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Item 7A. Quantitative and Qualitative Disclosures About Market Risk

2023-11-21 compared with 2022-11-22 · 53 added, 68 removed, 68 unchanged (64% of the section changed)

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Further, the Board has established the Directors Risk Committee, which, among other responsibilities, conducts regular oversight and review of the guidelines, policies and deliberations of the Asset/Liability Management Committee.

We have sought to manage our interest rate risk in order to control the exposure of our earnings and capital to changes in interest rates.

As part of our ongoing asset-liability management, we use the following strategies to manage our interest rate risk:

(i) marketing adjustable-rate and shorter-maturity (10-year, fixed-rate mortgage) loan products;

(ii) lengthening the weighted average remaining term of major funding sources, primarily by offering attractive interest rates on deposit products, particularly longer-term certificates of deposit, and through the use of longer-term advances from the FHLB of Cincinnati (or shorter-term advances converted to longer-term durations via the use of interest rate exchange contracts that qualify as cash flow hedges) and longer-term brokered certificates of deposit;

(iii) investing in shorter- to medium-term investments and mortgage-backed securities;

(iv) maintaining the levels of capital in excess of what is required for "well capitalized" designation;

(v) securitizing and/or selling long-term, fixed-rate residential real estate mortgage loans.

During the fiscal year ended September 30, 2022, $128.1 million of agency-compliant, long-term, fixed-rate mortgage loans were sold to Fannie Mae on a servicing retained basis.

At September 30, 2022, $9.7 million of agency-compliant, long-term, fixed-rate residential first mortgage loans were classified as "held for sale".

Of the agency compliant loan sales during the fiscal year ended September 30, 2022, $28.8 million was comprised of long-term, (15 to 30 years), fixed-rate first mortgage loans which were sold under Fannie Mae's Home Ready program;

and $99.3 million was comprised of long-term (15 to 30 years), fixed-rate first mortgage refinance loans which were sold to Fannie Mae, as described in the next paragraph.

First mortgage loans (primarily fixed-rate, mortgage refinances with terms of 15 years or more, and Home Ready) are generally originated under Fannie Mae procedures and are eligible for sale to Fannie Mae either as whole loans or within mortgage-backed securities.

We expect that certain loan types (i.e.

our Smart Rate adjustable-rate loans, home purchase fixed-rate loans and 10-year fixed-rate loans) will continue to be originated under our legacy procedures, which are not eligible for sale to Fannie Mae.

For loans that are not originated under Fannie Mae procedures, the Association’s ability to reduce interest rate risk via loan sales is limited to those loans that have established payment histories, strong borrower credit profiles and are supported by adequate collateral values that meet the requirements of the FHLB's Mortgage Purchase Program or of private third-party investors.

The Association actively markets home equity lines of credit, an adjustable-rate mortgage loan product and a 10-year fixed-rate mortgage loan product.

Each of these products provides us with improved interest rate risk characteristics when compared to longer-term, fixed-rate mortgage loans.

Shortening the average maturity of our interest-earning assets by increasing our investments in shorter-term loans and investments, as well as loans and investments with variable rates of interest, helps to better match the maturities and interest rates of our assets and liabilities, thereby reducing the exposure of our net interest income to changes in market interest rates.

The Association evaluates funding source alternatives as it seeks to extend its liability duration.

Extended duration funding sources that are currently considered include:

retail certificates of deposit (which, subject to a fee, generally provide depositors with an early withdrawal option, but do not require pledged collateral);

brokered certificates of deposit (which generally do not provide an early withdrawal option and do not require collateral pledges);

collateralized borrowings which are not subject to creditor call options (generally advances from the FHLB of Cincinnati);

and interest rate exchange contracts ("swaps") which are subject to collateral pledges and which require specific structural features to qualify for hedge accounting treatment (hedge accounting treatment directs that periodic mark-to-market adjustments be recorded in other comprehensive income (loss) in the equity section of the balance sheet rather than being included in operating results of the income statement).

The Association's intent is that any swap to which it may be a party will qualify for hedge accounting treatment.

The Association attempts to be opportunistic in the timing of its funding duration deliberations and when evaluating alternative funding sources, compares effective interest rates, early withdrawal/call options and collateral requirements.

The Association is a party to interest rate swap agreements.

Each of the Association's swap agreements is registered on the Chicago Mercantile Exchange and involves the exchange of interest payment amounts based on a notional principal balance.

No exchange of principal amounts occurs and the notional principal amount does not appear on our balance sheet.

The Association uses swaps to extend the duration of its funding sources.

