Five Common Misperceptions About BOLI

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Bank-owned life insurance has been a popular way for banks to earn a tax-deferred or even tax-free return on their capital for many years. In fact, banks can invest up to 25% of their Tier 1 capital in BOLI.

Banks have struggled with low yields on bank-approved investments such as U.S. Treasuries since the Federal Reserve dropped rates to zero. BOLI has been welcome relief to that pressure: As of mid-October, the average highest credit quality general account BOLI yielded 2.37% and the highest yield on average was 2.69%, according to the Newcleus BOLI Index. The taxable equivalent yield, based on a 21% tax rate, is 3% to 3.41%.

Despite its popularity, there are still many misperceptions in the market about BOLI that we want to dispel. Let’s focus on general account BOLI, the most common form of BOLI.

1. “BOLI is janitor insurance. Is it even legal?”
The term “janitor insurance” refers to a time when it was common for companies to buy life insurance for their employees without their knowledge or consent. That’s not legal anymore. With the passage of the Pension Protection Act of 2006, firms need to obtain consent from the employees covered by policies where the company pays the premium. In addition, only the top 35% highest paid employees can be considered for coverage.

For example, a regional bank may send out a notice asking for consent and a signature from 200 of the highest-paid employees in the bank, and 150 of them with sign it. Those 150 employees will be covered by BOLI.

2. “I don’t want my bank to profit off the death of employees.”
Many banks, especially community banks, choose to share a portion of the life insurance benefit with the deceased employee’s estate. In essence, the bank pays the premium, not the employee, and earns tax-deferred interest on the BOLI asset along with a death benefit that it can share with the employee. This can be structured in different ways. The bank may decide to offer a life insurance benefit only to the CEO, the members of the executive team, or the 20 top highest paid employees, for example.

3. “We don’t need to add a life insurance benefit.”
The point of BOLI is not life insurance coverage (yes, we know it’s called bank-owned life insurance). It’s not a regular term-life policy, where you write a premium check every month and receive a benefit when someone dies.

BOLI is an asset class. BOLI stays on the balance sheet and is accretive from Day 1. The day after a bank wires the premium, it is paid interest on the principal. The earned interest is tax-deferred until the death of the employee. If the employee dies, the earnings are tax free. But there are regulatory restrictions on the use of BOLI. For example, the Office of the Comptroller of the Currency requires banks to use the earnings to offset the cost of bank compensation and benefit programs.

4. “BOLI is an illiquid asset.”
This is a common misperception of BOLI. Typically, on a term-life policy, there’s no asset you can sell. That’s not true for BOLI. Like other investment products, banks can sell, or surrender the policy, at any time. In a time of widespread declines in asset values, a bank might find that the value of its asset, similar to a bond portfolio, has fallen. But the insurance company will return 100% of the cash surrender value. There are no fees to sell the asset. If a bank surrenders the policy before the death of the covered employee, the bank may owe unpaid taxes on any earnings received.

5. “Now is a bad time to buy BOLI.”
Given that many predict interest rates to go up in the next few years, banks may assume it’s a bad time to buy BOLI. Why lock in capital at a low interest rate when rates are going to go up? Although BOLI is a fixed-rate asset, it reprices at market rates. Typically, a BOLI portfolio has a duration of 5 to 7 years. Each year, 20% of the portfolio will turn over. By the fifth year, 100% of it has repriced.

We hope to have dispelled some of the common misperceptions about BOLI. If you haven’t maxed out the amount of BOLI you can put on your balance sheet, it might be time to take another look.

Wait Wait, Don’t Quit

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The Covid-19 infection rate across much of the country is in decline, but banks and other employers trying to bring workers back to the office are dealing with another problem: an acute labor shortage.

Last month acquired the nickname #striketober, as the U.S. reached a record high percentage of people quitting their jobs. The latest data from the U.S. Bureau of Labor Statistics found that 4.7 million people, or 2.9% of all employees, quit their jobs in August. Nonfarm employment as of October was 4.2 million shy of what it was pre-pandemic. Wages are climbing, and banks feel the pressure from companies like Bank of America Corp., which announced that it will pay workers at least $25 an hour by 2025.

The ability to work-from-home in such an environment has suddenly become a retention tool — no longer simply a response to the pandemic. As I head to Bank Director’s Bank Compensation & Talent Conference at the Four Seasons Resort and Club in Dallas Nov. 8 to 10, where close to 200 people will discuss those and other issues, it’s clear that flexibility is becoming the new 401(k).

