Document 3
Document 3
Silicon Valley Bank Financial Group (SVBFG) was founded in 1983 and was
headquartered in Santa Clara, California. Prior to its failure, SVBFG was a
financial services company, financial holding company, and bank holding
company with approximately $212 billion in total assets. SVBFG's principal
subsidiary was Silicon Valley Bank (SVB), a California state-chartered bank
with approximately $209 billion in assets that was a member of, and
supervised by, the Federal Reserve System (i.e., state member bank).While
SVBFG had both U.S. and non-U.S. subsidiaries, SVBFG primarily operated in
the U.S. and offered commercial and private banking products and services
through SVB. SVBFG derived substantially all of its revenue from U.S. clients,
and approximately 80 percent of its employees were based in the United
States.
At year-end 1983, SVB's assets were approximately $18 million, and SVBFG
grew gradually through 2019. Between 2019 and 2021, SVBFG tripled in size.
According to SVBFG's earnings release, 2021 was an "exceptional year of
growth driven by outstanding client liquidity" during which low interest rates
were an amplifying factor. SVBFG attributed its deposit growth to clients
"obtaining liquidity through liquidity events, such as IPOs, secondary
offerings, SPAC fundraising, venture capital investments, acquisitions, and
other fundraising activities—which during 2021 and early 2022 were at
notably high levels."
While low interest rates and more-frequent client funding events affected all
financial institutions and their clients, SVBFG saw an outsized impact
because of its concentration in venture capital and start-up clients, and
SVBFG invested these deposits in long-dated securities. SVBFG's assets grew
271 percent from year-end 2018 to year-end 2021, compared to 29 percent
for the banking industry. Asset growth slowed dramatically in 2022 as tech-
sector activity slowed in a rising-interest-rate environment.
SVBFG chose to invest majority of its funds into long term, held to maturity,
govt issued mortgage-based securities. These securities carry a lower risk
when seen from the credit perspective. As of December 31, 2022, SVBFG's
total HTM securities portfolio had a weighted-average duration of 6.2 years,
and the majority of SVBFG's HTM portfolio consisted of agency MBS with a
maturity of 10 years or more
The table given below shows that the share of securities on the portfolio of
SVB was almost double that of large banking organizations(LBOs).
Interestingly the percentage of unsecured deposits was also double that of
LBOs. At the same time, SVBFG's common equity tier 1 capital ratio (12
percent) was 200 basis points higher than the LBO average (10 percent).
As per the SVBFG document sheet cash outflow of the bank increased in
2023 as the clients started to withdraw money for their operations. Concerns
grew after a Financial Times article pointed out SVBFG's substantial
securities portfolio. On March 8, SVBFG announced a restructuring of its
balance sheet, which included the sale of $21 billion in available-for-sale
securities, resulting in a $1.8 billion after-tax loss, and a planned equity
offering of $2.25 billion. The company also informed investors to anticipate
lower growth and income for the fiscal year 2023 due to a continued
slowdown in the tech sector. Additionally, SVBFG mentioned that credit
rating agencies Moody's and S&P were contemplating negative rating
actions. In a message to investors, management expressed concerns about
"continued slow public markets, further declines in venture capital
investment, and ongoing high cash burn," which would impact earnings in
2023. Furthermore, on the same day, Silvergate Capital Corporation
announced plans to shut down operations and liquidate Silvergate Bank,
which further dampened depositor confidence.
The three critical weaknesses of SVBFG were: governance and risk management;
liquidity risk management; and interest rate risk and investment portfolio
management.
A consistent theme across each area is that SVBFG’s practices did not keep pace
with its rapid growth in size and risk. The board of directors’ and risk management’s
experience and capabilities were lacking for a firm that grew to over $200 billion in
assets. With respect to both liquidity and interest rate risk, the management team
was focused on short-term measures of risk and managing to profitability rather
than understanding the longer-term risk exposure.
The Liquidity Target examination in late 2021 provided some insights that SVBFG’s
risk-management practices had not kept pace with its growth.
Observations included that the board had failed to establish appropriate risk
management, internal governance structures were not enough given SVBFG’s
growth, the board lacked large bank experience, and that internal audit
coverage was inadequate.
The CRO was found to not be having necessary experience for a large
financial institution. The CRO left the office in April 2022.
The Governance and Risk Management examination supported the
downgrade to Deficient-1 and CAMELS ratings to “Less than Satisfactory - 3”.
