Pivoting to Offense to Endure the Covid-19 Economy

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Banks must plan for the economic conditions looming on the other side of Covid-19.

Banks must simultaneously figure out how to weather the public health crisis and serve their clients in almost entirely remote environments while preserving their financial health for months of economic uncertainty. The depth and longevity of this crisis requires banks to strategically reassess the immediate negative impacts, project probabilities of further disruption and re-engineer their delivery models.

We believe that the banks that take bold and decisive action around these key issues will emerge from this period with more-durable relationships, greater agility and resilience, steeper market growth and better profitability compared to their peers. Banks should prioritize a set of five stabilizing actions that will set the stage for resilience in any potential downturn. 

Help Customers Confront the Crisis
Adversity contains implicit opportunity for customer outreach. Banks should contact customers to communicate that their bank is open and available for support. They should devise strategic outreach programs to solidify customer confidence and build long-term relationships.

Banks should then immediately focus on helping customers find ways to ease cash flow constraints and shortfalls in working capital and liquidity reserves. They should consider relief programs and creative, beneficial adjustments to loan structures such as permitting deferred payments, interest-only payments, re-amortizing payments or waiving select fees. Aligning their clients’ new needs with bank solutions and products will establish a foundation for post-crisis revenue growth.

Surgical Expense Reductions
Often, the immediate reaction during economic turmoil is to cut staff without strategic approach. While this can lower costs by the next financial period, this approach fails to strategically position the bank for post-downturn recovery and risks misaligned skill-sets or understaffing.

We recommend that banks understand which levers can be strategically pulled to quickly reduce costs. These levers range from identifying and evaluating paper-based processes, robotic process automation and aligning operations and personnel to the revised sales volume estimates. There are significant cost savings available even in credit risk management — simply by optimizing credit processes and better leveraging data.

Credit Risk Management Tailored to the Crisis
Banks had no visibility into the recession, and must assess not only the immediate impact on borrower financial and implied repayment performances but also the delayed impact on various segments of the economy. Ensure your risk management strategy reflects the new credit reality:

  • Consider proactively managing the portfolio renewal cycle by implementing mass short-term extensions on lines of credit, re-evaluating credit policy exception limits and increasing monitoring through frequently conversations with borrowers.
  • Leverage data to scale the identification of emerging portfolio risk and related triggers.
  • Consider creating a Covid-19 financial health assessment to facilitate financial relief and to identify potential credit downgrades.
  • Assess industry-based impacts on your portfolio to predict deteriorating credits in order to right-size loan loss reserves. 
  • Increase the frequency and detail of credit monitoring procedures for sectors that have been immediately impacted and those that will be impacted in the near term.

Align Resources with Client Need
Changes in spending will impact the creditworthiness of many loan applicants, so banks must take a hard look at realistic expectations for new business goals in 2020 and 2021. Realign banker-relationship manager priorities and shift from new business development with prospective customers to selling deeper into the existing portfolio, where possible. Client engagement will enable banks to manage risk while providing the client with much-needed attention, solutions and assistance. 

It will also be critical to scale up certain operational functions quickly to meet shifting client demand. Realigning  branch staff to handle call center volume and line resources to assist with spiking credit action volumes allow you to redeploy and scale your workforce to the new reality.

Create a Balanced Remote Workplace Strategy
Banks must leverage all available tools not just to maintain, but further, customer relationships and generate new business activity where possible. Empower customers to make deposits digitally by providing remote deposit capture hardware and services and consider waiving a portion of RDC equipment or service fees for a trial period.

Proactively run and distribute bank statement reports through digitally secure methods, rather than requiring customers to create and distribute these reports. Collaborate with bank customers to send check payable files to the bank for check printing and distribution.

We believe a bank’s actions in the next 90 days are vital to the survival, sustainability and long-term positioning for regrowth. Responding to customers with needed outreach sets the stage for new levels of customer loyalty. Shifting the bank’s focus inward toward operations with a keen focus on streamlining processes, proactively changing procedures and aligning the right people to the right tasks will ultimately lead to both a sustained and improved financial ecosystem.

Pandemic Challenges, Strengthens Bank’s Deal Integration

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One bank found that the Covid-19 pandemic actually accelerated its deal integration, creating a stronger pro-forma institution to serve clients after overcoming a number of unexpected hurdles.

The coronavirus crisis has thrown a wrench in bank mergers and acquisitions, challenging everything from due diligence to pricing to regulatory and shareholder approvals. Only two bank deals were announced in May, according to S&P Global Market Intelligence; potential buyers and sellers seem to be focusing on assisting customers while they wait for a normalized environment. But Sandy Spring Bancorp found itself with no choice but to adapt its deal integration with Rockville, Maryland-based Revere Bank, even as both banks shifted to a remote work environment.

