Nine Vendor Risk Management Tips for the Board

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risk-management-7-19-17.png2017 is already proving to be a very difficult year for bank boards. While being on a board can be a rewarding experience, increasing regulatory pressures certainly don’t make the position and its corresponding responsibilities any easier.

One particular area of intense focus by the regulators is third-party risk management. Ultimately, the regulators have stated that it is your responsibility to ensure that you have a third-party risk program in place that addresses your vendors and the level of risk they pose.

Aside from potential enforcement actions and fines from the regulators, an inadequate third-party risk program can leave your institution ill-prepared or vulnerable to a host of issues. Worsening vendor financial performance could be an indicator of woes to come, such as poor customer service, bugs and issues with its system. Banks that auto-renew vendor contracts could miss a chance to re-negotiate old contracts.

Poor due diligence could mean partnering with a vendor that is damaging to your institution’s reputation. For example, if you don’t understand where customer complaints are coming from and why, regulators could question your ability to properly oversee and monitor your vendor’s performance and manage the corresponding impact on your customers.

While there will always be unforeseen issues you cannot avoid, having an effective third-party risk policy and program in place can ensure your full compliance with the guidance and help steer you to partnerships that will benefit your institution.

And, even when those unforeseen issues do occur, and they will, you’re better prepared to react in an effective and organized manner. To help, here are nine tips to keep you on the right path.

Nine Vendor Risk Management Tips for the Board

1. Read and understand the guidance from your primary regulator as it pertains to third-party risk management. There are key expectations clearly identified in the guidance and they should give you ample fodder for asking your institution’s senior management team pertinent questions.

2. Set expectations and tone from the top. Make sure that from senior management all the way to the front-line customer service representatives, everyone understands his or her responsibilities when it comes to compliance with the rules, as well as how your organization wants to handle vendor-risk management.

3. Have your vendor risk management program thoroughly reviewed for any possible deficiencies and focus on areas that are often overlooked, such as fourth-party risk management or reviewing third parties’ procedures for complaint management.

4. Automate your third-party risk program. Most institutions have already taken the steps away from Excel and other spreadsheet programs in favor of ones that help to manage a complicated network of vendors and regulatory expectations.

5. Involve your internal audit department, compliance team and counsel in evaluating the effectiveness of the vendor management program.

6. Strongly consider making vendor management directly accountable to the board or the most senior risk committee at your institution. Firmly establish its independence from the various lines of business and ensure the needs of vendor management do not fall on deaf ears. Ensure that any issues raised, whether in the course of normal business or during examinations, are promptly and thoroughly addressed.

7. Invite the head of your vendor management program to report regularly at board meetings. A standard set of reports is adequate, but make sure that any concerns or significant issues are clearly called out and reflected in the minutes of the meetings.

8. Ensure those involved in vendor management have adequate resources, such as staffing and a high enough budget, as well as ample training and experience to do the job well. Seek outside independent expertise or outsource tasks where needed, particularly for highly technical items such as business continuity plan reviews for SSAE 18 analysis, attestation standards issued by the American Institute of CPAs.

9. Ask pertinent questions and drill down when anything seems amiss. Use industry news, new regulations and enforcement actions as opportunities to view your own vendor management program through that lens and see if there are areas of concern that should be addressed.

The world of vendor management isn’t easy and your job as a director is incredibly complex and overwhelming at times. Fortunately, done well, vendor risk management can also be a significant strategic advantage, allowing you to do business with well-managed companies in a compliant and cost-efficient manner.

Resources
Venminder Library
CFPB guidance 2016-02
FDIC FIL 44 2008
OCC Bulletin 2013 29
OCC Bulletin 2017 21
FFIEC Appendix J

Filling Fraud Detection Gaps

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Investment in fraud detection can be a competitive advantage, especially as real-time payments initiatives create new opportunities—and threats—for financial institutions. Luis Rojas of Bottomline Technologies explains where and how to address gaps in fraud detection, and how bank boards should examine the true costs of fraud.

