Purpose / Background:
This document (LM-1 V.5) updates the HKMA's regulatory framework for supervising liquidity risk in Authorized Institutions (AIs). It provides guidance on the application of the Banking (Liquidity) Rules (BLR) and outlines the HKMA's supervisory approach. This version supersedes LM-1 V.4 dated 13.12.2024.
One-line conclusion (what changed / what needs to be done):
This update refines the regulatory framework for liquidity risk supervision, incorporating specific guidance on assets like cryptoassets and detailed requirements for liquidity ratios, impacting all Authorized Institutions. AIs must ensure compliance with updated definitions, calculation methods, and reporting obligations, with a particular focus on the implications of cryptoasset treatment.
Key Changes (3-8 bullets):
- Updated guidance on the treatment of cryptoasset exposures under LCR, LMR, NSFR, and CFR.
- Refined definitions and application of "free from encumbrances" for assets under LCR, LMR, and NSFR.
- Detailed requirements for the recognition of Residential Mortgage-Backed Securities (RMBS) as Level 2B assets under LCR and liquefiable assets under LMR, requiring explicit MA approval.
- Clarified implementation of liquidity ratios on Hong Kong office, unconsolidated, and consolidated bases, including special tailored bases.
- Updated notification requirements for liquidity events and supervisory responses.
- Emphasized the need for AIs to set and maintain internal liquidity targets with a sufficient buffer above regulatory minimums.
Key Dates / Deadlines:
The document is effective from 19.12.2025. Specific ratio requirements (LCR, LMR, NSFR, CFR) have historical implementation dates (e.g., LCR from 2015, NSFR from 2018), and the CFR has phased-in minimums (50% from 2018, 75% from 2019).
Applicability / Impact scope:
Applies to all Authorized Institutions (AIs). Different categories of AIs (Category 1, Category 2, Category 2A) are subject to specific liquidity ratios (LCR, LMR, NSFR, CFR) based on their designation.
Recommended management actions (3-7 actionable bullets):
- Review and understand the updated guidance on cryptoasset treatments and their impact on liquidity ratios.
- Verify that all assets classified as "free from encumbrances" meet the revised definitions and requirements under LCR, LMR, and NSFR.
- Assess the eligibility and seek MA approval for any RMBS intended to be included in HQLA or liquefiable assets, adhering to the stringent criteria.
- Ensure internal liquidity risk management policies and systems are updated to reflect the changes in ratio calculations and reporting obligations.
- Confirm that all notification procedures for liquidity events are aligned with the latest requirements.
- Review and adjust internal liquidity targets to maintain an adequate buffer above the revised regulatory minimums.
- Document overview (nature, purpose, scope)This document, LM-1 "Regulatory Framework for Supervision of Liquidity Risk" Version 5, is a statutory guideline issued by the Monetary Authority (MA) under Section 7(3) of the Banking Ordinance. Its purpose is to provide Authorized Institutions (AIs) with guidance on the application of the Banking (Liquidity) Rules (BLR) and to outline the MA's approach to supervising their liquidity risk. The scope covers all AIs and details the regulatory requirements, supervisory approach, and specific guidance on statutory liquidity ratios. It supersedes LM-1 V.4 (dated 13.12.2024).
- Main requirements (group by topic; state what must be done)
- Liquidity Risk Management: AIs must manage liquidity risk to avoid inability to meet obligations without unacceptable losses. This includes maintaining adequate liquidity and implementing sound systems and controls. Compliance with this module, the BLR, and other relevant supervisory documents is mandatory.
- Statutory Liquidity Requirements:
- Liquidity Coverage Ratio (LCR): Category 1 institutions must maintain an LCR of High-Quality Liquid Assets (HQLA) to total net cash outflows. Minimum LCR levels increased incrementally from 60% in 2015 to 100% from 2019 onwards.
- Liquidity Maintenance Ratio (LMR): Category 2 institutions must maintain an LMR of liquefiable assets to qualifying liabilities (after deductions) of not less than 25% on average each calendar month.
- Net Stable Funding Ratio (NSFR): Category 1 institutions must maintain an NSFR of available stable funding (ASF) to required stable funding (RSF) of not less than 100% at all times, unless self-rectification provisions apply.
- Core Funding Ratio (CFR): Category 2A institutions must maintain a CFR of available core funding (ACF) to required core funding (RCF). Minimums are 50% on average monthly from 2018 and 75% on average monthly from 1 January 2019.
