Hail to the Chiefs

Does creating snappy job titles lead to a better performing or more “in touch” bank? Possibly. But we are skeptical and at this point, it is too early to ascribe empirical evidence to say “yes’ or “no.”

The proliferation of titles such as “Head of Digital Banking,” “Head of Consumer Insights and Innovation,” “Cannabis Risk Officer” and so on have signaled priorities, but have they accomplished anything? In practice, it seems some new titles are not well aligned with the new skills needed to drive strategy or promote innovation. In some — or many — instances, it might be counterproductive if a bank is parsing responsibilities even further, muddying the waters on who is responsible for executing what.

We often see this in employee development. Many first-line supervisors, and even executive management, are under the false belief that the Chief People Officer, another name for the head of human resources, is primarily responsible for employee development. As a result, we see little execution that results in well-developed employees who can move the bank forward.

A common weakness uncovered in the bank strategy sessions or process improvement engagements that our firm undertakes is bank silos. Do titles lead to more silos or to more collaboration? Your chief innovation officer is not responsible for creating an end-to-end paperless mortgage experience that can go from application to close in less than three weeks. Your head of mortgage lending is — and that is based on knowing what customers demand.

Prior to advances in technology, the industry was awash in data. With these advances, there is even more of it. This is what drives banks to enlist data scientists, a functional position we highly support — although it is perhaps an exaggerated title. In a recent banking podcast, Kim Snyder, CEO and founder of data visualization firm KlariVis, spoke eloquently about data governance and integrity. How do we pull meaningful data out of our systems if we lack discipline in what we put in them?

How to use the data, how to make sure the data is well aligned across the organization and determining  who is responsible is the conundrum all banks face. Commercial lenders might belly ache about being held accountable for a client’s total relationship, which may affect compensation or how employees or how a bank markets their services. But this makes the lender keenly interested in viewing the total relationship across loans and deposits, wealth and other third-party systems that impacts many organizational silos.

Why would banks want to create even more silos with these newfangled chiefs? Convincing executive management teams that they are responsible for the entire bank, not solely their functional positions, has been a struggle. Would we exacerbate that struggle by creating positions that tell the head of commercial lending they are no longer responsible for their employees’ development or the department’s diversity since the bank now has a chief diversity officer? When many are responsible, nobody is accountable.

When executing a mission in the military, the senior officer of the operation issues something called a “Commander’s Intent.” This communicates to each unit what the commander deems success, such as “It is the Commander’s Intent that this mission degrades the enemy’s surface to air missile capability by 75%.” Each unit commander plays a role in executing the Commander’s Intent, with appropriate coordination. Could banking use such cultural discipline to achieve executives or the boards’ intent, without developing creative job titles or dispersing responsibilities to chief this or chief that?

We at The Kafafian Group think so. Keep your organization simple. Define roles and accountabilities. Issue your Commander’s Intent for missions that you currently use chiefs to define. Coordinate accountabilities and focus on execution and organizational learning. Success will be evident; one day, your bank will be called a “Top Performer” or an “Innovator” — a title that any executive management team can get behind.

What Banks Are Doing Now to Handle Compliance


4-13-15-Naomi.pngA heightened regulatory environment is here to stay, that much seems clear. So how are banks and bank management teams coping?

They are hiring more employees, buying software, scrutinizing vendors for compliance and focusing more and more on the business of complying with regulations, in addition to running the bank. Preston Kennedy, the CEO of $200 million asset Bank of Zachary, in Zachary, Louisiana, says he spends one-third of his time on compliance and regulations. “The regulations are now the table stakes,’’ he says. “If you want to go outside in the winter, you have to wear a coat. If you want to be a banker, you have to abide by a lot of regulations. ”

The following is a list of ways in which banks are coping with increased regulations.

Hiring a Chief Compliance Officer or Chief Risk Officer
Previously the domain of the largest banks, even small banks are hiring chief risk officers or chief compliance officers. In Bank Director’s 2015 Risk Practices Survey, 71 percent of respondents from banks below $1 billion in assets had a chief risk officer. So, too, did 92 percent of respondents from banks with $1 billion to $5 billion in assets. Bank of Zachary, despite its small size, has both a compliance officer and a recently hired chief risk officer, who reports directly to the CEO and the board of directors.

Buying Compliance Software or Getting Outside Advice
Banks also are turning to software vendors, core processors and outside consultants such as Fiserv, FIS, Computer Services, Inc. and DH Corp. to help manage compliance. “We are definitely seeing more indications that banks are relying on software more in all different areas,” says Christine Pratt, a senior analyst at financial services research firm Aite Group. Bank of Zachary just purchased a $35,000 program from Continuity to keep track of new regulations that will impact the bank, and help the bank document its compliance. Proper documentation is key because banks have to prove to regulators that they are in compliance. “In order to run a $200 million bank in suburban Louisiana, we have to rely on a company that is hardwired to the government to keep up with this pipeline of new regulations,’’ Kennedy says. “It’s absolutely ridiculous but it’s the task that we have.”

Incorporating Compliance
Banks are shifting away from handling compliance after the fact and moving toward incorporating compliance into many of their basic business processes, says Jamie van der Hagen, director of consumer lending for Wolters Kluwer Financial & Compliance Services, which sells regulatory consulting services and compliance software to banks. For example, instead of giving out loans and then checking to see if they meet fair lending standards, banks increasingly incorporate fair lending standards into the process of making loans. “Proactive compliance efforts, through automated testing for example, help banks validate their entire portfolio of products and accounts and identify potential compliance issues before they become a problem,’’ says van der Hagen. “Finding and addressing these possible compliance issues can have a positive impact on the bottom line by enabling institutions to identify loans that qualify for CRA credits and other premiums that can help them improve their overall bottom line.”

Starting to Prepare in Advance of Knowing the Final Rules
Banks are finding they have less time than in prior years to adjust after a rule is finalized and goes into effect. That means they have to prepare even as the rules are in the proposal stage. “They don’t have the time anymore to wait for the rule to be formulated,” says Pratt. “Banks have told me they’re writing two different versions of software [to prepare ahead of time]. That’s incredibly expensive.” Alternatively, vendors should help with the process of updating software on time.

Scrutinizing Vendors for Compliance
Regulators are increasingly emphasizing that banks are responsible for the missteps of their vendors on pretty much every law or regulation, including fair lending, debt collection or unfair consumer practices. The New York State Department of Financial Services, the state’s banking regulator, recently surveyed banks to determine their oversight of vendors for cybersecurity, as it is preparing new regulations on how banks should monitor third party vendors. Managing a bank’s vendors for compliance is a complex process, but there are general guidelines to getting it right.

However much of a burden it feels, bank management teams and boards know that they have to comply with regulations to stay in business. Managing the pace of regulatory change and keeping the bank out of the crosshairs of regulatory fines and punitive enforcement actions has become a core responsibility of the bank’s management team. “The pace of regulatory change has really increased in the last 10 years and there is no indication that it is going to go down,’’ says van der Hagen.