Coronavirus Sparks CECL Uncertainty

Even before COVID-19, the first quarter of 2020 was shaping up to be an uncertain one for large public banks. Now, it could be a disaster.

There is broad concern that the current expected credit loss standard, which has been effective since the start of 2020 for big banks, will aggravate an already bad situation by discouraging lending and loan modification efforts just when the new coronavirus is wreaking havoc on the economy. Congress is poised to offer banks temporary relief from the standard as a part of its broader relief act.

Section 4014 of the Coronavirus Aid, Relief, and Economic Security Act, or CARES Act, would give insured depository institutions and bank holding companies the option of temporarily delaying CECL implementation until Dec. 31, 2020, or “the date on which the public emergency declaration related to coronavirus is terminated.”

Congress’ bill comes as the Financial Accounting Standards Board has already rebuffed the efforts of one regulator to delay the standard.

On March 19, Federal Deposit Insurance Corp. Chairman Jelena McWilliams sent a letter to the board seeking, among other requests, a postponement of CECL implementation for banks currently subject to the standard and a moratorium for banks with the 2023 effective date.

McWilliams wrote that a moratorium would “allow these financial institutions to focus on immediate business challenges relating to the impacts of the current pandemic and its effect on the financial system.”

FASB declined to act on both proposals. “We’re continuing to work with financial institutions to understand their specific challenges in implementing the CECL standard,” wrote spokesperson Christine Klimek in an email to me later that day.

It’s not an overstatement to say that the standard’s reporting effective date could not come at a worse time for banks — or that a potential delay necessitating a switch back to the incurred loss model may be a major undertaking for banks scheduled to report results in the next several weeks.

“Banks are being tasked with something pretty complex in a very short timeframe. And of course, this is the first period that they’re including these numbers and a lot of the processes are brand new,” says Reza Van Roosmalen, a principal at KPMG who leads the firm’s efforts for financial instruments accounting change. “They’ve practiced with parallel runs. But you’re immediately going to the finals without having had any other games. This is the hardest situation you could be in.”

CECL has been in effect since the start of the new year for large banks and its impact was finally expected to show up in first-quarter results. But the pandemic and related economic crisis creates major implications for banks’ allowances and could potentially influence their lending behavior.

The standard requires banks to reserve lifetime loan losses at origination. Banks took a one-time adjustment to increase their reserves to reflect the lifetime losses of all existing loans when they switched to the standard, deducting the amount from capital with the option to phase-in the impact over three years. Afterwards, they adjusted their reserves using earning as new loans came onto the books, or as their economic forecasts or borrowers’ financial conditions changed. The rapid spread and deep impact of COVID-19, the bulk of which has been experienced by the U.S. in March, has led to a precipitous economic decline and interest rate freefall. Regulators are now encouraging banks to work with borrowers facing financial hardship.

“For banks, [CECL is] going to be a true test for them. It’s not just going through this accounting standard in the macroeconomic scenario that we’re in,” says Will Neeriemer, a partner in DHG’s financial services group, pointing out that the change comes as many bankers adjust to working from home or in shifts to keep operations running. “That is almost as challenging for them as going through the new standard for the first time in a live environment.”

The concern is that CECL will force allowances to jump once more at the beginning of the standard as once-performing loans become troubled all at the same time. That could discourage new lending activity — leading to procyclical behavior that mirrors, rather than counters, economic peaks and troughs.

It remains to be seen if that would happen if Congress doesn’t provide temporary accounting and provisioning relief, or if some banks decline the temporary relief and report their results under CECL. Regardless, the quarter will be challenging for banks.

“It’s temporary relief and it’s only for this year. It keeps the status quo, which I think is important,” says Lawrence Kaplan, chair of the bank regulatory group in Paul Hasting’s global banking and payments systems practice. “You don’t have to have artificial, unintended consequences because we’re switching to a new accounting standard during a period where there are other extraordinary events.”

“The Biggest Threat to the Deposit Insurance Fund I’ve Ever Seen”


rates-6-28-19.pngA little-known rule called the national rate cap is putting community banks in a bind.

The cap tries to set a high-water mark for rates by calculating a weekly average of advertised interest rates for specific deposit products at branches, plus 75 basis points. This wasn’t a problem when interest rates were dropping or staying steady, but the higher rate environment has now inadvertently handicapped community banks as they compete for deposits.

