FTC extends Red Flags Rule enforcement deadline…..again.

Thursday, July 30, 2009 by Keir Breitenfeld
There were always questions around the likelihood that the August 1, 2009 deadline would stick.  Well, the FTC has pushed out the Red Flag Rules compliance deadline to November 1, 2009 (from the previously extended August 1, 2009 deadline).

This extension is in response to pressures from Congress – and, likely, "lower risk" businesses questioning their being covered under the Red Flag Rule to begin with (businesses such as those related to healthcare, retailers, small businesses, etc).

Keep in mind that the FTC extension on enforcement of Red Flag Guidelines does not apply to address discrepancies on credit profiles, and that those discrepancies are expected to be worked TODAY. 

Risk management strategies are key to your success.

To view the entire press release, visit: http://www.ftc.gov/opa/2009/07/redflag.shtm

Regulation is on its way

Wednesday, July 1, 2009 by Risk-based Pricing


Much of the discussion on Capitol Hill revolves around sufficient risk-based capital and the derivation of how much tier 1 capital and/or common equity capital is appropriate. Most of our solution offerings and consulting services address various aspects of risk management, from targeting prospective customers, through loan origination and risk-based pricing, to ongoing relationship management and portfolio monitoring. We have been addressing risk management with our clients long before the recent financial and economic crises. We are both ready and able to assist new and existing clients in many ways: to effectively and efficiently address the management of credit and other risks and to develop strategies that offer optimal risk-based profit performance. We are always monitoring regulatory developments and, as always, will strive to assist our clients with new best practices to operate as effectively as possible under any new regulations affecting risk management policies, processes and governance responsibilities.

 

Benchmarking – A Foundation for Success

Tuesday, June 30, 2009 by Decision Sciences

-- By Kelly Kent

In recent months, the topics of stress-testing and loss forecasting have been at the forefront of the international media and, more importantly, at the forefront of the minds of American banking executives. The increased involvement of the federal government in managing the balance sheets of the country’s largest banks has mixed implications for financial institutions in this country.

On one hand, some banks have been in the practice of building macroeconomic scenarios for years and have tried and tested methods for risk management and loss forecasting. On the other hand, in financial institutions where these practices were conducted in a less methodical manner, if at all, the scrutiny placed on capital adequacy forecasting has left many looking to quickly implement standards that will address regulatory concerns when their number is called.

For those clients to whom this process is new, or for those who do not possess a methodology that would withstand the examination of federal inspectors, the question seems to be – where do we begin?

I think that before you can understand where you’re going, you must first understand where you are and where you have been. In this case, it means having a detailed understanding of key industry and peer benchmarks and your relative position to those benchmarks. 

Even simple benchmarking exercises provide answers to some very important questions.

• What is my risk profile versus that of the industry?
• How does the composition of my portfolio differ from that of my peers?
• How do my delinquencies compare to those of my peers? How has this position been changing?

By having a thorough understanding of one’s position in these challenging circumstances, it allows for a more educated foundation upon which to build assessments of the future.
 


Targeted efforts

Friday, May 29, 2009 by Prince Varma
When looking at your client retention and cross-sell strategies, you should be asking the following questions:
  • Which clients are likely to need additional products or services?
  • Has your top 15 percent changed?
    • If so, who has dropped out and who should be added?
  • Which of your clients have a high potential of leaving your financial institution?
  • When do you shift from client retention to credit risk management? 

Back to the portfolio management basics

Friday, May 29, 2009 by Risk Management
So, what is portfolio management? 

Portfolio risk management is the active and effective oversight of the current client base with the intent of:
  • Maximizing client retention
  • Maximizing cross-sell opportunities
  • Minimizing loss potential due to credit-risk issues
  • Minimizing loss potential due to operational risks
  • Maximizing profitability through the timely identification o f risk and the appropriate allocation of capital

What risk-based pricing topics would you like to hear more about?

Friday, May 22, 2009 by Risk-based Pricing
Are there any risk-based pricing topics or risk management methodologies that you would like to learn more about?

Strategies for improving profitability

Friday, May 22, 2009 by Risk Management

Below are a few risk management strategies that your financial institution can implement through the utilization of automated portfolio monitoring:

Special accounts strategies
Focus your internal resources on accounts with a high probability of recovery. Minimize "distractions" of resources and determine the probability of rehabilitation. By utilizing these strategies, your financial institution may be able to handle more accounts with same staff levels and have quicker and more accurate responses.