At $1.6 billion State Bank of Cross Plains, in a suburb of Madison, Wisconsin, allowing non-branch staff to work from home a few days per week has become an important benefit, said Chief Financial Officer Sue Loken at a recent Bank Director conference in Chicago.

In Buffalo, New York, at $152 billion M&T Bank Corp., employees will come back to the office three days a week starting in January 2022. Some already were coming into the office voluntarily or if their work required it.

Hybrid work looks like a better alternative to most banks than remote work. An unscientific audience poll at Bank Director’s recent Bank Audit and Risk Committees Conference in Chicago found that fewer than 5% of 57 respondents thought that more than half their employees would work remotely in the future. The most popular answer was that fewer than a quarter will work remotely, in line with Bank Director’s 2021 Risk Survey conducted at the beginning of the year.

That fits with what Paul Ward, chief risk officer at $15 billion Community Bank System in DeWitt, New York, had to say at the conference. Most employees are back at the office full-time, though a few still are working remotely.

Community Bank’s senior executives believe those in-person conversations are critical to building culture at the bank. Executives at M&T Bank also felt that culture is best cultivated in person, not via video conferencing. Michele Trolli, M&T’s head of corporate operations and enterprise initiatives, told The Buffalo News last October that M&T was “living off an annuity” acquired pre-pandemic by being together and knowing each other. “And that annuity, at some point, that runs out,” she said.

Unlocking Meaningful Compensation to Keep Essential Talent

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Banks are no strangers to using nonqualified deferred compensation plans to attract, retain and motivate their employees and strengthen their succession plans.

According to the American Bankers Association’s 2019 Compensation & Benefits Survey, nearly 65% of banks report utilizing deferred compensation plans. These plans can include supplemental executive retirement plans, or SERPs, which are typically designed for the seasoned bank executive talent. Unlike a 401(k) plan, a SERP has no contribution limit or rules that mandate that all employees must be able to participate. They are purposely designed for highly compensated executives and key employees for whom the 401(k) contribution limits act as a form of “reverse discrimination” toward retirement. These limits can cause a whole host of problems if not addressed by the introduction of a SERP.

Meaningful, thoughtful compensation will be essential for banks interested in motivating and retaining key executives and talent as they continue navigating through these unprecedented times. Guaranty Bancshares’s CFO Cappy Payne called the SERP a “cornerstone” of the Addison, Texas-based bank’s compensation approach.

“[W]e have a wide variety of executive compensation and benefit plans for our senior level management,” he says. “We purposely diversify their compensation such that it increases our ability to attract, retain and motivate the talent we need to differentiate in this incredibly tough economic environment.”

SERPs are often offered alongside several other types of long-term incentive compensation vehicles. Long-term plans can include stock options, stock appreciation rights, phantom stock, restricted stock, restricted units, performance shares of units and combinations of two or three plans. All of these programs are also a form of deferred compensation, like a SERP, but don’t offer as much customization as a SERP. Additionally, most institutions use bank owned life insurance as an indirect funding approach.

A bank may design the SERP so the executive receives a benefit at a later date — like retirement or after 15 years of service. The benefit of the SERP may be issued as a lump sum, a series of payments or combination thereof. It can also have performance criteria added as a motivational incentive. And because there are no contribution limits, this ability to customize and design around one executive team generates a significant ROI. Payne says Guaranty “strongly believes” in the customization of its long-term compensation plans.

“We find customization increases the appreciation of our efforts. In addition, when used with other plans like the annual incentive plan, and other stock-based long-term incentives, we believe we are able to sustain bank leadership that creates a successful banking atmosphere,” he says.

But SERPs aren’t perfect; just like any other executive compensation and benefit plan, it’s critical that bank executives and boards understand their disadvantages. One disadvantage is the funds that accumulate for a SERP are not protected from bankruptcy and creditor claims in the event of insolvency. SERP participants become general creditors of the bank. Still, the plans offer significant advantages and can be incredibly attractive to banks as employers.

  1. They are easy to implement.
  2. The don’t require IRS approval.
  3. They can be customized to the executive team and included as a retirement benefit.
  4. Banks can use BOLI to help recover their costs and offer a split-dollar life insurance benefit while employed.