Bankers say the rate cap, calculated and enforced by the Federal Deposit Insurance Corp., is unrealistically low compared to corresponding market rates. The difference could also make some banks appear riskier if examiners bring up deposit rates in exams.

Peoples Bank in Magnolia, Arkansas, uses wholesale funding to make loans for its low- to middle-income customers who lack deposits, says CEO Mary Fowler. The bank, which is well capitalized and has $200 million in assets, offers attractive rates to bring in and retain many of those funds.

The only problem? More than 90 percent of certificates of deposit (CDs) at Peoples Bank pay a rate that is higher than the rate cap.

“I call [these] traditional deposits, because they’re core as long as you’re paying the best rate in town. But we have to pay market rates for it,” she says.

Other banks are in a similar position, as higher rates have caused the national rate cap to lag the yield on Treasury securities of similar durations. This puts bankers like Fowler in a tough spot. They need to offer rates above the cap to attract or maintain deposits, but doing so invites skepticism from regulators. The FDIC declined to comment.

“Why would a customer get a CD from me when I can only hypothetically pay the national rate cap?” says Joseph Kiley III, president and CEO of Renton, Washington-based First Financial Northwest, a well-capitalized bank with $1.3 billion in assets. He points out that, at times, Treasuries paid more than 100 basis points above the rate cap.

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Bankers say the cap also creates tension with examiners, who see it as a proxy for “potentially volatile” deposits. That’s because the rule, which should only apply to a small subset of thinly capitalized institutions, has become standard across the industry.

Examiners ask executives at healthy banks what they would do with these higher-rate deposits if the bank lost capital and was forced to abide by the cap, says John Popeo, a principal at the consultancy Gallatin Group. Popeo is a former FDIC regulator who helped resolve failed banks after the financial crisis, and represents institutions across the country that are well capitalized and do not have any immediate regulatory issues.

He says examiners are not threatening a regulatory downgrade but want to see how the bank would fund itself in the event it is no longer well capitalized. For some banks, the answer isn’t pretty.

The cap could lead to systemic problems if too many banks dip below well-capitalized levels during an economic downturn, as the FDIC prohibits less-than-well-capitalized banks from offering rates above the cap.

“When they pull your funding, you’re done,” Kiley says. “[Your bank is] just going to bleed to death.”

The FDIC has begun the process of changing the rate cap calculation, but Fowler worries that an economic downturn that threatens bank capital levels could come faster than regulators’ correction. She has been in banking for decades and says the rate cap is “the biggest threat to the deposit insurance fund I’ve ever seen.”

Executives from Peoples Bank wrote five comment letters on the request for proposal. Fowler points out that the FDIC calculated the cap using only Treasury yields prior to 2009, at which point it changed its approach.

In calculating the rate cap now, the FDIC uses an average of prevailing deposit rates at bank branches, but excludes credit unions, negotiated rates and special offers from the calculation. Using branches means that big banks are overrepresented, and online banks paying market-leading rates are underrepresented. Fowler says the FDIC should change this. She thinks it should compare the current approach to the old Treasury approach, and select the rate that’s higher.

Kiley questions whether a rate cap is an antiquated notion but hopes any change will account for how customers interact with banks and rate-shop in the digital age. If the rate cap continues to exist, he would prefer that the FDIC use wholesale funding rates from institutions like the Federal Home Loan Bank.

“We are living in a world where we pretend folks walk into branches and say ‘Hi’ to the teller … and wave to their money in the vault,” he says. “Everyone banks like they buy from Amazon.com. I don’t think there should be a rate cap.”

Boardroom on Fire: A Bank Chairman’s Painful Lessons from the Financial Crisis


chairman-4-9-19.png“A sheriff’s car pulls up—the bank is on lockdown.” David Butler wistfully recalls that day in 2009; the day he lost everything.

“It was pretty traumatic,” he admits. “You have to ask tough questions. Can we survive it? What do we do? What’s our exit strategy?”

The events that transpired that fateful Friday afternoon send shivers down the spines of every bank director—the worst case scenario. No, not a robbery. The other worst case scenario.

“The FDIC comes in. They lock the doors and secure all our records before anyone’s allowed to go home.”

Butler was a founding board member of Western Community Bank. Western was big, state-chartered and publicly-traded. In 2007, they acquired a chain of banks with a sizable chunk of money tied up in Florida real estate. It was a ticking time bomb—and, spoiler alert: it was about to go off.