The supervisory team, Reserve Bank leadership, Board staff, and the national
LFBOMG agreed that SVBFG’s safety and soundness did not appear
threatened at the time of the rating.
In early 2023, when SVBFG’s liquidity and interest rate risk management
were deteriorating, a Governance and Control rating of “Deficient-2” should
have been considered.
Liquidity Supervision
An acute liquidity risk event on March 10, 2023 led to the depositors losing
faith in the ability of SVB.
SVBFG relied on a concentrated and largely uninsured deposit base to fund
the bank, and when depositor faith was lost, SVB was not able to meet
depositor withdrawal requests
Supervisors underestimated the liquidity risks which ultimately led to its
downfall.
SVB had a ‘Strong-1” rating which meant relatively low risk. This led to
the examination of liquidity risk management practices during the
CAMELS and BHC exams to not be that extensive. This led to missed
oportunities in finding any issues in the liquidity risk framework.
Year-to-date deposit trends and potential risks heading into 2023 were
first substantively reported by bank management to the SVBFG board
of directors in 2022. The bank management had suggested that more
significant measures had to be taken to deal with the continuous
deposits pressure.
Changing model assumptions and not improving the liquidity position was
not the best way to tackle the problem.
SVBFG had a short term view of IRR through NII rather than the EVE metric.
Management did not consider the risks such as the uniqueness of the
customer base and how it can be impacted by rate increases.
Reports for IRR were not rapid or severe enough that led to poor decisions at
SVBFG
Federal Reserve supervisors did not conduct an indepth review of the interest
rate risk. Instead they were reviewed by the CAMELS exam.
IRR practices showed several levels of concerns that were not raised as
findings. Breaches to the EVE metric were evident in the 2020, 2021 & 2022
exams.
Issues were identified regarding the lack of sensitivity testing, back-testing,
gaps with policies, ineffective control functions, and lack of oversight from
senior management and the board of directors.
Analysis of BASEL-III Disclosures by the Bank
CET1 Ratio:
Total Loans:
Actual: $74.3 billion
Basel III Recommendation: No direct limit but requires adequate provisioning
and risk-weighting for loans.
Non-Performing Loans:
Adequacy required under Basel III, actual figures not detailed in the report
but monitored closely.
Derivative Exposures:
Repo-Style Transactions:
6. Equity Investments
Strong Capital Ratios: SVB exceeded the Basel III minimums for CET1, Tier 1,
and Total Capital Ratios.
Liquidity Stress: A heavy reliance on long-duration securities without
adequate hedging exposed SVB to interest rate risks, violating Basel's stress-
testing recommendations.
Client Concentration Risks: Basel III emphasizes diversification, which SVB
lacked due to its narrow focus on technology and venture capital sectors.
Credit Risk Management: Basel III suggests proactive credit risk mitigation;
however, SVB's exposure to unfunded credit commitments and non-
performing loans indicates room for improvement.
Report by ChatGPT
Introduction
Silicon Valley Bank (SVB), one of the largest banks catering to the tech
industry, collapsed in March 2023, triggering concerns across financial
markets. Its sudden failure was the largest bank collapse since the 2008
financial crisis. The event highlighted significant risk management lapses,
especially in interest rate risk, asset-liability management, and liquidity
management. This report provides a detailed analysis of the collapse,
examining the root causes, contributing factors, and lessons learned.
SVB primarily served startups, tech firms, and venture capital (VC)
investors, resulting in a highly concentrated depositor base.
During the tech boom in 2020-2021, deposits surged as VC funding
reached record levels. SVB's assets ballooned from $71 billion in 2019
to over $200 billion in 2022.
However, this concentration exposed the bank to a downturn in the
tech sector. By 2022, as interest rates rose and VC funding declined,
the deposit base shrank.
3. Liquidity Crisis
Despite its size, SVB was not subject to the stricter regulatory
requirements that apply to systemically important banks.
The 2018 rollback of Dodd-Frank provisions for banks with assets
under $250 billion reduced the frequency and rigor of stress testing for
banks like SVB.
Regulators failed to identify and address the growing interest rate and
liquidity risks in SVB’s portfolio.
2. Contagion Risk
Conclusion
The collapse of Silicon Valley Bank underscores the importance of sound risk
management practices and effective regulatory oversight. While it was a
wake-up call for the banking sector, it also provided valuable lessons on
managing concentration risks, interest rate exposures, and depositor
confidence. Moving forward, a balanced approach that combines regulatory
vigilance and proactive risk management will be essential to prevent similar
failures.