Focus your internal resources
Focus your risk management resources on the accounts that are showing signs of deterioration, those that have fallen below minimum thresholds and show a significant decline from prior year performance. By doing this you can avoid credit review by identifying continuing high performers and negligible declines in credit quality.
 

Revisiting the Top Ten Origination Hot Topics of 2009

Friday, April 24, 2009 by Risk Management

 

1.       Portfolio Management – You should really focus on this topic in 2009.  With many institutions already streamlining the origination process, portfolio management is the logical next step.  While the foundation is based in credit quality, portfolio management is not just for the credit side. 

2.       Review of Data (aka “Getting Behind the Numbers”) – We are not talking about scorecard validation; that’s another subject.  This is more general.  Traditional commercial lending rarely maintains a sophisticated database on its clients.  Even when it does, traditional commercial lending rarely analyzes the data. 

3.       Lowering Costs of Origination – Always a shoe-in for a goal in any year!  But how does an institution make meaningful and marked improvements in reducing its costs of origination? 

4.       Scorecard Validation – Getting more specific with the review of data.  Discuss the basic components of the validation process and what your institution can do to best prepare itself for analyzing the results of a validation.  Whether it be an interim validation or a full-sized one, put together the right steps to ensure your institution derives the maximum benefit from its scorecard.

5.       Turnaround Times (Response to Client) –Rebuild it.  Make the origination process better, stronger and faster.  No; we aren’t talking about bionics here -- nor how you can manipulate the metrics to report a faster turnaround time.  We are talking about what you can do from a loan applicant perspective to improve turnaround time.

6.       Training – Where are all the training programs?  Send in all the training programs!  Worry, because they are not here.  (Replace training programs with clowns and we might have an oldies song.)  Can’t find the right people with the right talent in the marketplace? 

7.       Application Volume/Marketing/Relationship Management – You can design and execute the most efficient origination and portfolio management processes.   But, without addressing client and application volume, what good are they?

8.       Pricing/Yield on Portfolio – “We compete on service, not price.” We’ve heard this over and over again.  In reality, the sales side always resorts to price as the final differentiator.  Utilizing standardization and consistency can streamline your process and drive improved yields on your portfolio.

9.       Management Metrics – How do I know that I am going in the right direction?  Strategize, implement, execute, measure and repeat.  Learn how to set your targets to provide meaningful bottom line results.

10.    Operational Risk Management – Different from credit risk, operational risk and its management, operational risk management deals with what an institution should do to make sure it is not open to operational risk in the portfolio. Items totally in the control of the institution, if not executed properly, can cause significant loss.


What do you think? As the end of April approaches, are these still hot topics in your financial institution?

A revisit to the business risk of TARP

Tuesday, April 7, 2009 by Risk-based Pricing

Beyond the financial risk management considerations related to a bank’s capital, which would be directly impacted by Troubled Asset Relief Program (TARP) participation, it should be clear that TARP also involves business (or strategic) risk. We have spoken in the past of several major categories of risk: credit risk, market risk, operational risk and business risk. Business risk includes a variety of risks associated with the outcomes from strategic decision making, corporate governance considerations, executive behavior (for better or worse), management succession events (Apple and Steve Jobs, for instance) or other leadership occurrences that may affect the performance and financial viability of the business.

Aside from the monetary impact on the bank’s capital position, TARP involves a new capital securities owner being in the mix. And, with a roughly 20 percent infusion of added tier one capital, we are almost always talking about a very large, new owner relative to existing shareholders. The United States Department of the Treasury is the investor or holder of the newly issued preferred stock and warrants. The Treasury Department says it does not seek voting rights, but none-the-less has gotten them in at least some cases. The real “kicker” is embedded in the Treasury’s Securities Purchase Agreement – Standard Form. 

The most interesting clause, that appears to represent a very open-ended business risk to management decision making, is one relatively small paragraph, named Amendment, in the middle of Article V - Miscellaneous, just ahead of governing law (which is federal law, backed up by the laws of the State of New York).