Outlooks for Payments Fraud

  • How Banks Should Address Fraud Gaps
  • Dealing with Legacy Systems
  • What Boards Need to Understand

Facing Up to the Financial Technology Challenge

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technology-5-18-17.pngOf all the most difficult issues that bank boards must deal with, technology may be at the top of the list. Banks have long been reliant on technology (think IBM mainframes and ATMs) to run their operations, but in recent years technology has become a primary driver of retail and small business banking strategy. This change can be tied to the growing ubiquity of digital commerce, the integration of the mobile phone into the fabric of our everyday lives, the birth of social media and its adoption as an important business and commercial channel, and the ascendency of the millennial cohort as a major factor in our economy. Technology is everywhere, it’s in everything, and that trend is only going to become more pronounced in the future.

Why do bank directors as a group struggle so much with technology? Are they just a bunch of Luddites? In all fairness, most directors are not career technologists and therefore bring only limited professional knowledge of technology to the task of board governance. But demographics are clearly a factor as well. The average age for most bank boards ranges between the early 60s to the mid-70s, and baby boomers often find themselves overwhelmed by all of the technology-driven changes they see occurring around them. And while there may be an understandable tendency to resist adapting to new technologies in their personal lives, bank directors simply must understand how technology is changing their industry, and how it is impacting their institutions.

Christa Steele is the former president and CEO of Mechanics Bank, a $3.4 billion asset bank in Richmond, California, and more recently the founder and CEO of Boardroom Consulting LLC in San Francisco, where she works closely with bank CEOs and their boards. Steele doesn’t mince words—directors must educate themselves about the changes in financial technology that are transforming their industry—and she offers some suggestions about how this can be done. The following interview has been edited for length and clarity.

BD: Why do most directors at community banks struggle so much with the topic of technology?
Scope of knowledge and lack of diversity in the boardroom. This diversity does not stop at gender, age and ethnicity. Typically, community bank boardrooms are filled with childhood friends and family. This served a purpose early on, especially when those banks were formed. However, as a bank grows and evolves, it’s important to bring in new perspectives. It’s no secret that the majority of community bank revenue models are derived from the net interest margin. Fee revenue is virtually obsolete relative to the overall operating income for most of these institutions.

So how does a bank make up for this shortfall of diversified revenue streams? Management teams and their bank boards need to take a serious look at their digital strategy and internal infrastructure. If they do not assimilate to the changes occurring in what I call this vortex of technology, they’re going to get left behind.

Fixing this starts with succession planning for the institution. We have a lot of community banks where the management teams are close to or at retirement age. Many of these leaders do not want to make necessary changes because of the threat of internal disruption, time commitment, costs and maintaining a short-term horizon. Boards are similar. Most bank boards are tired. I feel boards in general have done an exceptional job getting their arms around compliance and safety and soundness issues in the last 10 years. However, they’ve taken their eye off of the ball when it comes to marketing, digital strategy and technology initiatives. I remember hearing about a Bank Director survey a few years ago in which board members were polled and asked how many of them used their cell phones to transact. It was staggering to learn that nearly half of the respondents didn’t use their bank’s mobile channel. How are these board members supposed to understand technology trends and its impact on the financial sector and their own banks?

BD: What can directors do to become more comfortable with technology?
Get educated beyond compliance training. Attend Bank Director conferences, ask questions, talk to folks involved in financial technology, follow automation. Pay attention to what’s trending. Get connected to social media. Join LinkedIn and gain perspective on what’s going on in the United States and abroad pertaining to technology in the financial sector. See what other people are doing outside of your own market.