In each of the Association's agreements, interest paid is based on a fixed rate of interest throughout the term of each agreement while interest received is based on an interest rate that resets at a specified interval (generally three months) throughout the term of each agreement.

On the initiation date of the swap, the agreed upon exchange interest rates reflect market conditions at that point in time.

Swaps generally require counterparty collateral pledges that ensure the counterparties' ability to comply with the conditions of the agreement.

The notional amount of the Association's swap portfolio at September 30, 2022 was $1.55 billion.

The swap portfolio's weighted average fixed pay rate was 1.88% and the weighted average remaining term was 2.7 years.

Concurrent with the execution of each swap, the Association entered into a short-term borrowing from the FHLB of Cincinnati in an amount equal to the notional amount of the swap and with interest rate resets aligned with the reset interval of the swap.

Each individual swap agreement has been designated as a cash flow hedge of interest rate risk associated with the Company's variable rate borrowings from the FHLB of Cincinnati.

We manage our interest rate risk in order to control the exposure of our earnings and capital to changes in interest rates.

Refer to the Overview section of Item 7 for additional discussion on how we manage interest rate risk.

Economic Value of Equity .

Using customized modeling software, the Association prepares periodic estimates of the amounts by which the net present value of its cash flows from assets, liabilities and off-balance sheet items (the institution’s economic value of equity or EVE) would change in the event of a range of assumed changes in market interest rates.

Using customized modeling software, the Company and Association prepare periodic estimates of the amounts by which the net present value of cash flows from assets, liabilities and off-balance sheet items (the institution’s economic value of equity or EVE) would change in the event of a range of assumed changes in market interest rates.

The simulation model uses a discounted cash flow analysis and an option-based pricing approach in measuring the interest rate sensitivity of EVE.

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The model is tailored specifically to our organization, which, we believe, improves its predictive accuracy.

The following table presents the estimated changes in the Association’s EVE at September 30,

2022 that would result from the indicated instantaneous changes in the United States Treasury yield curve and other relevant market interest rates.

Computations of prospective effects of hypothetical interest rate changes are based on numerous assumptions, including relative levels of market interest rates, loan prepayments and deposit decay, and should not be relied upon as indicative of actual results.

The following table presents the estimated changes in the Company's EVE at September 30, 2023 that would result from the indicated instantaneous changes in the United States Treasury yield curve and other relevant market interest rates.

TFS Financial Corporation

Interest Rates

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-200 1,422,575 168,597 13.44 % 8.83 % 62

-300 1,411,363 157,385 12.55 % 8.56 % 35

The following table presents the estimated changes in the Association's EVE at September 30, 2023 that would result from the indicated instantaneous changes in the United States Treasury yield curve and other relevant market interest rates.

Third Federal Savings and Loan Association

Interest Rates

(basis points) (1) Estimated

EVE (2) Estimated Increase

(Decrease) in EVE EVE as a Percentage

of Present Value of

Ratio (4) Increase

(basis points)

Amount Percent

(Dollars in thousands)

+300 $ 519,419 $ (512,967) (49.69) % 3.71 % (306)

+200 707,707 (324,679) (31.45) % 4.91 % (186)

+100 889,739 (142,647) (13.82) % 6.00 % (77)

0 1,032,386 — — % 6.77 % —

-100 1,143,898 111,512 10.80 % 7.30 % 53

-200 1,200,628 168,242 16.30 % 7.46 % 69

-300 1,189,237 156,851 15.19 % 7.22 % 45

_________________

(1) Assumes an instantaneous uniform change in interest rates at all maturities.

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(4) EVE Ratio represents EVE divided by the present value of assets.

The table above indicates that at September 30, 2022, in the event of an increase of 200 basis points in all interest rates, the Association would experience a 29.92% decrease in EVE.

In the event of a 100 basis point decrease in interest rates, the Association would experience a 11.43% increase in EVE.

The following table is based on the calculations contained in the previous table, and sets forth the change in the EVE at a +200 basis point rate of shock at September 30, 2022, with comparative information as of September 30, 2021.

The tables above indicate that at September 30, 2023, in the event of an increase of 200 basis points in all interest rates, the Company and Association would experience a 25.92% and 31.45% decrease in EVE, respectively.

In the event of a 100 basis point decrease in interest rates, the Company and Association would experience a 8.91% and 10.80% increase in EVE, respectively.

The following tables are based on the calculations contained in the previous tables, and set forth the change in the EVE at a +200 basis point rate of shock at September 30, 2023, with comparative information as of September 30, 2022.