Amendment begins normally enough, requiring the usual signed agreement of each party, but then states: “provided that the Investor may unilaterally amend any provision of this Agreement to the extent required to comply with any changes after the Signing Date in applicable federal statutes.” Wow. My reading of this is that if in the future Congress enacts anything that Treasury finds applicable to any aspect of the previously signed TARP Agreement, the bank is bound to go along. Regardless of whether the Treasury negotiates any voting rights, once the TARP Agreement is executed by the bank, management is not only bound by what is in the document to begin with, it is subject to future federal law as long as the TARP shares are held by the government. As a result, many banks have said no thank you to TARP.

At least four banks have recently paid back $340 million to repurchase the government’s shares. And, apparently another bank has offered to pay back $1 billion but, according to Andrew Napolitano at Fox Business Channel, the offer was turned down and the bank was threatened with adverse consequences if it persisted in its attempt to get out.

More pointed and public, and much larger in size, is the dance taking place now between Chrysler Corporation, Fiat, the UAW, four lead lenders and, you guessed it, the federal government. The secured loans in question total almost $7 billion and the government wants J.P. Morgan Chase, Goldman Sachs, Citicorp and Morgan Stanley to exchange $5 billion of the loans for Chrysler stock. The banks know they would do better (for their shareholders) by selling off Chryslers assets. This is an example of why bankruptcy exists. The stakes are large and so is the business risk of the influence from the government. It will be interesting to see how things turn out.

So, this new major owner does have a voice. If Congress wants certain lending volumes or terms, or they want certain compensation levels, it needs to be enacted into federal law. Short of having to pass a law, there is the implied threat of the big stick in the TARP agreement. The Purchase Agreement covers what the new owner wants now and may decide it wants in the future. This a form of strategic business risk that comes with accepting the capital infusion from this particular source.

 

Change management - Always a necessity

Friday, April 3, 2009 by Risk Management

This post continues the feature from my colleague and guest blogger, Mark Sofietti, Associate Process Architect in Advisory Services at Baker Hill, a part of Experian.

In today’s market, the banking industry seems to be changing at a very rapid pace.  The current crisis that we are in, as an industry and as a nation, is forcing institutions to revisit risk management policies and procedures to make the appropriate changes needed to remain healthy and profitable.  However, the current crisis is not the only reason why institutions should focus on change management.  Change management needs to be appropriately handled in bad and good times.  Understanding change management is always a necessity to a well-run organization.  Whether it is a reorganization, a new software system, a new policy or moving to a new building, change can cause a great deal of stress and uncertainty -- but it can also cause benefits.

So, as managers, you may be asking, “What can I do to ensure that positive changes are happening within my organization?  What are some of the items that I should consider when I am bringing about organizational change?” 

There are four necessary steps that need to be taken in order to improve the success of an initiative that is causing change to an institution. I covered two in my last post. Here are the additional steps.

3. Consider methods of change
One method of change is the education of individuals about new ways of operating.  This method should be used when there is more resistance to change and when individuals lack a clear understanding or knowledge of the change being made.  Education may cause the implementation to take longer, but those involved will better understand the effects of the change.

A second method is gathering participation from different levels and skill sets within the organizations.  Building a team should be used when there is the highest risk of failure due to change resistance and when more information needs to be gathered before an effective implementation can be completed.

Negotiation is a method that is used when a group or person is going to be negatively affected by the change.  This method could alleviate the discomfort by giving the person or group some other benefit.  Negotiations could allow an organization to avoid resistance, but it may be very costly and time consuming to implement the change.

The coercion change method is when a change is implemented with little room for diversion from the plan.  Employees are told what the change is going to be and they have to accept it.  This method should be used when speed is of the utmost importance, or if the change is not going to be easily accepted.  Most employees do not like this approach and it may cause resentment or it might cause staff members to leave.

The final method of change uses manipulation, the conscious decision to share limited information about the change that is taking place.  This method should only be used when no other tactic will work, or if time or cost is major issues.  This approach is dangerous because it can lead to more problems in the future.

4. Create plan of action
A plan should be created for the implementation of change to clearly address reservations and define the change strategy.  It should include internal and external audiences who can be affected by the change.  It is common to forget those who are indirectly impacted by the change -- and these audiences (customers, for example) may be the most important.  Objectives of the change need to be clearly outlined in the plan in order to understand how the new future state of the organization will look and operate.  The plan needs to be communicated to all those involved so that the transition can be understood and everyone can be held accountable.  The plan should be periodically revisited after implementation in order to review progress.  Creating a plan of action is a very important step to ensure that those who resisted the change do not revert back to their old habits. 