- Implementation Bases: Statutory liquidity ratios must be calculated on a Hong Kong office basis. Locally incorporated AIs with overseas branches must also calculate ratios on an unconsolidated basis (all Hong Kong and overseas business), unless approved for exclusion. Consolidated basis calculation may be required for locally incorporated AIs with associated entities, especially if deemed internationally active. Special tailored bases may also be required in exceptional circumstances.
- Notification of Liquidity Events: AIs have obligations to notify the MA of anticipated changes that could lead to a failure to meet liquidity requirements. Immediate notification is required for specified "relevant liquidity events," including failures to meet ratio requirements, actions involving HQLA monetization, and non-compliance with NSFR or CFR minimums.
- Supervisory Responses: The MA may issue notices requiring remedial action for contraventions of the BLR, potentially leading to more serious measures to maintain banking system stability and protect depositors.
- Internal Targets and Limits: AIs must set internal targets for liquidity ratios with a sufficient buffer above regulatory minimums. These targets must be reviewed and approved by the board at least annually.
- Key changes (vs previous requirements)
- Cryptoasset Treatment: New comprehensive guidance on recognizing cryptoassets under LCR and NSFR, including specific conditions for tokenized claims, stablecoins, and other cryptoassets.
- Encumbrances: Updated detailed guidance on what constitutes "free from encumbrances" for assets under LCR, LMR, and NSFR, with specific ordering for encumbrance of pools of assets.
- RMBS Recognition: Stricter criteria and mandatory MA approval process for recognizing RMBS as Level 2B assets (LCR) or liquefiable assets (LMR), including specific eligibility and performance requirements.
- Consolidation Scope: Clarification on how consolidation for liquidity purposes may differ from capital adequacy, particularly for associated entities like securities or insurance companies.
- Important dates & transition
- LCR: Minimum levels phased in from 60% in 2015 to 100% by 2019.
- NSFR: Came into operation from 1 January 2018.
- CFR: 50% minimum from 2018, 75% minimum from 1 January 2019.
- Document Effective Date: Version 5 is dated 19.12.2025.
- Applicability & impact scopeThis module applies to all Authorized Institutions (AIs). Specific requirements differ based on AI designation:
- Category 1 Institutions: Subject to LCR and NSFR.
- Category 2 Institutions: Subject to LMR.
- Category 2A Institutions: Subject to CFR.The changes, particularly regarding cryptoassets and RMBS, will impact AIs holding or considering holding such assets and those calculating ratios on consolidated bases.
- Compliance action checklist (practical steps)
- Review Document: Thoroughly read LM-1 V.5 and understand all updated requirements.
- Assess Cryptoasset Holdings: Evaluate current and potential cryptoasset exposures against the new recognition criteria for HQLA, LCR outflows/inflows, and NSFR ASF/RSF.
- Verify Asset Encumbrances: Review all assets classified as HQLA or liquefiable assets to ensure they meet the updated definitions of being "free from encumbrances."
- RMBS Review: If holding RMBS, assess their compliance with new qualifying criteria and prepare for MA approval if intended for HQLA/liquefiable asset status.
- Consolidation Scope Confirmation: For AIs subject to consolidated calculations, confirm the scope of associated entities included and update reporting accordingly.
- Internal Limits and Buffers: Review and adjust internal liquidity ratio targets and ensure sufficient buffer above the statutory minimums, considering historical trends.
- Reporting Systems Update: Ensure data collection and reporting systems are capable of accurately reflecting the new requirements, especially for cryptoassets and RMBS.
- Notification Procedures: Confirm that internal procedures for notifying the MA of liquidity events are up-to-date and clearly understood by relevant personnel.
- Appendices/attachments summary (if any; 1-3 sentences each; total <=20%)
- Annex 1: Assets regarded as “free from encumbrances”: This annex clarifies what constitutes an asset "free from encumbrances" for LCR, LMR, and NSFR calculations. It details conditions for pledged assets, pre-positioned assets, and hedging arrangements, and provides an encumbrance order for asset pools.
- Annex 2: Treatment of RMBS: This annex outlines the strict criteria for recognizing Residential Mortgage-Backed Securities (RMBS) as Level 2B assets under LCR and liquefiable assets under LMR, requiring explicit MA approval and demonstrating specific issuer, market, and performance characteristics.
- Annex 3: Guidance on treatments of cryptoasset exposures: This annex provides detailed guidance on how cryptoasset exposures are treated under LCR and NSFR, outlining conditions for recognition as HQLA and the calibration of cash flow and stable funding requirements based on the nature of the cryptoasset (tokenized claims, stablecoins, etc.).