Corporate

Vancity Community Investment Bank (VCIB) is a federally regulated Schedule 1 bank under the Bank Act (Canada) and is regulated by the Office of the Superintendent of Financial Institutions Canada (OSFI). VCIB offers commercial banking services and products including deposits.

VCIB is a wholly owned subsidiary of Vancity Credit Union. VCIB annual reports are consolidated with those of Vancity. Information about Vancity and its performance is available through the annual reports on the Vancity website.

Regulatory Disclosures below are in accordance with OSFI regulatory requirements and are based on the Basel Committee of Banking Supervision Pillar 3 disclosure requirements. Disclosures are based on Bank’s financial statements as at December 31, 2021.

Capital Adequacy ensures that VCIB has sufficient capital to meet minimum regulatory requirements, to support its business strategy and protect it against unexpected losses.   VCIB calculates its capital base as a percentage of the risk weighted assets and ensures minimum OSFI targets are not breached. In addition, VCIB defines Regulatory Capital risk as inadequate or insufficient capital available to meet regulatory levels required to support the strategy of the organization.  The Bank uses the annual Board of Directors approved Capital Management Policy to manage Regulatory Capital Risk.

The Asset and Liability Committee (ALCO) monitors compliance with the policy on a regular basis, and the Board of Directors reviews compliance with the policy on a quarterly basis. VCIB manages its capital under guidelines established by OSFI and follows an Internal Capital Adequacy Assessment process (ICAAP) submitted to OSFI for review annually.  Multiple stress tests are integrated into the capital planning process to determine capital requirements.  Stress testing quantifies possible events or future changes in economic conditions that could have unfavorable effects on VCIB’s exposures. As a result of stress testing, management is informed about potential risks and their impact and considers these risks in capital planning and risk management practices.

The table below provides the composition of capital disclosures under Basel III as required by OSFI as at December 31, 2021:

Leverage ratio measures the bank’s tier 1 capital relative to total assets. This ratio looks at tier 1 capital to judge how leveraged the bank is based on its assets. Tier 1 capital consists of assets that can be easily liquidated if the bank needs capital.

The following table summarizes Bank’s Basel III Pillar 3 Leverage Ratio as at December 31, 2021

VCIB defines Credit Risk as the risk of financial loss to VCIB if a customer or counterparty to a financial transaction fails to meet its contractual obligations. Credit risk arises primarily from VCIB’s loans and advances to customers. VCIB is also exposed to other credit risks arising from investments in debt securities and other exposures arising from its investment activities, including non-equity investment portfolio assets, derivatives and settlement balances with market counterparties.

VCIB’s credit philosophy is based on the view that our fundamental responsibility is to consider first and foremost the safety of the bank while being mindful that providing community impact borrowers with effective borrowing opportunities is a core business activity. VCIB manages, limits and controls concentrations of credit risk, where identified, to individual counterparties.

VCIB’s Lending Policy establishes the approach of the Bank to lending and applies to its lending activities. All of the Bank’s lending activities must be conducted according to the requirements and limits set out within the Lending Policy. The Lending Policy is reviewed annually by the Board.

Impairment of financial assets

VCIB uses an expected credit loss (ECL) model which applies to amortized cost financial assets, debt investments at fair value through other comprehensive income, off-balance sheet loan commitments, and financial guarantee contracts.

Loss allowances are measured on either of the following bases:

• 12-month ECL: these are losses that result from possible default events within the 12 months after the reporting date; and
• Lifetime ECL: these are losses that result from all possible default events over the expected life of a financial instrument.

ECL is measured as 12-month ECL unless the credit risk on a financial instrument has increased significantly since initial recognition, the instrument is credit-impaired at initial recognition, or trade and lease receivable, for which VCIB has elected to use lifetime ECL to measure the loss allowance.

The assessment of significant increase in credit risk considers information about past events and current conditions as well as reasonable and supportable forecasts of future events and economic conditions. Factors considered in the assessment include macroeconomic outlook, delinquency and monitoring.

Quantitative Credit Disclosures

A breakdown of VCIB’s loan portfolio by loan type, its credit risk weighted assets, and impaired loans are published by OSFI and are available through the following hyperlink:
Financial Data – Banks

Liquidity risk describes the risk that VCIB will encounter difficulty in meeting obligations associated with financial liabilities that are settled by delivering cash or another liquid asset as well as not being able to meet unexpected funding needs. Liquidity risk is inherent in any financial institution and could result from entity-specific circumstances and/or market events. Accordingly, VCIB has policies and procedures in place to manage its liquidity position, both to comply with regulatory requirements and adhere to sound business practices.

VCIB’s liquidity risk is subject to extensive risk management controls and is managed within the framework, policies and limits approved by the Board. On an annual basis, the Board, through the Audit Committee, reviews and approves the liquidity policy presented by management to ensure adherence to regulatory requirements. The Asset Liability Committee (“ALCO”) oversees the operational adherence to the liquidity policy. ALCO approves liquidity management processes and strategies presented by treasury and finance management in addition to overseeing adherence to minimum liquidity limits, eligibility requirements for liquid assets, investments with counterparties, funding diversification, deposit concentration and diversification limits.

Stress testing on liquidity is conducted annually as part of its risk oversight and the results would be used to inform and ensure that adequate liquidity risk limits are in place and current.