By regulation, the Association must measure and manage its interest rate risk for interest rate shocks relative to established risk tolerances in EVE.

TFS Financial Corporation

At September 30,

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Percentage Change in EVE Ratio (25.92) % (20.25) %

Certain shortcomings are inherent in the methodologies used in measuring interest rate risk through changes in EVE.

Modeling changes in EVE require making certain assumptions that may or may not reflect the manner in which actual yields and costs respond to changes in market interest rates.

Third Federal Savings and Loan Association

At September 30,

Risk Measure (+200 bp Rate Shock) 2023 2022

Pre-Shock EVE Ratio 6.77 % 9.08 %

Post-Shock EVE Ratio 4.91 % 6.71 %

Sensitivity Measure in basis points (186) (237)

Percentage Change in EVE Ratio (31.45) % (29.92) %

The manner in which actual yields, costs and consumer behavior respond to changes in market interest rates may vary from the inherent methodologies used to measure interest rate risk through changes in EVE.

In this regard, the EVE tables presented above assume:

• no new growth or business volumes;

• that the composition of our interest-sensitive assets and liabilities existing at the beginning of a period remains constant over the period being measured, except for reductions to reflect mortgage loan principal repayments along with modeled prepayments and defaults;

• that a particular change in interest rates is reflected uniformly across the yield curve regardless of the duration or repricing of specific assets and liabilities.

Accordingly, although the EVE table provides an indication of our interest rate risk exposure as of the indicated dates, such measurements are not intended to and do not provide a precise forecast of the effect of changes in market interest rates on our EVE and will differ from actual results.

In addition to our core business activities, which primarily sought to originate Smart Rate (adjustable), home equity lines of credit (adjustable) and 10-year fixed-rate loans funded by borrowings from the FHLB and intermediate term CDs (including brokered CDs) and which are intended to have a favorable impact on our IRR profile, the net impact of several other items resulted in the 21.70% deterioration in the Pre-Shock EVE Ratio (base valuation) measure at September 30, 2022, when compared to the measure at September 30, 2021.

Factors contributing to this decline

included changes in market rates, capital actions by the Association, and changes due to business activity.

Negatively impacting the Percentage Change in EVE was a $56.0 million cash dividend that the Association paid to the Company in December 2021.

Because of its intercompany nature, this payment had no impact on the Company's capital position, or the Company's overall IRR profile, but reduced the Association's regulatory capital and regulatory capital ratios and negatively impacted the Association's Percentage Change in EVE.

Accordingly, although the EVE tables provide an indication of our interest rate risk exposure as of the indicated dates, such measurements are not intended to and do not provide a precise forecast of the effect of changes in market interest rates on our EVE and will differ from actual results.

In addition to our core business activities, which seek to originate Smart Rate (adjustable) loans, home equity lines of credit (adjustable) and 10-year fixed-rate loans funded by borrowings from the FHLB and intermediate term CDs (including brokered CDs), and which are intended to have a favorable impact on our IRR profile, the impact of several other items and events resulted in the 279 and 231 basis point deterioration in the Pre-Shock EVE Ratio (base valuation) measures at September 30, 2023, when compared to the measures at September 30, 2022 for the Company and Association, respectively.

Factors contributing to these deteriorations included increases in market interest rates, capital actions by the Association, and changes due to business activity.

While our core business activities, as described at the beginning of this paragraph, are generally intended to have a positive impact on our IRR profile, the actual impact is determined by a number of factors, including the pace of mortgage asset additions to our balance sheet (including consideration of outstanding commitments to originate those assets), in comparison to the pace of the addition of duration extending funding sources.

The IRR simulation results presented above were in line with management's expectations and were within the risk limits established by our Board of Directors.

Our simulation model possesses random patterning capabilities and accommodates extensive regression analytics applicable to the prepayment and decay profiles of our borrower and depositor portfolios.

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In addition to EVE calculations, we use our simulation model to analyze the sensitivity of our net interest income to changes in interest rates (the institution’s EaR).

Net interest income is the difference between the interest income that we earn on our interest-earning assets, such as loans and securities, and the interest that we pay on our interest-bearing liabilities, such as deposits and borrowings.

In our model, we estimate what our net interest income would be for prospective 12 and 24 month periods using customized (based on our portfolio characteristics) assumptions with respect to loan prepayment rates, default rates and deposit decay rates, and the implied forward yield curve as of the market date for assumptions as to projected interest rates.