Achieving change is not an easy process, especially when time is not on your side.  If you take a second look at the change that you are trying to implement and do the necessary planning, you have a greater chance for success than if you or your organization fails to fully evaluate the consequences. 

Effective change management should be part of any financial risk management process. Take charge of your institution’s future through a calculated approach to change management and your organization will be in a better position for the next change that is coming around the bend.
 

Change management - Always a necessity

Friday, April 3, 2009 by Risk Management

This post is a feature from my colleague and guest blogger, Mark Sofietti, Associate Process Architect in Advisory Services at Baker Hill, a part of Experian.

Change is inevitable.  If you are not changing, then you are standing still and the world around you is changing.  In today’s market, the banking industry seems to be changing at a very rapid pace.  The current crisis that we are in, as an industry and as a nation, is forcing institutions to revisit their risk management policies and procedures to make the appropriate changes needed to remain healthy and profitable.  However, the current crisis is not the only reason why institutions should focus on change management.  Change management needs to be appropriately handled in bad and good times.  Understanding change management is always a necessity to a well-run organization.  Whether it is a reorganization, a new collections software system, a new policy or moving to a new building, change can cause a great deal of stress and uncertainty -- but it can also cause benefits.

So, as managers, you may be asking, “What can I do to ensure that positive changes are happening within my organization?  What are some of the items that I should consider when I am bringing about organizational change?” 

There are four necessary steps that need to be taken in order to improve the success of an initiative that is causing change to an institution.

1.  Understand current situation and needs
The first item necessary to have a successful implementation of change is to understand the current climate and reason for the change.  People are scared of change and many believe that “if it is not broken, don’t fix it.”  This is why the reasons for change need to be understood and communicated to all employees.  Changing, just for the sake of changing, causes a great deal of unrest to a department or organization.  With clearly defined reasons and objectives, the implementation of change can have a lower degree of failure.

2.  Identify resistance
During change, there will be some form of resistance.  As a manager, you will need to have thought through from where resistance might come and consider how to work through confrontations. 

One type of major resistance can be people who are looking out for their own self-interests.  People have their own agendas within the workplace and could view change as a threat to their advancement.  When dealing with these situations, you will need to have a good deal of collaboration and involvement from these individuals in order to successfully implement change.  Note, given this resistance, that the change will not happen as quickly and your timelines should be appropriately set. 

Another major resistance that may slow down the implementation of change is the lack of trust in the leaders enacting the change.  In these situations, management should build teams of trusted and respected people whose objective is to eliminate underlying resistance. 

Finally, providing facts and examples regarding the change is a necessity for a successful implementation.  Doing so can reassure employees that the change being made is beneficial to the organization.

The next post will continue with the additional two necessary steps that need to be taken in order to improve the success of an initiative that is causing change to an institution.

 

In this economic environment ...

Wednesday, March 25, 2009 by Prince Varma

Good day all. My last blog revolved around practical approaches to effective client relationship management. It time to get back to a “risk” type conversation.

I recently told my wife that if I hear the phrase “…in this economic environment …” uttered as a caveat one more time, I’m going to scream. I have truly come to anticipate the beginning or introduction to interviews and articles to lead in with this sentiment and it’s driving me nuts.

In these economic times (you can tell I’m from the sales side, I cleverly changed the phrase), it is clearly not business as usual within most financial institutions. Conversations with CEOs and bank presidents over the past two months have usually followed the same theme, “I’ve got money to lend, but I just can’t find a decent deal” or “I’ve got applications up the wazoo, but the quality just isn’t there.”

So, what is going on?
The obvious answer is that we are looking at applications more closely and the credit side (risk management guys) is deliriously happy because everytime they make a recommendation about “reviewing the opportunity further” they also don’t hesitate to mention, “in this economic environment.”