“For us, it’s very important to understand that not just the successful integration, but a successful acquisition is centered around finding the right partner to begin with,” says Sandy Spring President and CEO Daniel Schrider. “And it’s really important … to find an organization that either complements what we do or provides access to a different market that maybe we’re not in, but has a shared vision around client relationships.”

The Revere team was well-known to Sandy Spring, with executives serving on their state bank association as well as competing against each other for local deals. After talking for about 18 months, they announced their merger agreement in September 2019; the deal pushed the Olney, Maryland-based bank above $10 billion in assets.

For months, deal integration proceeded as expected. The banks kicked off internal communication campaigns to keep both groups informed of the timeline, process and upcoming changes, and increase comradery before merger close. They formed 20 cross-functional teams of employees from both companies that tackled specific integration-related tasks or objectives, which met through mid-February.

“Both companies had tremendous first quarters. We were very excited about bringing the two organizations in a new structure and pulling the trigger on a number of things, based upon our ability to be together,” he says. “Then obviously, things came to a screeching halt.”

Once the pandemic closed physical offices, Sandy Spring used video and electronic communication to continue integration work. The pro-forma executive team created welcome videos featuring Schrider, along with digital and virtual orientations, instead of the usual face-to-face interactions.

But the integration encountered yet another unexpected challenge: the Paycheck Protection Program. The Small Business Administration loan program began accepting applications on April 3, two days after the Revere acquisition closed.

“All of a sudden, two companies were faced with trying to solve the problems that many of their clients are having,” Schrider says. “That actually accelerated our integration.”

The newly combined teams, which pride themselves on being relationship focused, worked together to fulfill the unsolicited loan demand. They hosted daily PPP calls and involved more than 200 employees to process applications from customers at both banks. The undertaking combatted any inertia they may have felt about actually combining and functioning as one company.

“In a strange way, we’re probably in a better place today than we would have been, absent a pandemic, from the standpoint of being together,” he says. “Even though we’re not physically together.”

Sandy Spring believes picking a bank partner with similar values and staying focused on its strategy helped the pro-forma institution navigate deal-specific challenges. For instance, the all-stock deal for Revere originally carried a price tag of $460.7 million when it was announced in September; at close, it was valued at $287 million based on Sandy Spring’s quarter-end stock price, according to S&P Global Market Intelligence. Schrider says potential buyers and sellers should avoid fixating on absolute deal price, and instead consider the relative value and potential upside of the combined entity’s shares.

So far, the only integration activities that the pandemic has paused are reorganization efforts the bank believes are best done in person, including the planned appointment of Revere co-CEO Ken Cook as executive vice president. The systems conversion and branch consolidation are still on track for the third quarter. Until then, the pro-forma institution will continue to integrate while serving clients during the pandemic.

“It’s been a wild ride but a good one,” Schrider says.

Embracing a Challenging Environment to Evolve

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New York University economist Paul Romer once said, “A crisis is a terrible thing to waste.”

With a nod to Dr. Romer, we believe banks have an extraordinary opportunity to embrace the challenging environment created by the Covid-19 pandemic to enhance critical housekeeping matters. Here are five areas where banks may find opportunities to declutter or reengineer policies, procedures and best practices.

Culture
One of the most obvious opportunities for banks is to focus on culture. Employees working from home has eliminated the ability to have typical office parties, barbeques and other events to build comradery. Remote and semi-remote working environments are challenging employees in many difficult ways. Fortunately, banks are finding simple, yet creative, ways to stay in contact with their employees and build culture through additional correspondence and feedback — electronic happy hours, car parades, and socially distant visits, for example. Creatively maintaining high engagement in challenging times will serve to improve communication and culture over the long term. As management consultant Peter Drucker once said, “Culture eats strategy for breakfast.”

Cybersecurity
Cybersecurity risk continues to be top of mind for bankers and regulators given the remote work brought on by Covid. Certainly, most banks’ cybersecurity risk management planning did not contemplate the immediate scale of remote work, but the extreme experience is an opportunity to drill down on underlying policies and procedures. Banking agencies have provided the general blueprint on sound risk management for cybersecurity.

This heightened risk environment provides executives with a perfect opportunity to note where their vulnerabilities may exist or be discovered, where cyberattacks focus and what works—or doesn’t —for your bank. Use the guidance provided to assess your bank’s response and resilience capabilities. Consider the overall map and configuration of your cyber architecture. Consider authentication requirements and permissions to protect against unauthorized access. Take the time to work with information technology experts to clean up access controls and response plans. This is an active situation that provides bankers the unique opportunity to learn and adapt in real time.

Compliance
Banks also face enhanced compliance originating from federal programs aimed at keeping businesses afloat. A worthy endeavor to be sure, but the rollout of some federal programs such as the Small Business Administration’s Paycheck Protection Program has far outpaced the guidance for banks tasked with implementation. The trickle of (often inconsistent) guidance on the documentation, eligibility and certification adds compliance challenges in reporting under the Bank Secrecy Act, fair lending under the Equal Credit Opportunity Act and unfair or deceptive acts and practices under the Federal Trade Commission Act, for example.