Net interest income is the difference between the interest income that we earn on our interest-earning assets, such as loans and securities, and the interest that we pay on our interest-

bearing liabilities, such as deposits and borrowings.

We then calculate what the estimated net interest income would be for the same period under numerous interest rate scenarios.

The simulation process is subject to continual enhancement, modification, refinement and adaptation in order that it might most accurately reflect our current circumstances, factors and expectations.

As of September 30, 2022, we estimated that our EaR for the 12 months ending September 30, 2023 would decrease by 0.29% in the event that market interest rates used in the simulation were adjusted in equal monthly amounts (termed a "ramped" format) during the 12 month measurement period to an aggregate increase in 200 basis points.

The Association uses the "ramped" assumption in preparing the EaR simulation estimates for use in its public disclosures.

In addition to conforming to predominate industry practice, the Association also believes that the ramped assumption provides a more probable/plausible scenario for net interest income simulations than instantaneous shocks which provide a theoretical analysis but a much less credible economic scenario.

The Association continues to calculate instantaneous scenarios, and as of September 30, 2022, we estimated that our EaR for the 12 months ending September 30, 2023, would decrease by 15.06% in the event of an instantaneous 200 basis point increase in market interest rates.

Certain shortcomings are also inherent in the methodologies used in determining interest rate risk through changes in EaR.

Modeling changes in EaR require making certain assumptions that may or may not reflect the manner in which actual yields and costs respond to changes in market interest rates.

The simulation process is subject to continual enhancement, modification, refinement and adaptation.

As of September 30, 2023, the estimated EaR for the 12 months ending September 30, 2024 would decrease by 1.75% for the Company and 2.71% for the Association in the event that market interest rates used in the simulation were adjusted in incremental amounts (termed a "ramped" format) during the 12 month measurement period to an aggregate increase in 200 basis points.

The Company and Association use the "ramped" assumption in preparing the EaR simulation estimates for use in its public disclosures.

The Company and Association continue to calculate instantaneous scenarios, and as of September 30, 2023, the estimated EaR for the 12 months ending September 30, 2024, would decrease by 5.16% and 6.91%, respectively, in the event of an instantaneous 200 basis point increase in market interest rates.

The manner in which actual yields, costs and consumer behavior respond to changes in market interest rates may vary from the inherent methodologies used to measure interest rate risk through EaR.

In this regard, the interest rate risk information presented above assumes that a particular change in interest rates is reflected uniformly across the yield curve regardless of the duration or repricing of specific assets and liabilities.

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The EVE and EaR analyses are similar in that they both start with the same month end balance sheet amounts, weighted average coupon and maturity.

The underlying prepayment, decay and default assumptions are also the same and they both start with the same month end "markets" (Treasury and LIBOR yield curves, etc.).

The underlying prepayment, decay and default assumptions are also the same and they both start with the same month end "markets" (Treasury and FHLB yield curves, etc.).

From that similar starting point, the models follow divergent paths.

EVE is a stochastic model using 150 different interest rate paths to compute market value at the account level for each of the categories on the balance sheet whereas EaR uses the implied forward curve to compute interest income/expense at the account level for each of the categories on the balance sheet.

EVE is considered as a point in time calculation with a "liquidation" view of the Association where all the cash flows (including interest, principal and prepayments) are modeled and discounted using discount factors derived from the current market yield curves.

It provides a long term view and helps to define changes in equity and duration as a result of changes in

interest rates.

EVE is considered as a point in time calculation with a "liquidation" view of the Company and Association where all the cash flows (including interest, principal and prepayments) are modeled and discounted using discount factors derived from the current market yield curves.

It provides a long term view and helps to define changes in equity and duration as a result of changes in interest rates.

On the other hand, EaR is based on balance sheet projections going one year and two years forward and assumes new business volume and pricing to calculate net interest income under different interest rate environments.

EaR is calculated to determine the sensitivity of net interest income under different interest rate scenarios.

With each of these models, specific policy limits have been established that are compared with the actual month end results.

With each of these models, specific policy limits have been established for the Association that are compared with the actual month end results.

These limits have been approved by the Association's Board of Directors and are used as benchmarks to evaluate and moderate interest rate risk.

In the event that there is a breach of policy limits that extends beyond two consecutive quarter end measurement periods, management is responsible for taking such action, similar to those described under the preceding heading of General , as may be necessary in order to return the Association's interest rate risk profile to a position that is in compliance with the policy.

At September 30, 2022 the IRR profile as disclosed above was within our internal limits.

Financial Statements and Supplementary Data

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Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 7A. Quantitative and Qualitative Disclosures About Market Risk