All of these advantages combined make for a powerful compensation cocktail that, when used in conjunction with other plans and communicated appropriately, is dynamite.

Banks are under more pressure than ever before to succeed. The pandemic, low interest rates and political uncertainty all contribute to questions and uncertainty in the workplace — including among top executives. SERPs can be a powerful tool in the hands of visionary banks. The flexibility afforded in a SERP is second to none. Finally, it’s just smart business to make sure banks can differentiate themselves while being sustainable by attracting, retaining and motivating the best talent possible.

What Employers Need to Know about Coronavirus, Paid Leave

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From lobby closures to Paycheck Protection Program loans, the COVID-19 pandemic has thrown a lot at banks and other financial services providers during this pandemic. One more item to add to the list is the Families First Coronavirus Response Act (FFCRA).

The FFCRA is not one law but a suite of laws targeted at lessening the effects of the pandemic, including two laws that establish paid leave requirements on covered employers: the Emergency Family and Medical Leave Expansion Act (EFMLEA) and the Emergency Paid Sick Leave Act (EPSLA). As is the case with many employment laws and rules, a bank that fails to comply with the FFCRA paid leave requirements does so at its peril.

Who are covered employers?
The paid leave requirements generally apply to all private employers with fewer than 500 employees. There are limited exceptions to the Emergency Family and Medical Leave Expansion Act leave requirements for employers with fewer than 50 employees relating to leave for school and child care closures. A bank looking to take advantage of the EFMLEA exceptions should closely study the circumstances and the exception criteria. Further, while the federal rules apply only to small (under 500 employee) employers, some states’ paid leave laws cover large employers as well.

Who are eligible employees?
Employee eligibility is one area where Emergency Family and Medical Leave Expansion Act and Emergency Paid Sick Leave Act diverge. Paid leave under the EFMLEA is available to employees who have been employed for a minimum of 30 calendar days. For EPSLA related leave, all employees qualify, regardless of their length of employment. EFMLEA and EPSLA each apply to part-time as well as full-time employees and neither require an employer to provide paid leave to furloughed employees.

When can employees utilize paid leave benefits?
This is another area where the two statutes diverge. The EPSLA provides for paid leave if the employee is unable to work (or telework) because the employee:

  1. Is subject to a federal, state or local quarantine or isolation order.
  2. Has been advised by a health care provider to self-quarantine.
  3. Is experiencing symptoms of COVID-19 and is seeking a diagnosis.
  4. Is caring for an individual covered by (1) or (2) above.
  5. Is caring for a son or daughter whose school or place of care is closed or whose child care provider is unavailable due to COVID-19 precautions.
  6. Is experiencing any other substantially similar condition specified by the Secretary of Health and Human Services.

The Emergency Family and Medical Leave Expansion Act, as its name implies, is an expansion of the Family and Medical Leave Act and is triggered by the need for the employee to care for someone else, in this case the employee’s child. Specifically, EFMLEA provides for paid leave to employees who must care for a minor child because of a coronavirus-related school closure or childcare provider loss. EFMLEA benefits only are available if the employee is unable to work from home or telework. We should note, however, that employees who become ill with COVID-19 or are caring for family members who have COVID-19 may still be covered by the FMLA original unpaid “serious health condition” provision.

What are the paid leave benefits?
Under the Emergency Paid Sick Leave Act, full-time employees are entitled to 80 hours (i.e., 10 days) of emergency paid sick leave at either full-rate (reasons 1, 2 and 3 above) or two-thirds rate (reasons 4, 5 and 6 above). The benefit is capped at $511 per day when the employee is absent for reasons 1, 2 or 3, and $200 per day for reasons 4, 5 and 6. Part-time employees are entitled to receive a proportionately similar amount of leave based on their average hours worked in a two-week period.
For 10 weeks an eligible employee is entitled to receive up to two-thirds of their regular rate of pay, capped $200 per day under the EFMLEA. We should note here, that an employee can take advantage of the EPSLA benefit of up to $200 per day for the first 10 days of leave to care for a child due to school or childcare closing, bringing the maximum paid leave benefit to $12,000 for child care reasons.

How does a bank pay for this new requirement?
To soften the blow on banks and other employers of the mandatory paid leave under the FFCRA, the law provides for a dollar-for-dollar refundable tax credit for amounts paid by eligible employers. The refundable tax credit applies to all EPSLA and EFMLEA wages paid during the period from April 1 to Dec. 31, 2020. Compliance with the eligibility and record-keeping requirements of the law will be critical to the bank qualifying for the tax credit.