The early fallout of the housing market crash saw Western hemorrhaging $6 million a quarter, making Butler’s board an easy target for regulators.

“The FDIC wanted litigation wherever they could get it; half the time, even where they couldn’t,” he groans. “The public wanted heads to roll and we made perfect targets.”

Western had a clean public shell; no run-ins with the SEC—they were squeaky clean. But as the recession raged on, it became clear that “clean” didn’t cut it. “People were investigated, detained even, based on what? The suspicion of malfeasance? Yet we saw banks engaging in improper, verging on illegal activity walk away scot-free.”

This federal fishing expedition left Butler with a lingering paranoia; the fear that an army of pencil pushers sporting black suits and earpieces might knock on his door to have their Mission Impossible moment at his expense.

One month into 2009, Western’s shares plunged 95 percent. The finger of blame inevitably found a target. “Our CEO was a great guy, but the recession hit him like headlights on a deer,” Butler laments. “We asked him to resign. It was one of the most painful things I’d ever done.” The resulting shuffle in leadership landed David in the role of acting chairman.

“My job primarily became keeping morale up as we scrambled to find a partner,” he recounts. “We didn’t want depositors losing money, but we didn’t want to lose depositors. If they’ve got half a million in the bank, telling them to move it is hard, but it’s the right thing to do.”

Depositors weren’t the only people Western risked losing. The FDIC shot down attempts to offer retention bonuses, leaving Butler at the mercy of employees’ goodwill. “How do you ask someone not to jump ship when they’re waist-deep in water?”

As Butler fought to keep all hands on deck, Western’s board was rocking from the turbulence of days spent sparring over the bank’s balance sheet and late-night conference calls consumed by quarrels over how and where they would stretch its tier one capital.

“You can’t measure the character of your board until it’s been strained.”

“We had our share of those who didn’t stay the course,” he concedes. “Some resigned; some pointed blame—but then there were the ones who stuck it out. Even when it looked hopeless; even when tensions ran high, their commitment never wavered. I hold those people in the highest regard to this day.”

It was an act of bittersweet mercy when, in May 2009, the other shoe finally dropped.

A cease-and-desist order earlier in the year saddled Western’s board with a bureaucratic obstacle course of audits, reorgs, policy rewrites and loan appraisals; with no less than 15 deadlined reports to the state banking commission. One of the many hoops the board was forced to throw itself through required a reevaluation of Western’s loan loss reserves; an amount they determined to be $33 million. Butler was called to meet with the FDIC shortly thereafter.

“They sat me down and told me we needed $47 million,” he says. “I told them they were about to close my bank. We all sat there silently for a minute.”

Three months later, the state banking commission seized control of Western Community Bank, just $2 million shy of meeting its reserve requirement. The bank was turned over to the FDIC and sold to a local competitor for pennies on the dollar.

Where was Butler—the man who risked it all—that Friday afternoon when they came to take it all away?

“Our legal counsel advised us to stay away from the transition to avoid any situation where we might be questioned without an attorney present,” he explains. “So my wife packed a picnic basket and we drove to the beach.”

What about the anger, the resentment, the righteous indignation at the hopelessness of it all? “There was plenty of that to go around,” he admits. “The fact that we could fail was all they needed to treat us like we would. But you reach a certain age where you don’t have time to be angry. There’s no use holding onto all that bitterness.”

A decade has passed since that Friday afternoon when Butler lost it all. Murmurs of a looming recession seep from the rich vein of alarmist gossip to circulate amongst those with a finger on the pulse. “If those kind of whispers reach your ears, it means you’ve kept one to the ground,” Butler posits. “If you’re a bank director, you’ve got a choice. You can pick that ear up off the ground and look towards the future. Or,” he adds with a grin, “you can bury the rest of your head.”

Three New Ways the FDIC Is Helping Community Banks


regulation-3-8-19.pngIf there’s one takeaway from the Federal Deposit Insurance Corp.’s latest annual report, it’s that there’s a new sheriff in town.

The sheriff, Jelena McWilliams, isn’t literally new, of course, given the FDIC’s new chairman was confirmed in May 2018. Yet, it wasn’t until last month that her imprint on the FDIC became clear, with the release of the agency’s annual report.

In last year’s report, former Chairman Martin Gruenberg spent the first half of his Message from the Chairman—the FDIC’s equivalent to an annual shareholder letter—reviewing the risks facing the banking industry and emphasizing the need for banks and regulatory agencies to stay vigilant despite the strength of the ongoing economic expansion.