Change up the boardroom. Board appointment should be strategic in nature and no longer be about bringing your childhood friend or local jeweler down the street on your board. Bring in a fresh perspective. Evaluate board terms and board limits. A board that is a strategic asset to its bank should consist of expertise in marketing, cybersecurity, digital/e-commerce, financial and risk. Each of these appointments should be from outside your institution. Do not be opposed to bringing in someone younger in their 30s or 40s. By bringing in somebody younger, you bring in someone who is engaged in social media. Social media is where it’s at. We have banks that are interacting and partnering with Facebook. Bank of America just started letting customers transact through a universal login with Facebook where their customers can pay their mortgage payments, they can transfer money between accounts, they can do a variety of things through Facebook. The remainder of your director appointments should be former or current CEOs who provide a macro-level mindset to the ongoing challenges facing the institution.

BD: What are some of the barriers to innovation, particularly in the community bank space, around financial technology?
Lack of understanding the competitive landscape (it’s no longer just the community bank down the street), time, cost and willingness to embark upon a digital transformation. It’s a lot of heavy lifting for management, and oftentimes the board does not understand the complexities and costs associated with this endeavor. Many banks do not fully understand the technology contracts they have in place with their core providers and other technology vendors. Those contracts have them locked in for a duration of time, typically three to seven years. That is the number one barrier to making any changes. It is costly to exit existing contracts.

Many community banks are under utilizing the capability of their existing vendors. At Mechanics Bank, we went through and evaluated every vendor contract. We cut $3.5 million dollars out of our budget in a single calendar year through renegotiating, exiting and forming new relationships with vendors. We found we were paying for services we did not need and paying for services we weren’t using but should be using. This is the first step in embarking upon a new digital strategy.

I highly encourage bank boards to have a refresher course on how a bank operates using a bank simulation model. Each board member picks a role of CEO, CFO, senior credit officer, etc. and has to manage a bank’s funding, pricing, growth, capital requirements, loan loss provisions and so on. This is not only a great team-building exercise and will provide for a greater appreciation of the day-to-day management team of the bank, it will also set a solid foundation for discussing what is needed in the way of technology innovation to run the bank going forward.

Evaluate what you have, get educated on what’s trending, then decide what you need. Do not be the retailer that gets eaten alive by Amazon Prime. Be proactive instead of reactive to the changing needs of your customer base.

BD: Are the major cores an impediment to innovation?
I wouldn’t say impediment. There is no doubt that the big three core technology providers have a stronghold. But they are looking to innovate as well. Their biggest attribute is size and scale. Their biggest downfall is they are a slow-moving ship coming in and out of port. The long and the short of it is, you’re not going to get rid of your core provider. I feel it’s become increasingly important to be better partners with your core. When banks push for some kind of innovation, the cores typically say they’re planning on doing that two years from now. That is when the banks get irritated and push for needing it now but do not want to have to pay for a custom project. That is the frustrating part for the bankers, but the bankers need to help the core understand their needs. I am a firm believer in more outsourcing and in banks becoming nimble. This takes time but is achievable and necessary in this day and age.

BD: When we think about the technology challenges that banks face today and how the board should engage in finding solutions, does it really boil down to a people issue?
Yes, it is that simple. There are a lot of community banks that just refuse to think that financial technology innovation is impacting them. CEOs and directors need to have an open mind and be willing to learn something new. If you understand your digital strategy, you understand your technology strategy and you understand what’s going on around you—guess what, all of the sudden your board is engaged, and it’s going to make your company perform better.

M&A Readiness: Making Sure Your Bank Can Do Acquisitions

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acquisitions-5-10-17.pngWith many financial institutions benefiting from increased stock values and renewed optimism following the November election, merger activity for community banks is on the uptick. Successful acquirers must remain in a state of readiness to take advantage of opportunities as they present themselves.

Whether a prolonged courtship or a pitch book from an investment banker, deals hardly, if ever, show up when it is most convenient for a buyer to execute on them. As a result, buyers need to develop a plan as to what they want, where they want it and what they are willing to pay for it, long before the “it” becomes available. M&A readiness equates to the board of directors working with management to have a well-defined M&A process that includes the internal and external resources ready to jump in to conduct due diligence, structure a transaction and map out integration. Also, M&A readiness requires that buyers have their house in order, meaning that their technology is scalable, they have no compliance issues and the capital is on hand or readily available to support an acquisition.