Compliance teams have an opportunity to shine at something they are already extraordinarily good at: documentation. They should document the processes and practices they deploy to demonstrate compliance, despite the uncertainty and pace at which they are expected to operate. This documentation can support real-time decision-making that may come up with regulators in the future, and can serve as a basis for improvement on future best practices and training. Compliance teams will discover new questions to ask, novel scenarios to address and gaps to fill.

Operational Planning
The best time to consider the impacts of Covid on your bank’s operations is while events and memories are fresh. Banks all over the country are experiencing what a handful of institutions may go through in the wake of a natural disaster: devastation, uncertainty and a need for banking support. This is the time to review your bank’s disaster recovery and business continuity plans, specifically including pandemic planning, to assess the plans against reality.  

To help, the Federal Financial Institutions Examination Council released an updated statement on pandemic planning suggesting actions that banks can take to potentially minimize a pandemic’s adverse effects. This is an chance to improve business continuity planning for similar future events, understanding that they may not be as deep or prolonged as the coronavirus. Exercising the plans in real time, compared to a scheduled test, can reveal helpful improvements that will only strengthen the bank.

Customer Experience
Coping with remote work and providing banking services outside of a branch provides the opportunity for banks to consider strategies around technology and financial technology partnerships. Customers have been rerouted to electronic avenues, and many seem to have embraced technology to deposit checks, access accounts online and transact business.

This evolution offers banks the opportunity to adapt and recognize the use of financial technologies. Many customers will understandably return to branches to conduct some of their business when they reopen, but may require them less. Banks may want to consider how they can satisfy future customer demand and improve the customer experience more broadly. These are just five areas where we see opportunities for banks of all levels and complexity to enhance their policies, procedures and best practices as they prepare to move forward.

Compensating Employees in a Crisis

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It’s an old conflict with new, pandemic-created urgency: How to compensate employees during a crisis.

Compensation is one of the biggest variable expenses a bank has, and many incentive compensation plans may have components or goals that are no longer realistic at this state of the business cycle. At the same time, bank employees have served as first-responders to the economic crisis created by the coronavirus pandemic, putting in long hours to modify or originate loans. Boards are figuring out how to reward employees for these efforts while keeping a lid on expenses overall, balancing the bank’s growth and safety against the short-term operating environment.

The Paycheck Protection Program from the Small Business Administration creates an interesting compensation opportunity for banks, says Flynt Gallagher, president of Compensation Advisors. Many banks had employees who pulled all-nighters while working remotely to fulfill demand for these unsolicited loans. Some institutions may choose to exercise discretion by issuing spot awards, which reward employees for a specific behavior over a limited period of time, to bankers who worked overtime to help customers. Gallagher believes these may be larger than a typical award, citing one client that is setting aside $100,000 of PPP profits to distribute to employees who pitched in.

The pandemic created challenges for Civista Bancshares’ commercial lenders and their incentive compensation program, though it presented opportunities as well. Processing PPP applications took time that the Sandusky, Ohio-based bank’s commercial team may have spent monitoring and administrating their existing portfolios or prospecting for new customers. But after the $2.6 billion bank satiated demand from current customers, it opened its doors for new customers, says Civista Bancshares CEO Dennis Shaffer. Some new customers transferred their accounts and service needs as a result, which counts toward deposit goals that retail bank staff have.

Banks with plans featuring objectives or goals that may no longer be reasonable or prudent may be able to exercise discretion under their plans’ “extraordinary events” clause, Gallagher says. The clause applies to events that materially affect profitability, like selling a branch or implementing a new operating system. Banks electing that approach, he says, will also need to quantify the impact that Covid-19 has had on their performance.

At Civista, goals tend to be set in the first quarter, and Shaffer says that changing course on an incentive plan midstream could compromise its integrity. Gallagher adds that public companies like Civista may face scrutiny from proxy advisory firms if they make changes to a current plan or exercise too much description.

But boards have some options as they evaluate their current incentive compensation plans. Some may break their compensation plans into shorter plan periods. Gallagher predicts that banks may decide to shift or roll up individual goals into team or department objectives to reward the broad efforts of groups that may have gone beyond the four corners of their job descriptions.

“I don’t think you’re going to see any general methodology adopted. It’s going to be all over the board, based on the institution,” he says.

Walden Savings Bank is comparing its compensation plan, which uses a scorecard of 12 metrics evaluated monthly, to its expected financial performance, says Stephen Burger, who has chaired the Montgomery, New York-based bank’s compensation committee for 16 years. He says there is already “no way” to achieve at least four of those metrics, reducing the incentive accrual by 25%. The board and CEO of the $603 million bank also decided to cut their pay, but so far no employees have been laid off or furloughed.