“History shows that surprising and adverse developments in financial markets occur with some frequency,” wrote Gruenberg. “History also shows that the seeds of banking crises are sown by the decisions banks and bank policymakers make when they have maximum confidence that the horizon is clear.”

The net result, wrote Gruenberg, is that, “[w]hile the banking system is much stronger now than it was entering the crisis, continued vigilance is warranted.”

Gruenberg’s tone was that of a parent, not a partner.

This paternalistic tone is one reason that bankers have grown so frustrated with regulators. Sure, regulators have a job to do, but to imply that bankers are ignorant of the economic cycle belies the fact that most bankers have more experience in the industry than regulators.

This is why McWilliams’ message will come as a relief to the industry.

It’s not that she disagrees with Gruenberg on the need to maintain vigilance, because there’s no reason to think she does. But the tone of her message implies that she views the FDIC as more of a partner to the banking industry than a parent.

This is reflected in her list of priorities. These include encouraging more de novo formations, reducing the regulatory burden on community banks, increasing transparency of the agency’s performance and establishing an office of innovation to help banks understand how technology is changing the industry.

To be clear, it’s not that Gruenberg didn’t promote de novo formations, because he did. It was under his tenure that the FDIC conducted outreach meetings around the country aimed at educating prospective bank organizers about the application process.

But while Gruenberg’s conversation about de novo banks was buried deep in his message, it was front and center in McWilliams’ message, appearing in the fourth paragraph.

“One of my top priorities as FDIC Chairman is to encourage more de novo formation, and we are hard at work to make this a reality,” wrote McWilliams. “De novo banks are a key source of new capital, talent, ideas, and ways to serve customers, and the FDIC will do its part to support this segment of the industry.” Twitter_Logo_Blue.png

To this end, the FDIC has requested public comment on streamlining and identifying potential improvements in the deposit insurance application process. Coincidence or not, the number of approved de novo applications increased last year to 17—the most since the financial crisis.

The progress on McWilliams’ second priority, chipping away at the regulatory burden on community banks, is more quantifiably apparent.

The FDIC eliminated over 400 out of a total of 800 pieces of outstanding supervisory guidance and, in her first month as chairman, launched a pilot program that allows examiners to review digitally scanned loan files offsite, reducing the length of onsite exams.

Relatedly, the number of enforcement actions initiated by the FDIC continued to decline last year. In 2016, the FDIC initiated 259 risk and consumer enforcement actions. That fell to 231 the following year. And in 2018, it was down to 177.

“We will continue [in 2019] to focus on reducing unnecessary regulatory burdens for community banks without sacrificing consumer protections or prudential requirements,” McWilliams wrote. “When we make these adjustments, we allow banks to focus on the business of banking, not on the unraveling of red tape.”

Another of McWilliams’ priorities is promoting transparency at the agency. This was the theme of her first public initiative announced as chairman, titled “Trust through Transparency.”

The substance of the initiative is to publish a list of the FDIC’s performance metrics online, including call center response rates and turnaround times for examinations and applications. In the first two months the webpage was live, it received more than 34,000 page views.

Finally, reflecting a central challenge faced by banks today, the FDIC is in the process of establishing an Office of Innovation that, according to McWilliams, “will partner with banks and nonbanks to understand how technology is changing the business of banking.”

The office is tasked with addressing a number of specific questions, including how the FDIC can provide a safe regulatory environment that promotes continuous innovation. It’s ultimate objective, though, is in line with McWilliams’ other priorities.

“Through increased collaboration with FDIC-regulated institutions, consumers, and financial services innovators, we will help increase the velocity of innovation in our business,” wrote McWilliams.

In short, while the industry has known since the middle of last year that a new sheriff is in town at the FDIC, the agency’s 2018 annual report lays out more clearly how she intends to govern.

How Reciprocal Deposits Build Franchise Value


deposits-1-16-19.pngThere are many alternatives to core deposits that banks can utilize to fund loans. Internet listing services, for example, have become popular. Unlike brokered deposits, there are no regulatory deterrents against their use. Still, internet listing-service deposits tend to be more expensive and more price sensitive—hence less stable—than traditional core deposits because they often come from out-of-market customers who chase rates rather than from local customers looking to establish a relationship.