Technology. In assessing the scalability of an institution’s technology for acquisitions, a buyer should review its existing technology contracts to see if it has the ability to mitigate or even eliminate termination fees for targets that utilize the same core provider. Without this feature, some deals cannot happen due to the costs of terminating the target’s data processing contracts. Cybersecurity is another key element of readiness. As an institution grows, its cybersecurity needs to advance in accordance with its size. Buyers need to understand targets’ cybersecurity procedures and providers in order to ensure that their own systems overlap and don’t create gaps of coverage, increasing risk. Additionally, buyers should understand existing cybersecurity insurance coverage and the impact of a transaction on such policies.

Compliance. Compliance readiness, or lack thereof, are the rocks against which even the best acquisition plans can crash and sink. Ensure that your Bank Secrecy Act/anti-money laundering programs are above reproach and operating effectively, and that your fair lending and Community Reinvestment Act policies, procedures and practices are effective. Running into compliance issues will cause missed opportunities as the regulators prohibit any expansion activities until any issues are resolved.

Conducting a thorough review of compliance programs of a target is critical to an efficient regulatory and integration process. A challenge to overcome is the regulators’ prohibition on buyers reviewing confidential supervisory information (CSI), including exam reports as part of due diligence. While the sharing of this information has always been prohibited, the regulatory agencies have become more diligent on enforcement of this prohibition. Although it is possible to request permission from the applicable regulatory agency to review CSI, the presumption is that the regulators will reject the request or it will not be answered until the request is stale. As such, buyers should enhance their discussions with target’s management to elicit the same type of information without causing the target to disclose CSI. A simple starting point is for the buyer to ask how many pages were in the last exam report.

While stress testing may officially apply to banks with $10 billion or more in assets, regulators are expecting smaller banks to prevent concentrations of risk from building up in their portfolios. The expectation is for banks to conduct annual stress tests, particularly among their commercial real estate (CRE) loans. Because of these expectations, buyers need to know the interagency guidance governing CRE concentrations and how they will be viewed on a combined basis. Reviewing different stress-test approaches can help banks better understand the alternatives that are available to meet their unique requirements.

Capital. An effective capital plan includes triggers to notify the institution’s board when additional capital will be needed and contemplates how it will obtain that capital. Ideally, the buyer’s capital plan works in tandem with its strategic plan as it relates to growth through acquisitions. Recently the public capital markets have become much more receptive to sales of community bank stock, but this has not always been the case. In evaluating an acquisition, the regulators will expect to see significant capital to absorb the target as well as continue to implement the buyer’s strategic plan.

The increase in financial institution stock prices has increased acquisition opportunities and M&A activity since the election. Opportunistic financial institutions have plans in place and solid understandings of their own technology needs and agreements, regulatory compliance issues and capital sources. Although it sounds simple, a developed acquisition strategy will aid buyers in taking advantage of opportunities and minimizing risk in the current environment.

Handling Today’s Top Risk Challenges

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Cybersecurity and compliance are the top two areas of concern for the bank executives and directors responding to Bank Director’s 2017 Risk Practices Survey, sponsored by FIS. What are the best practices that boards should implement to mitigate these risks? In this video, Sai Huda of FIS highlights the survey results and details how boards can stay proactive.

  • Cybersecurity and Compliance Gaps
  • Five Cybersecurity Best Practices
  • Three Ways to Strengthen Internal Controls

What Does 2017 Hold for the Alternative Investment Industry?

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Last year was an exciting one in the alternative investment industry, and all indications point to another great year in 2017. Here are five predictions that will dominate the industry in 2017.

1. Capital invested in private equity funds will continue to increase amidst a further decline in hedge funds
Growth in alternative investments will continue to be explosive in 2017. According to a report from Cerulli & Associates, the mean allocation of alternative investments is still less than 5 percent of overall assets. Depending on the industry source, the general guidance is that the ideal allocation should be in the 15 percent to 25 percent range, signaling that there is a lot more room to grow.

