14. Risk Management

14.1 Risk Management Framework

The Agency’s responsibility for both the issuance of new debt and the repayment of maturing debt, together with the management of the interest rate and currency profile of the total debt portfolio, makes the management of risk a central and critical element of the Agency’s business. The principal categories of risk arising from the Agency’s National Debt activities are liquidity, market, counterparty credit and operational risk .The Agency has a range of policies and procedures to measure and control the risks involved.

The Agency has approved the NTMA Risk Management Framework to ensure that the Agency manages its risk profile within its agreed risk appetite; that material risks are adequately identified and monitored; and that suitable and effective risk management arrangements are in place, alongside clearly defined and delineated roles and responsibilities. A related suite of risk management policies establishes and maintains limits consistent with the Agency’s risk appetite and commensurate with its strategic goals.

The Agency’s Risk Management Framework is predicated on the three-lines-of-defence model and its organisational structure and risk governance structure are aligned in order to establish clear ownership and accountabilities for risk management. As the first line of defence, the Agency’s Business Units and Corporate Functions are primarily responsible for managing risks on a day-to-day basis, taking into account the NTMA’s risk tolerance and appetite, and in line with its policies, procedures, controls and limits. The second line, which includes the Agency’s Risk Management, Compliance and other control functions, is independent of first line management and operations, and its role is to challenge decisions that affect the organisation’s exposure to risk and to provide comprehensive and understandable information on risks. The Agency Internal Audit Function, which is part of the third line of defence, provides independent, reasonable, risk based assurance to key stakeholders on the robustness of the NTMA’s risk management system, governance and the design and operating effectiveness of the internal control environment.

A number of NTMA Committees and Risk sub-committees support the Agency in discharging its responsibilities in relation to risk management.

Agency Risk Committee (ARC)

The ARC assists the Agency in the oversight of the risk management framework, including setting risk appetite, monitoring adherence to risk governance and ensuring risks are identified, assessed, managed and reported. In addition it oversees the risk management function. It sets standards for the accurate and timely reporting of critical risks and reviews reports on any breaches of risk limits and the adequacy of any proposed action.

Agency Audit Committee

The Audit Committee assists the Agency in the oversight of the quality and integrity of the Agency’s financial statements and reviews and monitors the effectiveness of the systems of internal control, the internal audit process and the compliance function, and reviews and considers the outputs from the statutory auditor.

The ARC and Agency Audit Committee merged on 1 February 2017.

Enterprise Risk Management Committee (ERMC)

The ERMC is a management committee which oversees the implementation of the NTMA’s overall risk appetite and senior management’s establishment of appropriate systems (including policies, procedures and risk limits) to ensure enterprise risks are effectively identified, measured, monitored, controlled and reported, and ensuring that any portfolio concentrations are identified and managed appropriately.

Counterparty Credit Risk Committee (CCRC)

The CCRC oversees and advises the ERMC on counterparty credit risk exposures. It provides dashboard reporting of relevant counterparty credit risk exposures and details to the ERMC. It formulates implements and monitors compliance with the NTMA Counterparty Credit Risk Management Policy and ensures that appropriate actions are taken in respect of any breaches.

Market and Liquidity Risk Committee (MLRC)

The MLRC oversees and advises the ERMC on market and liquidity risk exposures. It provides dashboard reporting of relevant market risk and liquidity risk exposures and details to the ERMC. It formulates implements and monitors compliance with the NTMA Market and Liquidity Risk Management Policies and ensures that appropriate actions are taken in respect of any breaches.

Operational Risk and Control Committee (ORCC)

The ORCC reviews and recommends to the ERMC for approval the operational risk management framework and associated operational risk policies. The ORCC monitors, reviews and challenges the NTMA’s operational risks and reports on operational risk management to the ERMC.

Products and Processes Committee (PPC)

The PPC reviews, challenges and recommends to the ERMC for approval proposals and risk assessments in respect of new products and processes, or material changes to existing products and processes.

A key objective of the Agency is to ensure that the Exchequer has sufficient cash to meet all obligations as they fall due. Ensuring that the Exchequer has sufficient liquidity is one of the Agency’s most critical tasks. Liquidity risks related to the National Debt can arise either from domestic events or, given the high level of linkage between markets, from events outside Ireland. The Agency manages liquidity risk primarily by maintaining appropriate cash buffers, by limiting the amount of liabilities maturing in any particular period of time and by matching the timing and volume of market funding with the projected requirements. This is reinforced by the Agency's activities in maintaining a well informed and diversified international investor base, with a presence in all major capital markets and a broad range of debt instruments which can be issued.