Banks have another important, and arguably better, deposit-gathering tool at their disposal—reciprocal deposits. Thanks to the Economic Growth, Regulatory Relief and Consumer Protection Act, most reciprocal deposits now receive nonbrokered status.

What are reciprocal deposits? These are funds received by a bank through a deposit placement network in return for placing a matching amount of deposits at other network banks. Why would banks exchange equal amounts of money with each other? The mechanics of different reciprocal deposit services vary, but the gist is that a bank that participates in a reciprocal deposit network can offer access to FDIC insurance beyond $250,000 to attract safety-conscious customers who might otherwise consider various alternatives, including:
Depositing large sums into a money-center bank, foregoing some access to FDIC insurance and perhaps relying on ratings agencies, like Standard & Poor’s or Fitch, to help assess bank stability
Requiring that a bank collateralize or otherwise secure a large deposit with Treasuries or other ultra-safe, highly liquid government securities
Manually splitting a large deposit among multiple banks, maintaining relationships with each and negotiating different interest rates, signing multiple agreements and receiving multiple statements

Banks that participate in a reciprocal deposit network like the ability to more effectively pursue these large-dollar deposits from local customers who were previously beyond their reach, or whose collateralization requirements raised tracking and opportunity costs and lowered margins. Banks like that they can take multi-million-dollar deposits and place them through a reciprocal deposit network into other banks participating in the same network in increments below $250,000. The spreading out of the funds into multiple banks makes the entire amount eligible for FDIC insurance. This process enables a customer to access FDIC protection from many banks while working directly with just one. And the originating bank maintains ownership of the customer relationship.

Banks that receive reciprocal deposits from another bank are willing to take those funds because they are doing the same thing with their customers’ money. All told, participating banks exchange funds on a dollar-for-dollar basis so each comes out whole—giving rise to the term reciprocal deposits.

“Reciprocal deposits are popular because they tend to be associated with multi-million-dollar depositors, enabling banks to attract deposits in large chunks with lower acquisition and maintenance costs as costs tend to be spread over much larger deposit amounts,” explains Mark Thompson, president of CenterState Bank in Davenport, Florida. “Moreover, they tend to come from local customers at rates that are more in line with local pricing norms. They also tend to come from customers who are more likely to be interested in a broader, more long-term relationship that may include mortgages, credit cards and other profit-generating services.”

“In stark contrast to listing-service deposits, reciprocal deposits help a bank build franchise value,” according to James Di Misa, executive vice president and chief operating officer of Community Bank of the Chesapeake in Waldorf, Maryland. “Quite simply, reciprocal deposits tend to be large, lower-cost, in-market deposits and, as such, offer greater potential for opportunity and efficiency. For this reason, many banks are replacing at least a portion of their listing-service deposits with reciprocal deposits.”

Banks that don’t want to trade out listing-service deposits entirely can still use reciprocal deposits to augment their usage of listing-service funding. For example, they can use a reciprocal deposit offering to lure more business from a safety-conscious listing-service customer who keeps funds protected at multiple FDIC-insured institutions and who might consolidate some, or all, of their deposits with a bank that can offer access to FDIC protection far beyond $250,000.

And of course, reciprocal deposits can be a good replacement for collateralized deposits and wholesale funding options.

As the competition for deposits heats up, now is a good time for every bank to consider making reciprocal deposits a larger part of its funding strategy.

To learn more, please visit www.promnetwork.com/game-changer.

Why Investors Are Still Hungry for New Bank Equity


capital-10-12-18.pngThe U.S. economy is riding high. Bank stocks, while their valuations are down somewhat from their highs at the beginning of the year, are still enjoying a nice run. For most banks that want to raise new equity capital, the window is still open.

The banking industry is already well capitalized and bank profitability remains strong. According to the Federal Deposit Insurance Corp., the industry earned $60.2 billion in the second quarter of this year, a 25 percent gain over the same period last year, thanks in no small part to the Trump tax cut, which has also helped prop up bank stock valuations. The truth is, in the current environment, banks don’t need to raise new equity just to increase their capital base—they can do that through retained earnings. The industry is awash with capital and most banks don’t necessarily need even more of it.

“The industry overall is enjoying capital accretion,” says Bill Hickey, a principal and co-head of investment banking at Sandler O’Neill + Partners. “Capital ratios industry-wide have continued to increase as banks have earned money and obviously enjoyed the benefits of tax reform. … I think the need for equity capital has lessened slightly as a result of capital ratios continuing to increase.”