Really, what is the scoop and how do we adjust on the front line?
Clearly, we know that deeper reviews and management of risk is being undertaken. The problem is that the established standards are no longer valid. Yes, the basics ratios still need to be run, but let’s face it, in this economic environment a company’s historical performance is no longer an effective indicator as to their future performance. The playing field is no longer consistent. The past two to three years of financials are based on circumstances that no longer apply. This means that the analysts are having a difficult time establishing effective benchmarks from which to apply credit policy – and we know that those guys are the paragons of adaptability.

We are being asked to evaluate risk in an uncertain circumstance. We are looking at projected revenues and earnings and examining receivables. We are also comparing this business to others in the industry, determining which other market segments have a direct (and indirect) impact on the performance of this one, reviewing business plans and evaluating management depth and experience. And, at the end of the day, either saying no, saying yes but not so much or holding our breath and hoping that divine intervention shows us the way.

Does any of this should sound familiar to you?
It should. We see these type of deals all of the time and we call them the start-ups.

Ok, so what am I recommending? Quite simply, that we take a step back from our typical approach to the established business and engage with them the way we would a start-up.

When an opportunity or request presents itself, restrain the urge to go down the garden path. Slow down! No... stop! Take a deep breath, put on your “economic development hat ” and approach the deal the way you would if it were a start-up (and I don’t mean running away at top speed in the opposite direction screaming). You should: 

  • look for or help them construct a short term (next four to six month) tactical action/priority plan;
  • help them or review their 12-month business plan;
    o NOTE: If the business hasn’t realized that they need a short-term survival plan and a mid-term business plan… run! Run far and run fast!
  • examine their market and have them explain why they will make it versus the competition;
  • dig into their management expertise (think AIG);
  • have them explain how their tactical and 12-month business plan will keep the doors open and the lights on (since its coming into summer we’ll cut them some slack on the heat); and finally
  • review and revise their projections.

If at the end of this, you still feel that the deal has legs, it probably does, and you’ve done a pretty thorough job building the business case for the credit side.

Or, you could just lament that there really isn’t much out there in this economic environment.
 

Client penetration for your relationship management process

Wednesday, March 25, 2009 by Prince Varma

Part 2

Two additional tactics that you should incorporate into your relationship management penetration strategy include:

  • Conducting relationship reviews in addition to loan reviews; and
  • Identifying and proactively monitoring changes in client behavior.

Relationship reviews
Relationship reviews are a comprehensive and thorough examination of the client’s business and should be the foundation for your relationship management process. They seek to provide both the client and the relationship manager with a roadmap for the upcoming 14- to 16-month period by identifying specific goals and concerns, as well as constructing a snapshot of the client today. The purpose of a relationship review is to understand the broader direction.  Bluntly put, an annual loan review is not a penetration activity. Its primary focus is to verify the ongoing credit worthiness of an existing deal in the books. More details will come about this topic in a future blog.

Monitoring changes in behavior
Monitoring changes in client behavior through the use of “activity thresholding” is quickly becoming a mainstay in the financial industry. The idea isn’t new; however, the application of the concept to penetration is. Instead of having changes in credit score trigger an alert related to risk management and mitigation, we would instead look at thresholds related to line usage, number of deposit transactions, changes in average deposit amount and credit card transactions.

These kinds of client behaviors and activities provide insight into what is occurring within a clients business and as such, allow us to provide recommendations for products and services that are meaningful and appropriate.
 
 

Consumer lending - year in review

Friday, March 20, 2009 by Risk Management

This post is a feature from my colleague and guest blogger, Barry Timm, Senior Process Architect in Advisory Services at Baker Hill, a part of Experian.

2008 has proven to be an unbelievably challenging year for the economy as a whole, let alone the financial industry.  Never before have we experienced the type and degree of turmoil that we did in 2008, even since the “Great Depression”.
 

These economic challenges have been quick, severe and widespread; and, from large corporations to the individual consumer, all have been impacted to some degree.  The stock market is down, unemployment up, consumer confidence down, delinquencies up ….not exactly a pleasant roller coaster ride. 
 

And, there is no longer any projecting as to when the “bubble” is going to burst.  It happened.   Decreased real estate values have occurred not only in high impact geographic regions but throughout the country.  While home equity products have traditionally been the “golden child” of consumer loan product offerings, recent economic changes have caused a shift in that perspective.  As a result, tightened underwriting standards have limited the availability of the product as a whole.  In some markets the product offering has even been temporarily halted.
 