Keeping Benefits Simple During M&A

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Mergers and acquisitions are an attractive growth strategy for many banks, but deals are increasingly and needlessly complicated by existing employee benefit plans.

The United States entered the longest economic expansion in history during the third quarter of 2019, surpassing the 120-month run between March 1991 to March 2001. There have been parallels of economic events and potential perils between then and now: a strong housing market, corporate tax cuts, low interest rates, and a mergers and acquisitions environment that rivals the 1990s, resulting in a loss of more than 4% of the nation’s banks per annum on average. From March 1991 to today, the number of U.S. banks has decreased by over 60%. The industry is not only used to M&A but expects it.

But in recent years, we’ve seen a growing burden and complexity in navigating through bank M&A deals, in part due to existing nonqualified benefit plans and bank-owned life insurance, or BOLI, programs. Burdens include heightened regulations on allowable plan designs, evolving tax laws and stricter compliance and due diligence requirements.

Now more than ever, it has become increasingly likely that BOLI or nonqualified benefit plans will be involved in a transaction, and odds are that the acquired portfolio and plans were part of a previous deal.

About 64% of banks across the country owned BOLI at the end of 2018, according to data from S&P Global Market Intelligence, including 63% of banks under $2.5 billion in total assets, 82% of banks between $2.5 billion and $35 billion, and 64% of banks over $35 billion.

The BOLI market continues to expand as banks continue to consolidate, and new premium sales have averaged over $3.5 billion annually in the past five years. Additionally, approximately 65% of banks have a nonqualified benefit plan, split-dollar life insurance plan or both, based on records of Newcleus’ 750 clients.

Program sponsorship continues to expand, because BOLI and nonqualified benefits continue to be important programs for institutions. Implementing nonqualified benefit plans can serve as a valuable resource for banks looking to attract and retain key talent. Both selling and acquiring institutions need to understand the mechanics of benefit and BOLI programs in order to avoid inaccurate plan administration and mismanagement following a combination. This includes:

Non-Qualified Benefit Plans

  • Reviewing the plan agreement: Complete a thorough analysis of the established plan agreements. Understand all triggering events for benefits, available options to exit the plan and the agreement’s change-in-control language.
  • Accounting implications: The bank, in partnership with their plan administrator, should properly vet the mechanics and assumptions used in existing plan accounting. For example, change-in-control benefits could specify a discount rate that must be used for benefit payments, which may differ from rates used on existing accounting reports. They should also ensure that all plan benefits deemed de minimis have been accounted for, such as small split-dollar plans.
  • 280G: Complete a 280G analysis to understand the possible implications of excess parachute payments, including limitations (i.e. net best benefit provisions) caused by existing employee agreements and related non-compete provisions.

BOLI Programs

  • Insurance carrier due diligence: Bankers should complete a thorough review to ensure that acquired BOLI meets the holding requirement that is outlined by the bank’s existing BOLI investment policy, if applicable.
  • Active/inactive BOLI population: As the insured and surviving owner relationship becomes more separated, it is paramount that executives maintain detailed census information, including Social Security numbers, for mortality and insurable interest purposes.
  • Policy ownership: Many banks have implemented trusts to act as the owner of certain BOLI policies. While this setup is permissible, changes in control can impact a trust’s revocability. Institutions should review this information prior to closing, given that there may be limited options to directly manage those policies post-deal close.

These programs are not in the executives’ everyday purview, nor should they be. That’s why it’s so important for institutions to establish partnerships that help guide them through the analysis, documentation and due diligence process for BOLI and nonqualified benefit plans.

Banks may want to consider working with external advisors to conduct a thorough review of existing programs and examine all plan details. They may also want to consider administrative systems, like Newcleus MINTS, that streamline reporting and compliance requirements. Taking these steps can help reduce unnecessary headaches, and create a solid foundation for future BOLI purchases and new nonqualified benefit plans.

The Battle for Bank Talent: Trends and Strategies

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Motivated, talented employees always have been critical to the success of financial services organizations, meaning there always has been competition to attract high-performing employees. However, recent research indicates that competition has heated up considerably in the past few years, making it even more important for banks to stay abreast of current trends in compensation and human resource practices.

