MODERATE · Liquidity
Procedure L-04
Cash and due-from coverage is unusually low
Citation
FFIEC Liquidity and Funds Management Handbook; OCC Comptroller's Handbook, Liquidity booklet
Evidence
Cash and balances at depositories $2,489M against total assets $88,775M. This is a narrow liquidity proxy (cash + interbank balances only) and excludes the institution's unencumbered securities portfolio, which is its primary liquidity buffer at normal sizing. Levels below 4% combined with weak alternative funding sources merit explicit Contingency Funding Plan review.
Recommended action
Provide a full liquidity position report including unencumbered securities (Treasuries, agency MBS), available FHLB / discount window collateral, and 30-day net cash outflow projections. Demonstrate the Contingency Funding Plan addresses scenarios where cash positions decline and securities cannot be sold without loss.