“The scorecard is just a guideline,” he says. “We do have latitude to look at other opportunities and reward or cut in certain areas.”

The bank is already trying to keep a tight lid on expenses. They stayed local for their strategic planning weekend instead of going out of town, implemented a hiring freeze, paused a branch transformation project and are mulling alternations to certain benefits or staff reductions.

“We will find a way to reward our employees,” Burger says. “At the same time, if earnings aren’t there, we’ll also do a very effective job of making sure that they recognize that it’s a unique type of year.”

Gallagher cautions against banks making short-term cuts in employment or not rewarding producers. Good employees need to be retained in anticipation of better operating periods. And some banks may actually look to hire new employees right now, given that mass unemployment has flooded the marketplace with talent.

“One banker [I spoke to] said he doesn’t think he is overstaffed, he just doesn’t think he has people in the right places,” Gallagher says. “Companies that are forward-thinking will go hard on people while they’re available, even if they don’t need them. You’ll figure out how to use them to the best of their ability later. Get the talent right now.”

Opportunity Emerges from Coronavirus Crisis

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The banking industry has experienced shocks and recessions before, but this one is different.

Never has the economy been shut so quickly, has unemployment risen so fast or the recovery been so uncertain. The individual health risks that consumers are willing to take to create demand for goods and services will drive the recovery. As we weigh personal health and economic health, banking communities and their customers hang in the balance.

Ongoing economic distress will vary by market but the impact will be felt nationwide. Credit quality will vary by industry; certain industries will recover more quickly, while others like hotels, restaurants, airlines and anything involving the gathering of large crowds will likely need the release of a coronavirus vaccine to fully recover. As more employees work from home, commercial office property may never be the same. While this pandemic is different from other crises, some principles from prior experience are worth consideration as bankers manage through this environment.

Balance sheet over income statement. In a crisis, returns, margins and operating efficiency — which often indicate performance and compensation in a strong economy — should take a back seat to balance sheet strength and stability. A strong allowance, good credit quality, ample liquidity and prudent asset-liability management must take priority.

Quality over quantity. Growth can wait until the storm has passed. Focus on the quality of new business. In a flat yield curve and shrinking margin environment, resist the thinking that more volume can compensate for tighter spread. Great loans to great customers are being made at lower and lower rates; if the pie’s not growing, banks will need to steal business from each other via price in a race to the bottom. Value strong relationships and ask for pricing that compensates for risk. Resist marginal business on suspect terms and keep dry powder for core investments in the community.

Capital is king. It’s a simple concept, but important in a crisis. Allocate capital to the most productive assets, hold more capital rather than less and build capital early. A mistake banks made in prior crises was underestimating their capital need and waiting too long to build or raise capital. Repurchasing shares seems tempting at current valuations, but the capital may be more valuable internally. Some banks may consider cutting or suspend common stock dividends, but are fearful of condemnation in the market. The cost of carrying too much capital right now is modest compared to the cost of not having enough — for credit losses but equally for growth opportunity during the recovery.

The market here serves as the eye of the storm. The front edge of the storm saw the closure of the economy, concern for family, friends and staff and community outreach with the Paycheck Protection Program (PPP), not once but twice. Now settles in the calm. Banks have deployed capital, the infection rate is slowing and small businesses are trying to open up. But don’t mistake this period for the storm being over. There is a back edge of the storm that may occur in the fall: the end of enhanced unemployment insurance benefits, the exhaustion (and hopefully forgiveness) of PPP funds and the expiration of forbearance. Industries that require a strong summer travel and vacation season will either recover or struggle further. And any new government stimulus will prolong the inevitable as a bandage on a larger wound. Banks may see credit losses that rival the highest levels recorded during the Great Recession. Unemployment that hits Great Depression-era levels will take years to fully recover.

But from crisis comes opportunity. Anecdotal evidence suggests that business may shift back to community banks. When markets are strong, pricing power, broad distribution and leading edge technology attract consumers to larger institutions. In periods of distress, however, customers are reminded of the strength of human relationships. Some small businesses found it difficult to access the PPP because they were a number in a queue at a larger bank or were unbanked without a relationship at all. Consumers that may have found it easy to originate their mortgage online had difficulty figuring out who was looking out for them when they couldn’t make their payment. In contrast, those that had a banking relationship and someone specific to call for help generally had a positive experience.

This devastating crisis will be a defining moment for community banks, as businesses and consumers have new appreciation for the value of the personal banking relationship. Having the strength, capital, brand and momentum to take advantage of the opportunity will depend on the prudence and risk management that these same banks navigate the pandemic-driven downturn today.

Pandemic Poses Path to Boost Employee Engagement

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The coronavirus crisis has temporarily boosted employee engagement, giving companies and managers a chance to implement changes that could make those increases permanent.