Nowhere has that growth been more evident than in private equity funds, which have increased dramatically over the past few years. Assets have risen from $30 billion in 1995 to around $4 trillion in 2015. This growth will continue, as 64 percent of limited partners plan to increase their allocation to private equity funds, which is up from 26 percent just five years ago.

Hedge funds, on the other hand, have struggled as poor performance compounded by high fees resulted in large outflows in 2016.

2. Regulatory and compliance pressures will continue to increase even under a Trump administration
Regulatory and compliance pressures have been a dominant factor in the alternative Investment industry (and especially among hedge funds) for several years now. While some industry leaders are optimistic that a loosening of regulations will occur under the new Trump administration, the trend toward more transparency will continue to grow.

Study after study shows the impact of mounting regulatory and compliance pressures. Here are two reports that paint a clear picture:

  • In a Longitude Research study last year more than 50 percent of fund administrators predicted that the need to keep up with regulation would have the greatest impact on their activities over the following three years.
  • A report from Linedata showed regulatory and compliance being the chief concern facing fund administrators and fund managers alike.

3. Technological capabilities will become as important for fund administrators as accounting capabilities
Fund administrators are traditionally thought of as providers of accounting services. Technology was mostly thought of as internal plumbing, and the decisions made about the use of technology were often left in the hands of an IT department, with little senior-level involvement.

It’s safe to say that those days are over. This year we will see the further emergence of technology as an integral capability for any fund administrator—on par with the importance of their accounting capabilities.

Fund administrators rely on technology to give them the data, reporting and understanding needed to satisfy the evolving needs of their clients and investors. In fact, nine out of 10 fund administrators plan to invest in technology in the next three years.

4. Consolidation will continue to increase in the fund administration business
Competition in the fund administration industry is intense. This is being driven by the explosion in capital being invested, the increasing demands for regulatory transparency, and the economies of scale needed to effectively compete in a low-margin business. No metric shows this better than the one reported by Preqin that 28 percent of fund administrators have been fired by their clients in the past 12 months.

The trend toward consolidation has escalated significantly in the past two years. While this can be good news for the largest of funds that can afford the services of the largest of fund administrators, this consolidation is likely bad news for both mid-market fund managers and mid-market fund administrators.

5. Fund administrators will become a bigger force in private equity and real estate funds, as well as with family offices
The use of fund administrators is pretty much a requirement for hedge funds, as evidenced by the outsourcing to fund administrators increasing from 50 percent in 2006 to 81 percent in 2013. This dynamic really started taking shape in the wake of the Bernie Madoff scandal, which showed the perils of a lack of validation and supervision within the industry.

In comparison, fund administrators are under-penetrated in private equity and real estate funds, with estimates showing fund administrator penetration at around 30 percent of assets under management today. However, this is expected to increase 45 percent by 2018.

The same conditions that drove the shift to fund administrators in the hedge fund space affect private equity and real estate funds as well. Just as happened with investors in hedge funds, investors in private equity and real estate funds are demanding third-party validation of assets and performance. Regulatory pressures are already having an impact on general partners of private equity and real estate funds.

Although occurring more slowly, the need to turn to fund administrators is also happening in the single and multi-family office space thanks to an increasing rate of wealth and investments in ever more complicated asset types.

Why a Compliance Mindset Is Hurting Community Banks

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risk-management-1-20-17.pngCommunity banks are wasting money on compliance. They are spending more than ever, hiring additional risk officers, internal auditors, compliance officers, vendors and consultants. They are checking every box and fulfilling every mandate. And they are doing it all wrong.

A recent study by the supervision division at the Federal Reserve Bank of St. Louis found that spending more on compliance isn’t leading to higher regulatory ratings for the smallest community banks. It isn’t elevating the bank’s regulatory management scores, or positioning banks for success.