We frequently hear the terminology “bailout” being used in the news.  While we all have expectations as it relates to the bailout approach, I thought I would “Google” the word “bailout” to see what would magically appear.  Interestingly enough, the first listing was titled “Walk away from your home”, with a link to the home page for a mortgage default legal team.  This is not exactly what I was expecting to find, but is definitely reflective of the times.
 

And, according to the FDIC, there have been 25 failed financial instituions in the year 2008.  This single year number equates to the total number of failed financial institutions between the prior periods 2001 through 2007. 


Okay … enough doom and gloom.  In spite of all that has occurred within the economy, some financial institutions continue to maintain a strong credit quality position in their consumer portfolios and have maintained profitability throughout all of the market volatility.  

What are the strong survivors doing that differentiates themselves from the others?


1. They understand their portfolio.  

Advisory Services frequently assists clients with various types of portfolio management analysis and often presents those findings to senior management.  We often hear that management is surprised by the results of that analysis. The point is that high-level management reporting is not enough these days. Additional detail and depth are necessary. 


More specifically, as opposed to evaluating payment performance at the portfolio level, it is important to consider the following:

  • Do you know your delinquency numbers at the product level? 
  • How do delinquencies compare to your product approval rates? 
  • Do you routinely compare approval/decline rates and delinquencies to scorecard results and/or credit bureau scores?  
  • Do you know where pricing exceptions are being made and are you receiving sufficient return for the level of risk?

2. A focused strategy is in place.
It is important to re-emphasize the specific, strategic direction and focus of your defined market.  Now is not the time to be “pushing the envelope” and extending into untested waters.  There is something to be said about focusing on your strengths, staying within your defined footprint and meeting the needs of your core, proven line of business while following sound financial risk management.


3. The underwriting process is under control.
This does not automatically mean that a “tightening” of underwriting standards is necessary.  It does mean, however, that stronger attention to detail is warranted.  It is important that underwriting criteria is reviewed and that you are sure that defined underwriting practices are consistently applied.  As noted in item number one above, this may require digging a little deeper and reviewing current and past decisioned loans (preferably with a critical eye of an independent third party).  Assessing the underwriting process becomes increasing complex and more critical with a decentralized underwriting approach.


Focus on the positive
Now that 2008 is behind us, let’s continue to focus on the positives to come in 2009.  Reflect on the past, but strive to center your attention on ongoing portfolio monitoring, financial risk management assessments and improvements for the future. 

 

Client penetration for your relationship management process

Friday, March 20, 2009 by Prince Varma

Part 1

Ok, it’s me again, your business development guy in financial risk management clothing. In my first blog, I promised that I would start providing specific tactics related to optimizing penetration and retention efforts.
 
So, in “non-consultant” speak, we’re trying to figure out:

  • how we are going to get deeper with existing clients;
  • keep the (good) business we have; and 
  • find new opportunities.

Today, we’ll focus on client penetration strategies. Some of this should be pretty self-explanatory.  If it is, that’s good. If it isn’t, you have a lot of work to do.

First, let’s recognize that not clients are going to be suitable candidates for increasing the existing relationship. Secondly, we can’t focus strictly on those “A” clients in our portfolio (assuming that you’ve implemented even the most rudimentary sales segmentation strategy, which is categorization into three to four tiers based on total relationship). There simply aren’t that many and if you’ve done your job effectively, there shouldn’t be many more “A” clients to add.

Getting deeper requires a defined approach. It doesn’t just happen. Clients will not call you on a regular or on-going basis and tell you that they need more services (well not usually). Rather, the responsibility rests on our shoulders to uncover changes in their operations and to look for signs that indicate growth, changes in direction and/or priority or changes in their day-to-day activities.

Sounds simple right? So, how should you do this?

One approach might be to engage in a “client call/touch routine” that will have you contacting the upper 65 percent of your portfolio on a pre-defined schedule or frequency. The rationale being that continued and consistent interaction with the client base will result in both uncovering possible “new” needs as well ensuring that in the event there is a competitive effort underway, we will have the opportunity to provide our recommendation.  

My next blog will feature two additional tactics to include in your relationship management process.
 