Employee engagement has increased since the start of the pandemic, according to the analytics and advisory firm Gallup, even as negative emotions also have risen. One potential reason could be stronger and more-empathetic connections between managers and employees. Companies have an opportunity to continue making changes that could result in long-term employee engagement increases, such as shifting managers from bosses to coaches.

Stay-at-home orders caused many banks to move to remote work environments for their employees, which altered the way managers relate with and oversee their reports, says Andrew Robertson, a managing consultant in retail banking and financial services at Gallup. Those shifts occurred as the firm began to see lower reported levels of well-being and higher levels of emotions like stress and anxiety in its surveys.

“Work has really shifted, so the dynamic of … command-and-control literally can’t work right now,” Robertson says. “A boss would be over-the-shoulder task managing or micromanaging. Employees are acutely aware that is no longer applicable.”

The firm has also seen an increase in the percentage of employees who wish to continue working from home in some capacity, as well as an openness from managers and executives to allow that. But adding a work-from-home arrangement can complicate management once employees go off-site. In response, some managers seem to be electing a more empathetic, personal and coach-like approach when it comes to connecting and managing remote workers.

Managers are key to a team’s success, especially in moments of pressure and crisis. Their ability to connect and lead their reports has huge implications for banks seeking top performance. But they can also be a major liability when it comes to preserving, enriching and engaging a bank’s workforce.

Gallup’s research indicates that 70% of a team’s engagement can be attributed to their manager. Bad managers are costly: The firm found that one out of every two people leave a job as a direct response to a manager.

“If you want to boil employee engagement down, it’s essentially the manager,” says Paul Berg, financial services thought leader at Gallup. “Most people are having a mediocre-to-poor experience with their manager.”

But Gallup has found that employee engagement has moved higher during the pandemic, from 34% to 38% — its highest level since it began tracking in 2000. That’s a critical opportunity for banks. Higher employee engagement can translate into higher customer advocacy, productivity and profitability, and lower turnover, absenteeism, safety and theft.

Some of the reasons behind the move include that companies quickly rolled out definitive and detailed plans that kept employees informed of how their jobs would need to change. Managers were empowered to support employees as they moved to remote work, and employees may be especially grateful to have a job right now.

But another reason may be that employees and their managers may be having more meaningful and more frequent conversations — a dynamic that can drive engagement. Managers are figuring out ways to keep their teams connected to their work and to each other, acknowledging their colleagues’ stress and trying to keep morale high.

This creates a natural opening for banks to continue cultivating this increased engagement by training managers to become coaches and not bosses. But not just any type of coach.

Berg says companies that adopt a coaching mentality for managers tend to focus on specific objectives, which winds up being “completely ineffective.” The secret to good coaching is focusing on an employee’s strengths. Just as the best coaches help their players identify and leverage their strengths as part of a team, the best managers “focus on what’s right with a person,” Berg says.

Shifting to a coach mindset may come more naturally for some managers right now, given that remote work has changed the types of conversations they have with employees. Robertson says effective managers during the pandemic are the ones who get to know their employees and their situations in order to help them accomplish what they need to, and can have more-meaningful conversation about their work as a result. He believes the role of managers as a glue connecting workers to their banks has become more, not less, important during the pandemic.

“There have been moments [during the pandemic] where we’ve really understood that these human connections are important at work, and that we’re actually able to accomplish so much together when we make those thoughtful human connections,” he says.

Starting from Scratch: Reassessing Business Loans

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Deposits are up, investors have shown signs of optimism and parts of the country are slowly reopening. But amid these positive signals, banks are only just beginning to see the signs of future trouble that Covid-19 may cause for their loans. Prudent banks are working to plan for the long-tail impacts the crisis will have.

One of the banks gazing into its crystal ball is PNC Financial Services Group. The Pittsburgh-based bank made headlines when it sold its 22% stake in BlackRock last month. Chairman and CEO William Demchack, explained in an early June company presentation that the institution was selling while it could, and preparing for the unknown effects that Covid will likely have on the economy.

“[B]ehind the scenes, what hasn’t played out, and will take some period of time to play out, is the deterioration we’ve seen in small business, commercial and real estate,” he said. Once the stimulus payments and deferrals run out,  “the pain shows up.”

That pain may be especially acute for smaller banks which, Demchack pointed out, tend to carry higher concentrations and exposures to small business and commercial real estate  than their larger counterparts. “[I]t’s the smaller end of our economy that’s really getting crushed here.”

With losses looming on the horizon, some banks are leveraging data and analytics solutions to essentially re-underwrite their entire loan portfolios in light of Covid-19.

Just after announcing the BlackRock sale, PNC was again in the news for a brand new partnership it struck with OakNorth, which licenses an AI-based underwriting platform it incubated within the company’s UK-chartered bank. OakNorth recently announced some of its first partnerships with U.S. banks, including Customers Bancorp, a $12 billion asset institution based in Wyomissing, Pennsylvania.