That’s because having a compliance mindset is a recipe for mediocrity, no matter the size of the bank. The banks that will earn the most leeway with regulators—and maximize value for shareholders—will naturally implement and utilize the tools and processes that are a prerequisite for compliance as a critical function of their strategic and capital planning processes.

When that happens, compliance becomes a mere afterthought; something that is more icing on a cake that doesn’t need icing to begin with. This type of approach is actually easy to execute. You don’t need expensive, overrated and highly misleading black-box models and software. You don’t need an entire department dedicated toward enterprise risk management.

What you do need is a cultural mindset, which starts with the CEO and the board of directors. They must change the outlook in the bank so that risk management tools are used to play offense, not defense. These proactive and forward-looking tools enable the team to see problems before they materialize. The CEO can then position the bank to gain a competitive edge, while its competitors (from both an operational and capital markets perspective) get blindsided.

I participated in a recent regulatory panel with the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corp. The topic was how best to manage commercial real estate concentrations. Part of the discussion revolved around the role of stress testing, which can be critical to showing examiners that a bank has enough capital to handle a risky portfolio.

Stress testing is a great tool for the job, but it’s a tool, not the job. Banks that simply submit stress tests to regulators as evidence that they can manage a loan portfolio aren’t going to get what they want.

Instead of viewing stress tests as an end game, bank CEOs need to think of them as tools to provide insights. Reports must be discussed at the board level and understood by the highest levels of management. And then the bank must adjust its strategy if the tests show a potential problem. This lesson applies to much more than concentrations. The results of adequate stress testing offer a strategic guide to capital planning, M&A and more.

The trick to compliance is to not treat it as a compliance exercise. It must be an integral part of strategic planning. A CEO cannot give a stress test to the chief risk officer and say, “Make the problem go away.” CEOs must look at the results, understand them and use them to adjust their strategic thinking. If organic growth is not working, the proper analytics can guide the executive team’s strategic course toward a merger or acquisition.

A funny thing happened when I began talking about this compliance mindset on the recent regulatory panel. The regulators nodded their heads in agreement.

Four Tips for Choosing a Fintech Partner

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Over the last three years we’ve implemented five strategic partnerships with fintech companies in industries such as mobile payments, investments and marketplace lending. In doing so, we’ve developed a reputation of being a nimble company for fintechs to partner with, yet we remain very selective in who we decide to work with.

We are very often asked–in places like the board room, at conferences and at networking events, how we choose what fintech companies to work with. It is a great question and one that needs to be looked at from a few angles. If you’re a financial institution looking to potentially begin partnering with fintech companies, below are some criteria to consider when vetting an opportunity.

A Strategic Fit: How does this relationship fit into your strategic plan? Finding a fintech that helps advance your goals may sound obvious, but it can be easy to get caught up in the fintech excitement, so don’t allow the latest fad to influence your choice of a partner. Don’t lose sight of your vision and make sure your potential partners buy into it. It’s better to have a few, meaningful partnerships than a host of relationships that may inadvertently distract you from your goals and spread your resources too thin.

Cultural Alignment: Make sure to do some research on the fintech’s management team, board of directors and advisory board. How do they–and their company’s mission-fit with your organization’s mission? Do you trust their team? Our CEO, Mike Butler, likes to say that we have a culture of trying to do things, not trying to NOT doing things. That’s important to us, and we want to work with teams that think similarly. Spending time together in the early stages of the relationship will help set the stage for a solid partnership in the future.

A Strong Business Plan: Is the company financially sound? Is their vision viable? Back to earlier commentary on not getting too caught up in the latest technology trend, consider testing the business idea on someone who isn’t a banker, like a friend or family member. While you might think it’s a great idea, does it appeal to a consumer that is not in our industry? If the business plan passes muster, another issue to consider is the fintech’s long-term plan and possible exit strategy, and the impact it would have on your business if the relationship went away. It’s important to understand both the fintech’s short- and long-term business plans and how those will impact your bank’s balance sheet and income statement today and in the future.