Financial institution profits, credit risk and loan pricing for 2008

Tuesday, March 17, 2009 by Risk-based Pricing

Part 6

Peer Group 2 fee income

Non-interest income again, as a percent of average total assets, declined to .86 percent from .95 percent in 2007. For Peer Group 2 (PG2), fees have also been steadily declining relative to asset size, down from 1.04 percent of assets in 2005. A smaller, non-interest bearing deposit base with no other new and offsetting sources of fee income will lead to increased pressure on this metric.

Operating expenses
Operating expenses also put more pressure on earnings on these smaller banks. They increased from 2.79 percent to 2.83 percent of average assets. That’s four basis points on the negative. Historically, this metric has been flattering for this size bank and usually moves up or down from year-to-year. It was almost equal at 2.82 percent of assets in 2004.

As a result of the sizeable decline in margins, the continued decline in fee income and the slight increase in operating expenses PG2’s efficiency ratio lost ground from 59.52 percent in 2007 to only 64.72 percent in 2008. That means that every dollar in gross revenue cost them almost 65 cents in administrative expenses this year. This metric averaged 56 cents in 2005/2006. It’s amazing how close these numbers are for banks of very different size where you would expect clear economies of scale.

The total impact of margin performance, fee income and operating expenses, plus the huge increase in provision expense of 59 basis points leads us to a total decline in pre-tax operating income of .96 percent on total assets. That is a total decline from 1.58 percent pre-tax ROA in 2007 to .64 percent pre-tax ROA, a loss of 61 percent from the pre-tax performance in 2007. My same conclusion as above would hold regarding the pricing of risk into bank lending (although the smaller banks didn’t perform a badly as the larger in this regard).

Although all 490 banks are declining in all profit metrics, the smaller banks seem to have an edge in pricing loans, but not deposits. Although up dramatically in 2007, and even more in 2008 for both groups, the PG2 banks seem to be suffering fewer credit losses relative to their asset size than their larger brethren. Both groups have resulting huge profit declines, but the largest banks are under the most pressure through this period.

An interesting point, with higher loan yields and fewer apparent losses, is whether PG2 banks are somewhat better at risk-based pricing (for whatever reason) than the largest bank group. Results are results. The 2009 numbers aren’t expected to show a lot of improvement as the general economy continues to slow and credit and financial risk management issues continue. We’ll probably comment on 2009 as the quarterlies become available this year.

 

Defining risk management

Thursday, March 12, 2009 by Prince Varma

Hello. My name is Prince Varma and I’ve spent the better part of the last 16 years helping financial institutions (FI) successfully improve their in business development, portfolio growth and client relationship management practices.

So, since the focus of this blog is to speak to readers about risk management, many of you are probably wondering what a “sales and business development” guy is doing writing a piece related to mitigating and managing risk?

Great question!

The simple fact is that the traditional or prevailing sentiment or definition related to risk management – mitigating credit risk -- is incomplete. A more accurate and comprehensive approach would be to recognize, acknowledge and address that “risk” cuts across the entire client relationship spectrum of:

  • client penetration/growth;
  • client retention; and
  • client credit risk mitigation.

How do penetration and retention count as “risk factors”?
(this is where the sales guy stuff comes in)

From a penetration perspective, the failure to recognize potential opportunities either within the existing client base or in the operating market, introduces revenue growth risk (meaning we aren’t keeping our eye on the top line). Ultimately it impacts the FI’s ability to add assets (either deposits or loans) and also has a direct affect on efficiency and deposit to loan ratios.

From a retention perspective, the risk is even more obvious. Our most valued clients are the ones that we must continuously engage in a proactive manner. Let’s face it. In even the smallest markets, there are no less than four to six other institutions waiting to jump on your client in the event that you grow complacent. There is a huge difference between selection and satisfaction. And, if we aren’t focused on keeping a client after securing them, our net portfolio growth targets will be impossible to achieve. 

Considering the current market environment, now more than ever, effectively managing these three elements of “risk/exposure to the FI” is crucial to an institutions success both practically and pragmatically. Everyone internally at the bank is focused on the “credit risk mitigation” piece. The conversations that are occurring outside of the bank’s walls however are focused on the “L” word or liquidity and getting credit flowing again.

How many times have we read or more frankly been beaten with this comment from business owners “…there’s no one making loans anymore…” or “…its impossible to get credit…?”