Customers’ Vice Chairman and Chief Operating Officer, Sam Sidhu, is paying close attention to the unknown outcomes of Covid and the effects the economic crisis will have on the bank’s “core” mid-sized commercial loans.

Sidhu explains that in the first 30 to 60 days of the crisis, banks encountered the known, obvious risks that social distancing and stay-at-home orders posed to businesses like restaurants, hotels and hair salons. “But where banks can become a little complacent is the areas that are unknown risks,” says Sidhu. That’s where it’s important to practice discipline in stress-testing the portfolio.

But how can a bank re-evaluate its loans at scale, in a way that doesn’t throw the baby out with the bathwater?

A generalist might point out that restaurants won’t perform well in this environment. But what about a pizza franchise that earned significant portions of its revenue from deliveries pre-Covid? These types of restaurants may be unaffected by the health crisis; in fact, they may be booming because of it.

To complicate the calculation, it’s not just immediate issues like an absence of demand that lenders need to consider. They also need to understand a business’ ability to restock and recover. To do that effectively, context is key. That’s what the technology that PNC and Customers Bank have licensed from OakNorth is designed to provide.

The OakNorth platform categorizes businesses into 1,600 sub-sectors so that they can be segmented into highly specific groupings. Then, the platform can be used to apply any number of OakNorth’s more than 150 stress testing models, including a new Covid Vulnerability Rating framework, to assess business borrowers.

Customers Bank is working with OakNorth on portfolio management and underwriting. Sidhu says a benefit of using the technology is that it’s “allowing a community bank to be able to have investment banking-type access to data” — an important factor in a world where old models have been rendered irrelevant.

“Everything that you thought when you underwrote a loan is no longer true,” says OakNorth Chief Information Officer Sean Hunter. Banks typically use previous years’ financial statements to underwrite a loan, but 2019 financials cannot predict how a business will perform in the 2020 world. Hunter says “you need to underwrite your whole book again, from scratch.”

OakNorth has been offering banks the opportunity to test drive its Covid Vulnerability Rating, running a forward-looking analysis on bank portfolios using 15 to 20 anonymized data points to identify at-risk loans.

No one knows what risks banks will be battling in the coming months. “Hopefully, these unknown risks will never become an issue,” says Sidhu, “but smart banks can’t really rely on hope. [They] need to be focused on trying to proactively address those risks, and get ahead of problems.”

Risk, Business Continuity Planning: Trends and Lessons from Covid-19

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The Covid-19 pandemic has introduced unprecedented strains to the economy, enhancing concerns about credit risk and pressuring lenders’ ability to serve their borrowers.

Cybersecurity and other risk environments have also evolved, following government-mandated work from home models. These shifts are prompting bank leaders to evaluate their business continuity plans and pandemic planning initiatives to ensure they’re putting safety and efficiency first.

Bank Director’s 2020 Risk Survey, sponsored by Moss Adams, was conducted in January before the U.S. economy felt the full effect of the coronavirus. Yet, insights derived from this annual survey of bank executives and board members help paint a picture of how the industry will move forward in a challenging operating environment.

Credit Risk
Most community banks have issued loans through the Paycheck Protection Program (PPP), the Small Business Administration’s loan created under the Coronavirus Aid, Relief and Economic Security (CARES) Act passed in late March. These loans, which may be forgiven if borrowers meet specified conditions, allowed small businesses to retain staff, pay rent and cover identified operating expenses.

However, it’s likely that businesses will seek additional credit sources as the economy restarts. The lapse in business revenue generation will pose significant underwriting challenges for banks.

More than half of respondents in the 2020 Risk Survey revealed enhanced concerns around credit risk over the past year, while 67% believed that competing banks and credit unions had eased underwriting standards.

While there’s no way to determine what the future holds, near-term lending decisions will likely occur amid an uncertain economic recovery. There are some important questions institutions should consider when determining their lending approach:

  • How will our organization evaluate lending to businesses that have been closed due to the coronavirus?
  • Should a pandemic-related operational gap be treated as an anomaly, or should lenders consider this as they underwrite commercial loans?
  • What other factors should be considered in the current environment?
  • How much bank capital are we willing to put at risk?

Cybersecurity
Directors and executives who responded to the survey consistently indicate that cybersecurity is a key risk concern. In this year’s survey, 77% revealed their bank had placed significant emphasis on increasing cybersecurity and data privacy in the wake of cyberattacks targeting financial institutions, such as Capital One Financial Corp.

With more bank staff working remotely, cyber risks are even greater now. Employees are also emotionally taxed with concerns about their health, family and jobs, increasing the risk for errors and oversights. Unfortunately, the COVID-19 pandemic presents cybercriminals with a ripe opportunity to prey on individuals.

Business Continuity
In the survey, respondents whose bank had weathered a natural disaster within the last two years were asked if they were satisfied with their institution’s business continuity plan. The majority, or 79%, indicated they were.