Trends in the Battle for Talent
The most recent indicator of the intensifying competition for talent can be found in the Crowe Horwath LLP 2016 Financial Institutions Compensation and Benefits Survey. Of the many trends in compensation, incentive and benefits strategies that are tracked in this annual survey, three areas were particularly revealing in 2016:

Employees are changing jobs at the fastest pace in at least a decade, with both officer and nonofficer turnover trending sharply upward over the past two years. Some turnover is the result of consolidations or performance issues, but most turnover represents the voluntary departure of employees–usually at a significant cost to the banks.

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Bank staffing strategies appear to have recovered from the recession. More banks today are planning for normal growth in staffing (35.6 percent), while the number of banks planning to maintain (34.1 percent) or reduce (3.6 percent) staffing levels is declining to pre-recession levels.

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The percentage of banks that plan to implement above-market compensation strategies has increased steadily over the past four years. In the 2016 survey, 28.5 percent of banks reported their strategy was to pay more than 10 percent above the market average.

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Taken together, these three trends–higher turnover, expected staffing increases, and growing use of above-market compensation strategies–suggest that the battle for talent is likely to continue and intensify.

Factors Driving the Competition
Viewing the survey results through the lens of current industry experience, one might reasonably conclude that bank compensation strategies are no longer responding to recession and credit crisis concerns. The survey responses suggest that banks are now being driven by a new set of economic and competitive factors including:

  • Employee expectations: As memories of recession-driven job insecurity fade, events such as bank consolidations, increased profitability and rising executive compensation are catching employees’ attention. The increased turnover rate suggests that high performers in search of better opportunities are more willing to take a chance and make a move now.
  • Growth strategies: Although mergers or acquisitions often are associated with net reductions in payroll, bank consolidations also can create demand for managers and executives who are more experienced in handling larger organizations. Other market strategies—such as enhanced digital banking or a relationship-banking approach—also can drive demand for employees with technical or consultative-selling skills.
  • Technology: Just as technology affects some of the skills needed to serve bank customers, it also is changing some employer-employee relationships. The “gig economy,” where short-term contract workers provide specialized services to multiple employers, has not yet affected most traditional bank jobs but certain positions—marketers, data analysts and website or mobile banking developers, for example—often can be filled by contract workers rather than full-time employees.
  • Competition: Banks with strong market positions in commercial lending or other desirable business lines sometimes find themselves on the defensive as they ward off competitors trying to lure away their most productive employees. Often banks end up offering selective pay boosts and bonuses to discourage so-called “lift out” strategies, in which a competitor lures away key managers or an entire department.

New Approaches to the Battle for Talent
Putting more emphasis on pay—particularly performance-based pay or incentives—is one way to attract and retain high performers. But higher pay scales are not the only solution.

Many banks that are consistently regarded as “employers of choice” are not the highest paying employers in their markets—or even the highest paying among comparable banks. Instead, they shift a portion of their workforce investments toward maintaining benefit programs and work cultures that promote work-life balance.

Some banks now present employees with an annual “total rewards statement” that spells out all the investments their employers are making in them. Such statements can help motivate employees by reminding them of their value to the organization. Individual personal recognition, status and career opportunities can also be powerful motivators.

Regardless of the specific mix of techniques that are used, the intensifying battle for talent means banks will need to pursue a deliberate, multifaceted approach to attract, motivate and retain the talented and high-performing employees they need to pursue their business strategies.

Mitigating Risk When Choosing a BOLI Carrier for Your Community Bank

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BOLI-3-9-16.pngIf your community bank is considering revamping your benefits offerings, you’ve probably thought about Bank-Owned Life Insurance (BOLI). Purchasing BOLI is one of the lowest risk ways for banks to fund the cost of their benefits, and for a community bank struggling to compete with commercial banks for top talent, this may be a strategic financial decision. While BOLI is a long-term investment, it generates tax-free interest, making it extremely appealing to community banks. As with any investment, the decision to purchase a BOLI portfolio must be carefully considered so you can get the most return with as little risk as possible. Here are some ways to ensure you choose the right BOLI carrier and get the most out of your policy.