Over the last few years, banks have clearly taken advantage of the opportunity to repair their balance sheets, which were ravaged during the financial crisis. According to S&P Global Market Intelligence, there were 123 bank equity offerings in 2016, which raised nearly $6 billion in capital at a median offering price that was 125 percent of tangible book value (TBV) and 52.8 percent of the most recent quarter’s earnings per share (MRQ EPS). There were 146 equity offerings in 2017 that raised nearly $7.5 billion, with offering price medians of 66.3 percent of TBV and 16.6 percent of MRQ EPS. (The industry was much less profitable in 2016 than in 2017, which explains the wide disparity between the median values for the two years.) And through Sept. 26, 2018, there were just in 66 offerings—but they have raised $7.6 billion in equity capital, with a median offering price that was 175 percent of TBV and 13.3 percent of MRQ EPS.

As the median offering prices as a percentage of TBV have gone up over the last two and a half years, while also declining as a percentage of the most recent quarter’s earnings per share—which means that institutional investors are in effect paying more and getting less from a valuation perspective—you might think investor appetite for bank equity would begin to wane. But according to Hickey, you would be wrong.

“There is a lot of money out there looking to be deployed in financial services and banks,” he says. “So there are folks who need to deploy capital—pension funds, funds specifically focused on investing in financial institutions. They have cash positions they need to deploy into investments. So there is a great demand for equity, particularly bank equity at the current time.”

Hickey says most of this new equity was raised to fuel growth, either organic growth or acquisitions. But any bank considering doing so needs to provide investors with a detailed plan for how they intend to use it. “You have to be able to articulate a strategy for the use of the capital you intend to raise,” says Hickey. “That seems obvious, but it needs to be explained quite well to the investment community so they understand how the capital is going to be deployed and have a sense of what their return possibilities are.”

And if you’re going to tap the equity market to support your strategic growth plan, make sure you raise enough the first time around. “Arguably, a company [should] raise enough money that will allow it to fund their growth for at least 18 to 24 months,” Hickey explains. “Investors don’t like it when they’re investing today and then 12 months later the same company comes back looking for more capital. Investors would [prefer] to minimize the number of offerings so they’re not diluted in the out years.”

The Case for Rating Community Banks Investment Grade


investment-9-18-18.pngFor years, legacy rating agency thinking held that community banks could not be rated investment grade. They were too small, the thinking went, and therefore could not compete with scale-advantaged larger banks. Moreover, this structural deficiency likely made community banks riskier, as they were naturally subject to adverse selection in terms of loan originations.

All of this is intuitive. But it doesn’t stand up to further scrutiny.

If we consider the history of bank failures, we see that very small banks and very large banks are disproportionately represented. Meanwhile, well-run community banks, with long-standing ties to local markets, core deposit funding and well diversified risks have a long history of successfully riding out credit cycles. That piqued our interest. But we still needed to get over the hump of competitiveness. How could a community bank’s cost structure—the basis for pricing assets and liabilities—match the efficiency of the largest banks? We took a closer look.

Started with funding costs. Turns out that government guaranteed deposit funding—available to all FDIC-insured institutions, large and small, is a great equalizer. In fact, most community banks derive substantial amounts of their funding via core deposits, giving them an advantage over the largest banks that require substantial sums of more expensive market-sourced funding.

What about operating costs? Surely, the largest banks enjoy substantial economies of scale relative to community banks. That may be true, especially in terms of being able to absorb things like the significant increases in regulatory reporting and compliance costs. What we found interesting, however, is that the efficiency ratios of community banks in many cases compare favorably to those of the larger banks. Our research came up with two explanatory considerations. First, according to the FDIC, the benefits of economies of scale are realized with as little as $100 million in assets, and second, among larger banks, the benefits of scale are typically offset by the added costs brought on by complexity and administrative friction. This serves as a reminder that, in terms of competitiveness, banking, especially small to mid-sized commercial banking, is a local scale business, not a national (or international) one.

Now, you might point out, broader and more sophisticated product offerings must tip the scale in favor of larger banks. And there must be some benefit to the substantial technology and marketing spend of the larger banks. We wouldn’t disagree. But we also believe community banks can punch back with value of their own created out of local market knowledge and relationships as well as superior responsiveness. And most small businesses really don’t demand a sophisticated product set, and marketing spend generally creates value in consumer financial services, much of which left community banking some time ago.

