Mark Midkiff
Special Advisor

Across recent industry forums — like Bank Director’s Acquire or Be Acquired Conference — and private conversations with bank executives, a more analytical tone has emerged. Optimism is present, but it is conditional. Growth is back on the agenda, yet it is being considered through the lenses of soundness, profitability and operational capacity.

Through these conversations, five themes consistently stand out: macro uncertainty, regulatory recalibration, the strategic deployment of artificial intelligence (AI), the evolution of digital asset strategy and a disciplined reopening of M&A. Taken together, they signal not a relaxation of standards but a sharper focus on what truly matters.

Macroeconomic Risk as a Strategic Input
Macroeconomic and geopolitical volatility is no longer treated as episodic shock risk; it is a structural feature of the operating environment. Tariffs, sector-specific disruptions, geopolitical fragmentation and conflict, and the uneven impact of AI across industries create layered exposures within loan portfolios and funding bases.

Leading institutions are not relying solely on static stress tests or consensus forecasts. They are building scenario frameworks that ask more strategic questions:

  • Where are we unintentionally concentrated?
  • How could AI-driven disruption alter borrower performance?
  • What second-order effects might follow trade or regulatory shifts?
  • Where are we most exposed to tail events that sit outside traditional modeling assumptions?

This reframes scenario analysis from a compliance exercise to a capital allocation discipline. It informs pricing, portfolio construction and growth strategy. In a world of persistent uncertainty, vulnerability and opportunity often sit in the same exposure.

From Process to Soundness
Supervisors also appear to be recalibrating. The emphasis is shifting away from expansive process expectations toward a clearer focus on safety, soundness and violations of law.

This is not deregulation. The line remains firm around unsafe or unsound practices — particularly in underwriting, liquidity, asset/liability management, credit risk management, Bank Secrecy Act and anti-money laundering (BSA/AML) compliance and material model risk management.

What is changing is the signal to well-managed institutions. There is encouragement to innovate and deploy transformative technologies provided risk is understood and controlled. Institutions able to demonstrate disciplined risk identification may find more flexibility to grow, pursue M&A or modernize infrastructure.

As a result, many banks are reassessing where risk and compliance dollars are deployed. Investments once spread broadly to meet heightened expectations are being redirected toward the most material exposures. Efficiency is not the objective; allocation discipline is. The goal is to reallocate capital and talent toward areas of highest risk and return while still harvesting sustainable efficiency gains from modernized processes and technology.

AI and the Operating Model
AI sits at the center of this reallocation. Its impact is not incremental; it is structural.

At a basic level, AI enhances productivity. More strategically, it improves decision quality by ingesting institutional data and generating more predictive outcomes. At scale, it supports complex processes — transaction monitoring, model validation, underwriting review — at speed and with increasing consistency.

The question is no longer whether to experiment with AI but how far to integrate it into the operating model. For some banks, that means pilots. For others, it means redesign.

This shift raises governance demands. Talent in data science and model risk management becomes critical. Control frameworks must evolve alongside capability. Boards must understand how efficiency gains are redeployed — strengthening risk management and analytics rather than simply reducing expense. When implemented thoughtfully, AI can simultaneously improve operating leverage and enhance risk-adjusted returns.

Institutions that view AI solely as a way to reduce costs risk missing its strategic value: better risk selection, improved pricing discipline and more resilient decision-making.

Digital Assets: Practical Over Novel
Digital asset strategies are also maturing. Many risk leaders view stablecoins skeptically, citing AML complexity, potential deposit disintermediation and unclear customer demand.

Tokenized deposits, by contrast, offer on-chain efficiencies while remaining within traditional banking structures. The focus is less on novelty and more on alignment — how digital capabilities fit within existing risk taxonomies, liquidity frameworks and compliance obligations.

Growth With Constraints
The M&A door is open but selectively. Well-capitalized, operationally mature institutions are positioned to pursue inorganic growth.

Integration capacity, however, is the constraint. Talent, systems compatibility and governance bandwidth must support consolidation while institutions simultaneously modernize operations, often through AI-enabled transformation.

Disciplined acquirers are weighing soundness and profitability alongside strategic rationale. Growth alone is insufficient; sustainable returns and risk durability are the standard.

What defines this moment is selectivity. Bank leaders are not retreating from growth. They are demanding clearer risk-adjusted returns, stronger scenario discipline and tighter alignment between innovation and control.

Momentum is present, but it is measured. Institutions that succeed will be those that manage and price risk prudently, improve the balance of risk and return across the portfolio, redeploy investment intentionally and integrate technology in ways that strengthen not dilute safety and soundness.

WRITTEN BY

Mark Midkiff

Special Advisor

Mark is a seasoned financial services leader with deep experience across risk management functions, including enterprise, credit, market, compliance and operational risk, as well as portfolio management and asset recovery activities.

Formerly, Mark was chief risk officer of KeyCorp, reporting directly to the CEO and was chairman of KeyBank National Association, a member of KeyCorp’s Executive Leadership Team and Executive Council. He was vice chair of Key Corporation’s Enterprise Risk Management Committee.

Mark joined Key from BB&T, where he served as deputy chief credit officer. Prior to this role, Mark served as the global chief risk officer, responsible for overseeing the risk functions in all of GE Capital’s business units.

Mark currently serves on the Texas Capital Bancshares Board and is a Board and Executive Committee member of ProSight (formerly the Risk Management Association).