That should be read as … penetration and retention

Striking a balance between effective and appropriate credit risk exposure and deepening or growing the portfolio has been a challenge facing those of us in the front office for as long as I can remember. The “sales revolution” is effectively over. We’ve learned the critical lesson that we need to evolve beyond being strictly a credit officer (you did learn that right??!!). And, you didn’t/shouldn’t become a “banking products generalist” with no analytical depth. Knowing all this, it is important that we return to the guiding principles of effective lending which include:
- evaluating the scope of the opportunity;
- isolating the risk and identifying a reasonable and realistic recovery/mitigation remedy;
- determining what other alternatives the borrower might be considering; and
- being willing to let the “bad deals” walk.

In subsequent blogs, I’ll provide you with specific tactics aimed at optimizing penetration and retention efforts and implementing effective and practical client management strategies.

After all what would you expect from a business development guy…
 

Start with vision. Finish with strategy.

Wednesday, March 11, 2009 by Risk Management
When you begin thinking about financial risk management, you must begin with a vision for your loan portfolio and the similarity of a loan portfolio to that of an investment portfolio.  Now that you have that vision in place, we can focus on the overall strategy to achieve that vision. 

A valuable first step in loan portfolio monitoring is to establish a targeted value by a certain time (say, our targeted retirement age).  Similarly, it’s important that we establish our vision for the loan portfolio regarding overall diversification, return and the management of risk levels.

The next step is to create a strategy to achieve the targeted state.  By focusing on the gaps between our current state and the vision state we have created, we can develop an action plan for achieving the future/vision state.  I am going to introduce some rather unique ideas here. 

Consider which of your portfolio segments are overweight?  One that comes to mind would be the commercial real estate portfolio.  The binge that has taken place over the past five plus years has resulted in an unhealthy concentration of loans in the commercial real estate segment.  In this one area alone, we will face the greatest challenge of right-sizing our portfolio mix and achieving the appropriate risk model per our vision. 

We have to assess our overall credit risk in the portfolios next.  For small business and consumer portfolios, this is relatively easy using the various credit scores that are available to assess the current risk.  For the larger commercial and industrial portfolios and the commercial real estate portfolios, we must employ some more manual processes to assess risk.  Unfortunately, we have to perform appropriate risk assessments (current up-to-date risk assessments) in order to move on to the next stage of this overall process (which is to execute on the strategy).

Once we have the dollar amounts of either growth or divestiture in various portfolio segments, we can employ the risk assessment to determine the appropriate execution of either growth or divestiture.

Portfolio management - a love/hate relationship

Thursday, March 5, 2009 by Risk Management

What is porfolio risk management? It is the active and effective oversight of the current client base with the intent of:

  • Maximizing client retention –LOVE
    • Everyone wants to retain clients and deepen relationships!
  • Maximize cross-sell opportunities –LOVE
    • Again, everyone wants to retain clients and deepen relationships!
  • Minimize loss potential due to credit risk issues –HATE
    • No one wants credit issues to develop!
  • Minimize loss potential due to operational risks –HATE
  • Maximize profitability through timely identification of risk and appropriate allocation of capital –LOVE / HATE
So, here are a few questions for you to focus your targeted portfolio management efforts.

  • Which clients are likely to need additional products and services?
  • Which clients have a high potential of leaving your financial institution?
  • When do you shift from client retention to credit risk management?

     

Moderation. Moderation. Moderation.

Thursday, March 5, 2009 by Risk Management
Just as with diet recommendations, moderation needs to be the new motto for credit risk management.  Diets provide for the occasional bag of chips or dessert after dinner, but these same food items become problems if the small quantity or occasional indulgence suddenly becomes the norm. 
Similarly, we, in our risk management efforts, put forth guidelines that establish limitations on certain loan types or categories that have been deemed risky should the numbers or quantity become too large a part of the overall portfolio.  Unfortunately, we have a tendency to allow earnings or portfolio growth to cloud our judgment and take an attitude of “just one more.” 
In the past several years, we have experienced excesses in commercial real estate, residential development and subprime mortgages.  It is now these excesses that are creating the problems that we are dealing with today. 
Bringing back these limitations – in other words, reestablishing the discipline in our portfolio risk management – will go a long way in avoiding these same problems in the future. 
As I learned early in my banking career:  “…soundness, profitability and growth…in that order.”