So, what about the risk side of the equation? Larger banks by definition will have greater spread-of-risk than community banks, where risks are more concentrated, certainly in terms of geography, and quite possibly loan type (most notably CRE). What our research found was that through cycles, community banks’ loss rates per loan type were typically better than those of larger banks. In other words, no evidence of adverse selection, and a realization that most markets in the U.S. are relatively well diversified economically.

This is not to say that all community banks are investment grade. Well-run community banks can be rated investment grade. Therein lies an essential element of our rating determination—an in-depth due diligence session with senior management. Here, we look to understand the framework and priorities for managing risk, key aspects of growth strategies, and the rationale underpinning capital and liquidity structure. This is a story sector, and the management evaluation is critical to our rating outcome.

Our research suggests that well-run community banks can compete successfully with larger banks, and generate solid fundamental performance through the cycle. We rated our first community bank in 2012, and today that figure stands at 115 and counting, testament that our approach has resonated with investors and depositors alike.

Rethinking the FICO Score


FICO-6-20-18.pngFor decades, pre-dating many banking careers today, the tried and true method to evaluate credit applications from individual consumers was their FICO score. More than 10 billion credit scores were purchased in 2013 alone, a clear indicator of how important they are to lenders. But is it time for the banking industry to reconsider its use of this metric?

The FICO score, produced by Fair Isaac Corp. using information from the three major credit bureaus—Equifax, TransUnion and Experian—has been considered the gold standard for evaluating consumer credit worthiness. It focuses squarely on the concentration of credit, payment history and the timeliness of those payments. FICO scores have generally proven to be a reliable indicator for banks and other lenders, but in an age operating at light speed, in which many purchases can be made in seconds, a score that can fluctuate in a matter of days might be heading toward obsolescence.

Some believe a person’s credit score should be considered only in parity with other, more current indicators of consumer behavior. A study released in April by the National Bureau of Economic Research says even whether people choose an Apple or Samsung phone “is equivalent to the difference in default rates between a median FICO score and the 80th percentile of the FICO score.”

Consider the following example. A consumer pays off an auto loan, resulting in a reduction in their FICO score. This is largely due to the reduced amount of credit extended. That reduced score could become a deciding factor if the customer has applied for, but not yet closed, a mortgage 60 or so days before paying off the vehicle and could affect the interest rate of the applicant.

That leaves a bitter taste for anyone with average or above average credit who has demonstrated financial responsibility and, it could be reasonably argued, would be a much better candidate for credit extension than someone with the same score who doesn’t give two flips about the regular ebbs and flows in their credit.

For all its inherent benefits to the industry, the traditional credit score isn’t perfect. Banks could be using their own troves of customer data to evaluate their credit applications more accurately, more fairly or more often. This could be a boon for institutions hoping to grow their deposit base or enhance their loan portfolios. Some regulators have indicated their attention to this approach as well. The Federal Deposit Insurance Corp.’s Winter 2017 Supervisory Insights suggests data could be a helpful indicator of risk and encouraged member institutions to be more “forward-thinking” in their credit risk management.

“As new risks emerge, an effective credit [management information system] program is sufficiently flexible to expand or develop new reporting to assess the effect those risks may have on the institution’s operations,” the agency said.

That suggests the FICO score banks are currently using might not tell the full story about how responsible credit applicants might be.

“My personal opinion is that among most people, if you have someone who thinks about [their digital footprint and credit], you’re already talking about people who are financially quite sophisticated,” Tobias Berg, the lead author of the NBER study and an associate professor at Frankfurt School of Finance & Management, told Wired Magazine recently. The study examined a number of data points that go far beyond what is incorporated in a FICO score.

That certainly has value for banks. The data they already collect about their customers could be used to determine credit worthiness, but there’s a counter argument to be made. Digital footprints are much easier to manipulate more quickly over time by changing usernames, search history, devices and the like. Using an Android over a more expensive iPhone could be a negative in the study’s findings, for example, which might not reflect the customer’s true credit profile.

But FICO scores are not reviewed as regularly as they could be, and a swing of a couple dozen points from one moment to another can significantly sway some credit applications.

For now, fully abandoning the FICO score isn’t a likely or manageable option for banks, nor one that’s favored by regulators, but the inclusion of digital data in credit applications is something that could be adapted and be beneficial to both the bank and customers eager to expand that relationship with their institution.