However, the Covid-19 pandemic isn’t a typical natural disaster. Although buildings haven’t been destroyed, companies are still experiencing significant disruption to their normal operations — if they’re able to operate at all.

These circumstances, coupled with expanding technology and banks operations increasingly moving to the cloud, will likely lead to further changes in business continuity planning.

Remain Flexible
In an interagency statement released a week before the World Health Organization declared that the Covid-19 outbreak a pandemic, federal regulators reminded depository institutions of their duty to “periodically review related risk management plans, including continuity plans, to ensure their ability to continue to deliver their products and services in a wide range of scenarios and with minimal disruption.”

The Federal Financial Institutions Examination Council also updated its pandemic guidance, noting the need for a preventative program and documented strategy to continue critical operations throughout a pandemic.

Since that time, banks have encouraged customers to broadly adopt digital platforms and, when necessary, serve customers in person through drive-through lines or by appointment to reduce face-to-face contact. Bank employees wear masks and gloves, branches are cleaned frequently and, where possible, staff work remotely.

Gain Insights
The pandemic is a real-world tabletop exercise that can provide important takeaways about the effectiveness of an organization’s business continuity plan. It’s important for organizations to take advantage of this opportunity.

For example, there could be another wave of Covid-19 later this year; alternately, it could be years before we see an event similar to what we’re experiencing. Either way, your bank must to consider the potential consequences of each outcome and have a plan ready. Reviewing your organization’s business continuity plans and initiatives can help reveal opportunities to move forward with confidence, despite challenging operating environments.

Adapting Bank Supervision to the Covid-19 Reality

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Can a bank socially distance itself from its primary federal regulator?

In the midst of the Covid-19 pandemic, the answer is apparently yes.

The Office of the Comptroller of the Currency, which oversees nationally chartered banks and thrifts, has been impacted by the virus’ shutdown in much the same way as the institutions it oversees.

In an interview with Bank Director, Acting Comptroller of the Currency Brian Brooks — who replaced former Comptroller Joseph Otting after his resignation on May 29 — says the pandemic has forced the agency to adapt its preferred method of operation to the restrictions of social distancing.

“One thing that I worry about from a supervision perspective is, historically, bank examiners go on-site,” Brooks says. “Not because it’s convenient, but because being able to be in a room with bankers and sit face to face with people … is a critical tool in identifying fraud and identifying trends that might not make it onto a management report, or might not be raised in a formal presentation. And the longer banks are in a work-from-home environment, the harder it is for us to do that human aspect of bank supervision.”

Brooks says while there are legitimate health reasons why much of the banking industry has operated with a distributed workforce for the last several months, he’s anxious to reintroduce the element of personal contact into bank supervision. “I know that may not happen next month or even this quarter, but we need to start charting that course back, because this method of supervision can’t go on forever,” he says.

The OCC is reopening its facilities on June 21 and is encouraging people who do not have underlying health conditions and would feel comfortable doing so to return to their offices. “That’s our way of showing leadership to the industry of how one can start charting this course back to normalcy,” Brooks explains. “But having said that, we’ve moved to significantly enhanced cleaning schedules. We’re obviously providing face masks and gloves to people who are in mail-handling or public facing positions. We’re changing seating arrangements to maximize the availability of social distancing. And of course, we’re continuing to allow anyone who wants to, to work remotely while making the office … more normalized for everybody else.”

Brooks believes that recent data on the virus suggests that the health risk for most people is manageable. “What the data seem to be showing is that hospitalization rates and fatality rates for people of working age, who don’t have particular risk conditions, seem to be within historic norms,” he says. “Which is not to say that this is not a dangerous disease, but it does appear to be that … people who are under a certain age and who don’t have certain conditions are not at special risk relative to other types of viruses that we’ve seen before.”

And when OCC examiners do return to on-site visits to their banks, they will follow whatever safety protocols the bank has in place.

The Covid-19 pandemic has dealt a crushing blow to the U.S. economy — which entered a recession in February — and the OCC wants national banks to take a hard look at their asset quality. It’s not an easy assessment to make. Banks have granted repayment deferrals of 90 days or greater to many of their borrowers at the same time as the federal government suspended troubled debt restructuring guidance and pumped money into the economy through the Paycheck Protection Program. A clear asset risk profile has yet to emerge for many institutions.

“Some of the traditional metrics that we’ve used to determine asset quality … could be masked by a lot of the relief efforts,” says Maryann Kennedy, senior deputy comptroller for large-bank supervision at the OCC. “Many of our institutions are going back and retooling many of their stress testing models in response to the breadth, depth and velocity of the number of programs that they’re instituting there.” 

Just because OCC examiners don’t have personal contact with their banks doesn’t mean they haven’t been talking to them through the pandemic. Some of those conversations are an effort to triage which banks may need the greatest attention from regulators.

