All treasurers have to cope with regulatory changes, but treasurers at big financial institutions have been particularly burdened over the past decade by the flood of new capital requirements and banking rules that have been handed down since the financial crisis.
However, James von Moltke, who was named treasurer of Citigroup Inc. in September 2015, notes that his company has met all of the various capital and liquidity requirements that have been set out.
“We feel we’re in compliance with all the capital liquidity rules on a fully phased-in basis,” said von Molke, pictured at right. “We achieved that level at the beginning of this year, with an issuance we did in January.”
The January issuance brought Citi’s total loss-absorbing capacity (TLAC) to 9%, in line with the Fed requirement that becomes effective in January 2019.
New capital requirements “have been a focus point but not a challenge” for Citi, von Moltke said, because the company was well-positioned to meet them. He was quick to credit the work of his predecessor, Eric Aboaf, who left Citi to become CFO of Citizens Financial Group.
“I obviously inherited a balance sheet that he had built largely to meet all those requirements over the years,” he said.
Citi’s work to ensure its balance sheet could meet all of the new requirements entailed some innovation in its debt issuance. For example, last year it was one of the banks pioneering the use of callable debt tailored to the TLAC requirements for systemically important financial institutions.
Under the TLAC rules, a bank’s long-term debt counts less toward the requirement as the debt approaches maturity. Thus, von Moltke said, if the bank “can call it a year before that final maturity and replace the debt with new TLAC-eligible debt, we avoid carrying the debt and the associated coupon for that final year.”
“We and one other firm were the first to issue callable securities with this specific goal in mind,” he added.
Citi offered investors debt that was callable a year before its maturity. The bank has adopted a structure for these TLAC-eligible callables in which the coupon in the final year is a fixed spread over a floating index.
“It sets the incentives, we think, the right way for what TLAC-eligible callable debt is aiming to achieve for the investors,” von Moltke said. “The environment in which it would not be called is one where there’s stress in the marketplace and we might, for liquidity or other reasons, choose not to call [the debt]. In that event, investors are receiving a credit spread that was initially set against our 10-year on a one-year piece of paper.”
Citi’s treasury is also working to diversify its funding sources, von Moltke said. For example, on Monday, Citibank, rather than the holding company, sold a $2.5 billion issue of two-year senior notes.
While other financial institutions have their bank units issue debt, Citi hadn’t done so “for quite a long time,” he said. In addition to diversification, the bank unit has higher ratings than the holding company, making it “efficient funding for us,” he said.
Investment Banking Background
Prior to joining Citi, von Moltke was an investment banker at Morgan Stanley. Citi hired him in 2009 to manage its efforts to divest assets, including those that it had labeled as noncore and grouped in its Citi Holdings unit for disposal, such as its stake in the Smith Barney brokerage unit and retail banking businesses located around the world.
Von Moltke later led Citi’s financial planning and analysis organization, where he worked on such items as the bank’s budgeting process.
“Both those jobs gave me real insight into the firm’s financial processes and an opportunity to partner with the senior leadership both in the finance organization, and across the organization, whether in risk or the businesses,” he said.
Von Moltke said treasury encompasses roughly six or eight disciplines, such as managing an investment portfolio and issuing debt. “What I found is that my career as a banker and then my subsequent career inside Citi had given me exposure to most, if not all, of the practice areas within treasury,” he said. “Obviously I inherited an extremely capable staff, but I’ve worked to deepen my own knowledge and expertise of each of those domains over the last year and a half, since I’ve been in the role.”
Now that Citi has ensured that it is meeting the various capital and liquidity requirements, von Moltke said his main focus is optimizing how it uses its balance sheet.
“The balance sheet at the end of the day should be a reflection of our clients’ business activities,” he said. “What we build and manage around that, around capital funding and liquidity, is what we need to preserve a robust profile in those areas, to meet not just our regulatory requirements but our own internal views about how to manage a balance sheet prudentially.”
That task “entails also working with the businesses to make sure that the balance sheet usage of client activity is well understood and, as a consequence, also well-managed by us as a firm,” he added.
Von Moltke’s also working on expanding the bank’s capabilities and infrastructure in such areas as real-time reporting in the liquidity space and stress-testing, he said, “to be sure that we meet—at least—and hopefully exceed all of the regulatory expectations for the company.”
In terms of regulatory issues, von Moltke said the financial industry is approaching the end of a flood of regulations that were triggered by the financial crisis, including the rules implementing various aspects of Dodd-Frank. “What the market is anticipating is that there will be some amount of re-evaluation of those rules in light of the goals of the new administration,” he said, adding that treasury organizations are equipped with subject matter expertise in many of the areas that may be involved in such a re-evaluation, such as capital planning and interest-rate risk.
Rising interest rates present another challenge, von Moltke said. While the economy has been through rising-rate cycles before, he noted that this time the increases follow an extended period of very low interest rates. “It’s historically unprecedented that we’re in the eighth year of rates very near zero,” he said.
Other factors that could play a role as interest rates head higher include all the new regulations governing banks, which mean banks “are performing their intermediation function in the economy clearly in a different way than in the past,” von Moltke said. And changes in technology may affect customer behavior as rates move higher, given that it’s now much easier for individuals, or companies, to move money from one account to another, or from one bank to another.
“A customer can move money using their iPhone,” he said. “It gives individuals as well as corporate treasurers the ability to be flexible and agile in a changing market environment, which I think is positive for the economy as a whole—but something that banks need to be able to support and manage.”