A liquidity contingency plan (LCP) exists for liquidity to satisfy funding requirements in the case of a general market disruption or adverse economic conditions. Proper execution of the LCP is the responsibility of the treasury department. The LCP outlines the appropriate steps to follow and stakeholders to notify. It is scenario tested annually, and the results are presented to the Board.

Key measures used by VCIB for managing liquidity risk are the ratio of liquid assets to total assets, as well as the Liquidity Coverage Ratio (LCR) and Net Cumulative Cash Flow (NCCF) with the latter two metrics quantifying liquidity survivorship reported to the bank regulator. For the purpose of measuring liquidity risk, liquid assets comprise the total market value of cash, Government of Canada or provincial treasury bills, debt securities with a government guarantee and a minimum DBRS Limited (“DBRS”) investment rating of A, government guaranteed mortgage-backed securities, banker’s acceptances and bearer deposit notes from Schedule I and II banks with a DBRS rating of R-1 low or higher, and corporate commercial paper with a DBRS rating of R-1 low or higher.

VCIB defines Operational Risk as the risk of loss resulting from regulatory non-compliance and impacts that are detrimental to our customers resulting from people, inadequate or failed internal processes and systems, or from external events such as external fraud or cyber-crime.

The Operational Risk Management Framework outlines operational risk management actions, tools and establishes accountabilities for managing risk consistent with the Three Lines of Defense model.

The Board of Directors receives reports and other operational risk information from management on a quarterly basis.  The Risk Management Committee is a management committee responsible for establishing an organization wide operational risk management program integrated with Enterprise Risk Management and the Risk Appetite.  Management is accountable for developing the appropriate strategies, policies, and tools to identify, assess, measure, monitor, manage and report operational risk.

Oversight and governance of the remuneration policies and compensation structure for VCIB’s senior management is provided by the Governance & Executive Compensation Committee (“GECC”) of the Board, which meets quarterly.   There are five members on the GECC.  Directors are provided an honorarium, however, directors that are executive members of the Bank or the parent company, Vancity, are not compensated.  Total remuneration paid to directors in 2021 was $112,677.

The Governance and Executive Compensation (GECC) Committee’s primary role is to ensure that the Board of Directors provides for effective governance of Vancity Community Investment Bank and that the governance practices evolve with the needs of the Bank and the expectations of the stakeholders (shareholder, members, employees, regulators).  The Committee is also responsible for ensuring the performance of the CEO and compensation of the CEO is appropriate in relation to the Bank’s needs and objectives.

VCIB is a subsidiary of Vancouver City Savings Credit Union (“Vancity”). Vancity retains an independent compensation consultant, Willis Towers Watson, to provide advice on the various elements of total rewards programs, including that of the Bank, where necessary.

The policy and competitiveness of the total reward program is reviewed annually to ensure changing market conditions are considered and that the Bank can attract and retain employees needed to deliver on its business objectives.

The Bank endeavors to ensure that the remuneration policy is consistent with the business model. The senior management team’s compensation package consists of base salary and an annual variable incentive plan aligned with organizational objectives. Performance measurements used to calculate variable remuneration are adjusted to account for current or potential risks to the company and are comprised of both individual and organizational performance objectives.  Organizational objectives build a strong connection between Business Goals and the Business Plan.  Achievement levels are stated as “Threshold”, “Target” and “Trajectory”. The Target reflects the Board approved Plan.  There is no payout if threshold is not achieved.  Individual performance objectives are weighted and rated by the manager to determine the individual performance score.

For 2021, the total amount of fixed and variable remuneration for 10 key VCIB management was:

Vancity Community Investment Bank is committed to a number of voluntary codes of conduct and public commitments to protect consumer interests.

• Code of Conduct for the Delivery of Banking Services to Seniors
• Code of Conduct for the Credit and Debit Card Industry in Canada
• Model Code of Conduct for Bank Relations with Small- and Medium-Sized Businesses
• Principles of Consumer Protection for Electronic Commerce: A Canadian Framework
• Commitment on Modification or Replacement of Existing Products or Services (2012)
• Guidelines for Transfers of Registered Plans
• Fraud protection
• Canadian Bankers Association: Online Payments
• Visa Zero Liability

The primary objective of the Senior Complaints Officer (SCO) is to focus on fairness and transparency for all clients and partners involved in the complaint escalation process related to our products and services. The SCO Office is an impartial department directed to review complaints that remain unresolved after the completion of the first two steps of VCIB’s Complaint Process. This Office will investigate complaints and act as a go-between for our clients, partners, and the various business areas within VCIB, including our Impact Banking and Visa teams. This office does not report into any of the business areas to protect our impartiality in addressing the concerns.

Once we receive all the necessary information to complete an initial review, the complainant will receive a summary of the details of our complaints resolution process and the complaint will be assigned to an investigator. Depending on the nature and complexity of the complaint, the investigation may require input from different departments. Once the complainant receives our response, they can decide to accept it or request further review from an external complaints body.
For 2022, the Senior Complaints Officer received no complaints. As a result, the average time to complete an investigation and the type of complaints data is not applicable for 2022.

Complaint URL link: https://vcibweb-staging.azurewebsites.net/contact-us/#complaint