“There is a real time risk-based assessment of what’s happening with our national banks and federal savings associations, so we can try to understand how we move forward and where we focus our attention. [It’s] is very challenging, similar to the challenge [banks have] trying to understand their asset quality and the situation with their loan portfolios,” says Kennedy.

The OCC is essentially trying to assess the pandemic’s economic impact on national banks and thrifts while those institutions make their own credit risk assessments.

“A real-time conversation that’s going on right now, particularly in that in our larger banks, is ‘What is your stress forecasting looking like for provision expense in the second quarter, as well as what could be those potential impacts to earnings, particularly as it relates to any earnings expectations that might be out there?’” Kennedy says. “Those are challenging conversations going on right now … as our bank managements sort of work through the struggle [with] some of those specifics. It’s not a real predictive economy right now.”

Avoiding Pitfalls of Covid-19 Modifications for Swapped Loans

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Many banks are modifying commercial loans as they and their commercial borrowers grapple with the economic fallout of the Covid-19 pandemic.

Payment relief could include incorporating interest-only periods, principal and interest payment deferrals, and/or loan and swap maturity/amortization extensions. While modifications can provide borrowers with much-needed financial flexibility, they also risk creating unintended accounting, legal and economic consequences.

Don’t forget the swaps
Lenders need to determine whether there is a swap associated with loans when contemplating a modification. Prior to modification, lenders should coordinate efforts with their Treasury or swap desk to address these swapped loans, and ensure that loan and swap documentation are consistent regarding the terms of the modification.

Develop realistic repayment plans
Lenders need to consider how deferred obligations will be repaid when creating a temporary payment deferral plan. The lender may need to offer an interest-only period so a borrower can repay the deferred interest before principal amortization resumes, or deferred interest payments could be added to the principal balance of the loan. Lenders also should consider whether the proposed modification will be sufficient, given the severity of the borrower’s challenges. The costs associated with amending a swapped loan may convince a lender to offer a more substantive longer-term deferral, rather than repeatedly kicking the can down the road with a series of short-term fixes.

Determine whether swap amendment is necessary
The modified loan terms may necessitate an amendment of the associated swap. It may be possible to leave the swap in place without amendment if you are only adding an interest-only period, as long as the borrower is comfortable with their loan being slightly underhedged. But if you are contemplating a full payment deferral, it typically will be desirable to replace the existing swap transaction with a new forward-starting transaction commencing when the borrower is expected to resume making principal and interest payments.

Understand bank or borrower hedge accounting impact of loan modifications
Lenders often hedge the value of their fixed-rate loans or other assets through formalized hedging programs. A popular strategy has been to designate these swaps as fair value hedges using the shortcut method.

This method requires that the economic terms of the asset, such as amortization of principal and timing of interest payments, precisely match those of the hedge. A mismatch due to a loan payment deferral would cause the lender to lose the hedge’s shortcut status. The lender’s hedging program potentially could maintain hedge accounting treatment using the more cumbersome long-haul method if that mismatch scenario was contemplated in the hedge inception documentation.

Borrowers who have taken variable rate loans may have entered into swaps to gain synthetic rate protection. Restructuring  a hedge to defer payments alongside the loan’s deferred payments could jeopardize an accounting-sensitive borrower’s hedge accounting treatment. It is possible for the borrower to reapply hedge accounting under the amended terms, although the restart has additional considerations compared to a new un-amended hedge. If hedge accounting is not restarted, the derivative’s valuation changes thereafter would create earnings volatility per accounting rules. While borrowers should be responsible for their own accounting, lenders’ awareness of these potential issues will only help client relationships in these uncertain times.

Take stock of counterparty derivative exposure
As interest rates plunge to record lows, many lenders have seen their counterparty exposure climb well above initially-approved limits. Hedge modifications may further exacerbate this situation by increasing or extending counterparty credit exposure. We recommend that lenders work with their credit teams to reassess their counterparty exposure and update limits.

Accounting guidance also requires the evaluation of credit valuation adjustments to customer swap portfolios. Lenders should ensure that their assumptions about the creditworthiness of their counterparties reflect current market conditions. These adjustments could also have a material impact on swap valuations.

Hope for the best, plan for the worst
Hopefully, loan modifications will give borrowers the opportunity to regain their financial footing. However, some may face continued financial challenges after the crisis. Lenders should use the modification process to prepare for potential defaults. Loan deferments or modifications should provide for the retention of the lender’s rights to declare a default under the loan documents and any swap agreements. The lender, through consultation with its credit team, may want to take this opportunity to bolster its position through the inclusion of additional guarantors or other credit enhancements.

The economic fallout from the global pandemic continues to have a profound impact upon borrowers and lenders alike. Adopting a thoughtful approach to loan modifications, especially when the financing structure includes a swap or other hedge, may make the process a little less disruptive for all.