  1. Document every part of the process to ensure compliance. Regulations require careful attention, and national bank regulators provide a roadmap for the pre-purchase due diligence and ongoing risk management of BOLI. Before beginning the process of selecting a BOLI carrier, keep in mind that every step your community bank takes needs to be documented. From when you first purchase BOLI and throughout the life of your policy, documentation is absolutely critical for regulatory compliance, so you should frequently review reports of the performance of your BOLI assets. If any process isn’t documented, then in the eyes of regulators, it doesn’t exist. If you’re unsure of the proper protocol, working with a consultant who understands the regulatory process can help you with any issues that arise.
  2. Conduct a financial analysis of BOLI carriers. When choosing between BOLI carriers, you need to look at a variety of metrics to make the best decision. In the past, some banks’ decision making was reliant on ratings from independent agencies, and while ratings are still important, they are not the only thing you need to consider. By conducting a financial analysis of the carrier, you can get a clearer picture of whether the purchase will keep risk low while providing the yield your bank needs to fund competitive benefits. Here are financial metrics that can help you narrow down your options to a shortlist of low-risk choices:

    • Financial strength: Looking at the carrier’s balance sheet and income statement can help you determine the company’s financial strength, as can ratings from outside agencies.
    • Asset quality: By reviewing publicly available information about the carrier’s assets, you can identify any unusual trends and verify the carrier’s claims paying ability.
    • Risk-Based Capital: Review the carrier’s level of capital over time, compared to the regulatory required amount.
    • Investment philosophy: How does the carrier approach their investment portfolio; what techniques do they use for asset liability matching?
    • Experience in the BOLI market: How long has the carrier been active in the BOLI industry, and have they built a reputation for success in that time?
    • Ownership structure: Is there a parent company that could provide support in time of distress? Does the carrier have a stock or mutual ownership structure?
  3. If you need help, work with an executive benefits consultant. Choosing the right BOLI package for your community bank is an important decision and there are many compliance and regulatory issues that some banks just don’t feel comfortable navigating on their own. Working with an expert is the best way to make the most profitable, lowest-risk decision and to ensure regulatory compliance. Your consultant must understand the operating environment of your bank and your strategic interests in order to help you reach your financial goals and fund your benefits package. While selecting a BOLI carrier and deciding how to fund your purchase is complicated and may require outside help, it is an option that has enabled many community banks to offer more competitive benefits to employees.

Banks Pay Higher Salaries, But There is More Turnover

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9-27-13-Crowe.pngEvery year Crowe conducts a compensation and benefits survey of financial institutions. The results of the 2013 Financial Institutions Compensation Survey are now in, and our analysis of the trends indicates some interesting patterns.

Pay is rising. Inflation expectations and market conditions appear to be strengthening as indicated by banks making larger upward adjustments to their salary structures.

2013 was not a banner year for CEO compensation growth. Slow compensation growth for CEOs in 2013 appears to indicate that bank financial performance has improved only modestly.

Hiring and retaining the right employees continue to be the highest-priority human resource concerns. While banks have several important priorities related to human resources, their most highly rated concerns appear to be finding and retaining the right employees.

Annual salary increases continue to average 2.70 percent. The market has settled into a stable range of annual salary increases.

Employee turnover is increasing. Employees appear to be more comfortable with their job prospects as turnover has returned to pre-recession levels.

Compensation growth varies widely by job position. Some job positions have experienced significant growth in compensation over the past four years while others have lagged. For example, compensation for chief credit officers is up 23 percent over the past four years, while branch manager II compensation is up only 9 percent.

Benefit costs continue to grow. Benefit costs as a percentage of salary continue to increase, with health benefits being the primary source of increased costs.

Benefit cost-containment efforts are a major focus. More than half of the banks surveyed are trying to contain costs by using a variety of techniques to shift a portion of benefit costs to employees.

This year, our analysis identified some differences between small banks (those with less than $1 billion in assets) and their larger brethren.

An above-market compensation strategy is more common at larger banks. A higher proportion of larger banks than smaller banks indicated they are consciously paying above-market compensation.

Smaller banks are doing a better job of differentiating pay for above-average performers. Smaller banks had a higher differential of pay increases between above-average performers and average performers.

Larger banks pay a higher proportion of incentives. Incentives as a percentage of salary are typically higher at larger banks, although the difference and amount vary from year to year.

Banks with more than $1 billion in assets are expecting more growth. A higher proportion of larger banks expect their number of employees to grow compared with their smaller counterparts.

View a full summary of the results of the survey for more detailed findings.