the gap turns negative between day 30 and day 60: outflows grow by 2,300 in that period and the remaining 1,360 is used after 30 x 1,360 / 2,300 = 17.7 days, about day 48. This figure is reported for information so that the management body sees how much the plan relies on pre-positioned central bank collateral.

7. Funding sources and counterbalancing capacity

Counterbalancing capacity (CBC) is the cash the bank can generate from its assets and funding options within a given time. Distinguish three tiers. Tier A is the liquidity buffer itself (HQLA held in the treasury's control, unencumbered, and in the right legal entity and currency). Tier B is central bank credit on eligible non-HQLA collateral that has been pre-positioned. Tier C is market actions that take weeks and depend on market conditions, such as new covered bond issuance or a securitisation. Only Tier A counts toward the LCR, but the CFP uses all three with realistic timing.

Check the arithmetic: Tier A 2,000 + 3,600 + 510 + 150 = 6,260; Tier B 2,240 (3,200 x 70%); Tier C 1,000 + 1,500 + 240 = 2,740; total 6,260 + 2,240 + 2,740 = 11,240. The survival horizon in section 6.3 uses Tiers A and B (8,500), because Tier C depends on markets that may be closed in the combined severe scenario.

For every source, record the evidence that it works: the date of the last repo with each counterparty, the last central bank operation, the last cover pool eligibility check. Supervisors increasingly test monetisation in practice, not on paper, and the 2023 US addendum explicitly asks banks that rely on the discount window to keep operational readiness, including periodic test transactions.

8. Central bank facilities and operational readiness

Readiness checklist for each facility: legal agreements signed and current; collateral eligibility rechecked monthly; valuation and haircut data loaded; named staff trained with access rights in the collateral and tender systems; cut-off times listed in the playbook; a test transaction performed within the last [12] months; and the accounting and disclosure consequences of drawing understood by the CFO. Note that the use of emergency liquidity assistance is a central bank decision and is excluded from the counterbalancing capacity so that the plan does not rely on it.

9. Action playbook

Execution rules: every action carries an execution record (date, amount, counterparty, approval reference); the treasurer updates the counterbalancing capacity table after each action; actions that reduce capital (asset sales at a loss) are coordinated with the CFO and the capital plan in the ICAAP Report (finance/icaap-report); and actions listed in the recovery plan as recovery options are not double counted between the two plans.

10. Communication plan

Communication can stabilise or accelerate a run. Prepare messages in advance for each audience and approve them in principle at each annual review, so that only facts need to be filled in. Keep messages factual and consistent across channels, and make sure front-line staff receive the same message as the press at the same time.

11. Intraday, currency and intragroup liquidity

11.1 Intraday liquidity

Monitor the largest intraday net cumulative outflow, the timing of critical payments, the intraday credit available from the central bank against collateral, and the share of payments made after their usual time. Under stress, counterparties may delay their payments to the bank while expecting the bank's payments on time, so the plan sets a payment prioritisation order (time-critical obligations such as settlement system and central bank payments first) and names who may throttle discretionary outgoing payments.

11.2 Significant currencies

11.3 Intragroup liquidity

Document each intragroup facility, its legal capacity, any regulatory or tax restriction on transfer (large exposure limits, local liquidity requirements for branches and subsidiaries, ring-fencing), and the operational steps to move funds. In the example the leasing subsidiary is funded by the parent through a committed intragroup line of EUR 1,200 million, and the New York branch is subject to US requirements that may limit how quickly liquidity can be returned to the head office.

12. Testing and maintenance

12.1 Testing programme

12.2 Findings log

12.3 Maintenance triggers

Update the plan within [30] days when: the annual ILAAP is approved; a test produces a material finding; the funding mix changes by more than [10] percentage points in any line; a new legal entity, branch or significant currency is added; a central bank changes collateral rules that affect more than [10]% of Tier B; or regulation changes (for example the application of revised SREP guidelines EBA/GL/2026/06 from 2027-01-01).

12.4 Requirement coverage map

The 12 CFR 252.34(f) rows are mapped for illustration only: Regulation YY subpart D binds US bank holding companies with USD 100 billion or more of assets, and Fernhollow's New York branch is below the Regulation YY liquidity thresholds for foreign banking organisations, so it follows SR 10-6 and the 2023 addendum. A bank that is in scope keeps this map as evidence for its examiners. | Basel Principles for Sound Liquidity Risk Management, Principle 11 | Whole plan | Name and number only |

13. Glossary and references

13.1 Glossary

13.2 References

Standard and licence note

Based on Directive 2013/36/EU Article 86, Regulation (EU) No 575/2013, EBA guidelines cited by number, the US Interagency Policy Statement on Funding and Liquidity Risk Management with its 2023 addendum, 12 CFR 252.34 and OCC Bulletin 2026-10 (US federal works in the public domain; EU texts reused with acknowledgement of the source). The Basel Committee principles and the PRA supervisory statement are cited by name and number only; no text from them is reproduced. The structure, indicators, thresholds and all wording are original to this template. Fernhollow Bank and every figure are fictional and are not a calibration recommendation. Check the current official version of each cited text and your national transposition before use. Template licence: MIT.