Compliance Buy-In: Does the fintech team appreciate the importance of security? Do they appreciate the role of regulation in banking and finance? Do they understand they may need to modify their solution in light of certain regulations? We know fintechs can sometimes look at banks with impatience, feeling that we’re slow to move. And while some might move at a slower pace than other, we banks know that there are good reasons to proceed cautiously and that compliance isn’t a “nice to have” when it comes to dealing with other people’s money. We are never willing to compromise security and are sure to emphasize that early in the conversation. It’s critical to find a partner with a similar commitment.

We’re in an exciting time; the conversations on both the bank and fintech sides are increasing about collaboration rather than competition. Considering criteria like the above will help banks take advantage of new possibilities in a meaningful way.

Cutting Compliance Costs with Regtech

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I was having a discussion about the future of banking with some fellow investors recently and one of my younger and more tech savvy associates opined that fintech companies would soon make traditional branch banking obsolete. It is a provocative idea but I am pretty sure he is wrong. Two decades from now it will still be fairly easy to find a bank branch a short drive away even if it is in a driverless car. Bankers will adapt and banking will become more mobile and more digital, but there will always be a place for banks and their branches in the economy.

Bankers are not sitting in their offices waiting to be replaced. They are finding ways to use new technology advancements to make their business faster, more efficient-and most importantly, less expensive. This is particularly true in one of the highest cost centers in the bank-regulatory compliance-where the automation of that detail intensive process is providing huge cost benefits. Compliance costs have been spiraling upward since the financial crisis led to an avalanche of new regulations, and technology might be the industry’s best hope of bringing those costs back down.

Bankers are starting to see the advantages of big data and analytics-based solutions when they are applied to the compliance challenge. “Although still in the early stages, banks are applying big data and advanced analytics across customer-facing channels, up and down the supply chain, and in risk and compliance functions,” said Bank of the West Chairman Michael Shepherd in a recent interview with the Reuters news service. For example, a growing number of banks are using new technology to automate the enormous data collection and management processes needed to file the proper compliance reports, particularly in areas like the Bank Secrecy Act. This new technology can help regional and community banks address data gathering and reporting challenges for regulatory compliance.

Smaller banks in particular are looking to partner with companies that can help build a data driven approach to compliance management. More than 80 percent of community banks have reported that compliance costs have risen by at least 5 percent as a result of the passage of the Dodd-Frank Act and the expense is causing many of the smallest institutions to seek merger partners. In fact, two of the biggest drivers of my investment process in the community bank stock sector is to identify banks where compliance costs are too high, and where there is a need to spend an enormous amount of money to bring their technology up to date. Odds are that those banks will be looking for a merger partner sooner rather than later.

While banks are looking to make the compliance process quicker, easier and cheaper, they also need to be aware that the regulators are developing a higher level of interest in the industry’s data collection and management systems as well. A recent report from consulting firm Deloitte noted that “[In] recent years regulatory reporting problems across the banking industry have more broadly called into question the credibility of data used for capital distributions and other key decisions. The [Federal Reserve Board] in particular is requesting specific details on the data quality controls and reconciliation processes that firms are using to determine the accuracy of their regulatory reports and capital plan submissions.”

The Consumer Financial Protection Bureau is also monitoring the compliance management process very closely. An assistant director there was quoted recently as saying that the bureau is increasingly focusing its supervisory work on the third-party compliance systems that both banks and nonbanks sometimes rely on. This is the behind-the-scenes technology that drives and supports the compliance process.

There is a developing opportunity for fintech companies to focus their efforts on providing regtech solutions to regional and community banks. The cost of compliance is excessive for many of these institutions and, for some, place their very survival into question. Regtech firms that develop compliance systems that are faster, more efficient and can help cut compliance costs significantly in a manner acceptable to the regulatory agencies will find a large and fast growing market for their services.