Market risk is the risk of loss or increased costs resulting from changes in the value of assets and liabilities (including off-balance sheet assets and liabilities) due to fluctuations in risk factors such as interest rates, foreign exchange rates or other market prices. The Agency must have regard both to the short term and long term implications of its transactions given its task of managing not only the immediate fiscal debt service costs but also the present value of all future payments of principal and interest. The exposure to interest rate and currency risk is controlled by managing the interest rate and currency composition of the portfolio in accordance with the Agency’s risk appetite. Specific limits are in place to control market risk; exposures against these limits are reported regularly to senior management. As conditions in financial markets change, the appropriate interest rate and currency profile of the portfolio is reassessed in line with periodic limit reviews. The Agency seeks to achieve the best trade-off between cost and risk over time and has in place a hedging programme to manage interest rate and exchange rate risks and to protect the Exchequer from potential volatility in future years. More information on the use of derivatives is set out in Derivatives (note 15).

Counterparty credit risk is the risk of financial loss arising from a financial market transaction as a result of a counterparty failing to fulfil its financial obligations under that transaction and with regard to the National Debt mainly arises from derivatives, deposits and foreign exchange transactions. The level of counterparty credit risk is managed in accordance with the Agency’s risk appetite by dealing only with counterparties of high credit standing. Procedures provide for the approval of risk limits for all counterparties and exposures are reported daily to management. A review of all limits is undertaken periodically to take account of changes in the credit standing of counterparties or economic and political events. In order to mitigate the Exchequer’s exposure to market counterparties while at the same time ensuring that Ireland has efficient market access for its hedging activities, the Agency may enter into credit support arrangements with the market participants with which it wishes to trade – this involves the receipt and posting of collateral to offset the market value of exposures. More information on the use of credit support arrangements is set out in Derivatives (note 15).

Controls have been established to ensure that operational risks are managed in a prudent manner. These controls include the segregation of duties between dealing, processing, payments and reporting.

14.2 National Debt – Currency Composition

The Agency hedges the foreign currency risk of the National Debt through the use of forward foreign exchange contracts and currency swaps. The currency composition of the National Debt, and related currency hedges, are as follows:

Currency
As at 31 December
2016
€m
2015
€m
Debt Instruments
Euro 178,340 175,446
US Dollar 2,448 2,579
Pound Sterling 4,148 5,420
Australian Dollar - 132
Japanese Yen 364 348
Chinese Yuan 524 -
185,824 183,925
Foreign Currency and Swap Contracts
Euro 7,270 7,627
US Dollar (2,450) (2,581)
Pound Sterling (4,148) (5,424)
Australian Dollar - (134)
Japanese Yen (364) (348)
Chinese Yuan (522) -
(214) (860)
National Debt 185,610 183,065

14.3 National Debt – Maturity Profile

The residual maturity profile at year-end of the Medium / Long Term Debt, taking into account the treasury management transactions entered into by the Agency, is as follows:

2016
€m
Due within
1 year
Due between
1-5 Years
Due between
5-10 Years
Due over
10 Years
Total
Irish Government Bonds 6,306 42,764 37,611 34,964 121,645
EU / IMF Funding Programme 21 14,528 6,538 29,211 50,298
Other Medium & Long Term Debt 5 4 331 1,358 1,698
Short Term Debt1 4,629 1,265 0 0 5,894
State Savings2 6,654 7,752 2,786 2 17,194
Cash & Other Financial Assets (9,195) (1,849) (75) 0 (11,119)
National Debt 8,420 64,464 47,191 65,535 185,610

2015
€m
Due within
1 year
Due between
1-5 Years
Due between
5-10 Years
Due over
10 Years
Total
Irish Government Bonds 8,155 50,159 30,450 36,322 125,086
EU / IMF Funding Programme (652) 7,950 11,238 31,211 49,747
Other Medium & Long Term Debt 5 1 331 831 1,168
Short Term Debt1 3,161 765 - - 3,926
State Savings2 6,447 7,903 2,341 1 16,692
Cash & Other Financial Assets (11,286) (2,016) (252) - (13,554)
National Debt 5,830 64,762 44,108 68,365 183,065
  • Short Term Debt has been adjusted to reflect the expected longer maturity of a portion of the Ways and Means monies repayable to the POSBF. Prior year figures have been restated similarly
  • State Savings maturities are based on actual maturity information provided by An Post for end 2016. Prior year figures have been restated similarly

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NOTE 15 >