Use Compensation Plans to Tackle a Talent Shortage


Can you believe it’s been 10 years since the global financial crisis? As you’ll no doubt recall, what was originally a localized mortgage crisis spiraled into a full-blown liquidity crisis and economic recession. As a result, Congress passed unprecedented regulatory reform, largely in the form of the Dodd-Frank Act, the impact of which is still being felt today.

Significant executive compensation and corporate governance regulatory requirements now require the full attention of senior management and directors. At the same time, shareholders continue to apply pressure on management to deliver strong financial performance. These challenges often seem overwhelming, while the industry also faces a shortage of the talent needed to deliver higher performance. As members of the Baby Boomer generation retire over the coming years, banks are challenged to fill key positions.

Today, many banks are just trading people, particularly among lenders with sizable portfolios. Many would argue the war for talent is more intense than ever. According to Bank Director’s 2017 Compensation Survey, retaining key talent is a top concern.

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To address this challenge, many banks have expanded their compensation program to include nonqualified benefit plans as well as link a significant portion of total compensation to the achievement of the bank’s strategic goals. Boards are focusing more on strategy, and providing incentives to satisfy both the bank’s year-to-year budget and its long-term strategic plan.

For example, if the strategic plan indicates an expectation that the bank will significantly increase its market share over a three-year period, compared to competition, then executive compensation should be based in part upon achieving that goal.

Achieving Strategic Goals
There are other compensation programs available to help a bank retain talented employees.

According to Federal Deposit Insurance Corp. call report data and internal company research, nonqualified plans, such as supplemental executive retirement plans (SERPs) and deferred compensation plans, are widely used and are particularly important in community banks, where equity or equity-related plans such as stock options, restricted stock, phantom stock and stock appreciation plans are typically not used. These plans can enhance retirement benefits, and can be powerful tools to attract and retain key employees. “Forfeiture” provisions (also called “golden handcuffs”) encourage employees to stay with their present bank instead of leaving to work for a competitor.

SERPs
SERPs can restore benefits lost under qualified plans because of Internal Revenue Code limits. Regulatory rules restrict the amount that can be contributed to tax-deferred plans, like a 401(k). A common rule of thumb is that retirees will need 70 to 80 percent of their final pre-retirement income to maintain their standard of living during retirement. Highly compensated employees may only be able to replace 30 to 50 percent of their salary with qualified plans, creating a retirement income gap.

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To offset this gap, banks often pay annual benefits for 10 to 20 years after the individual retires, with 15 years being the most common. SERPs can have lengthy vesting schedules, particularly where the bank wishes to reinforce retention of executive talent.

Deferred Compensation Plans
We have also seen an increasing number of banks implement performance-based deferred compensation plans in lieu of stock plans. Defined as either a specific dollar amount or percentage of salary, bank contributions may be based on the achievement of measurable results such as loan growth, increased profitability and reduced problem assets. Typically, the annual contributions vest over 3 to 5 years, but could be longer.

While deferred compensation plans have historically been linked to retirement benefits, we see younger officers are often finding more value in cash distributions that occur before retirement age.

To attract and retain millennials in particular, more employers are expanding their benefit programs by offering a resource to help employees pay off their student loans. According to a survey commissioned by the communications firm Padilla, more than 63 percent of millennials have $10,000 or more in student debt. Deferred compensation plans can also be extended to millennials to help pay for a child’s college tuition or purchase a home. Because these shorter-term deferred compensation plans do not pay out if the officer leaves the bank, it provides a strong incentive for the officer to stay longer term.

Banks must compete with all types of organizations for talent, and future success depends on their ability to attract and retain key executives. The use of nonqualified plans, when properly chosen and correctly designed, can make a major impact on enhancing long-term shareholder value.

Insurance services provided by Equias Alliance, LLC, a subsidiary of NFP Corp. (NFP). Services offered through Kestra Investment Services, LLC (Kestra IS), member of FINRA/SIPC. Kestra IS is not affiliated with Equias Alliance, LLC or NFP.

Innovation Spotlight: Howard Bank


innovation-10-3-17.pngScully-Mary-Ann.pngMary Ann Scully, CEO and chairman
As a lifelong banker with over 30 years of varied executive experiences, Mary Ann Scully headed the organizing team for Howard Bank of Baltimore, Maryland, and currently serves as a board member of the Baltimore Federal Reserve and a community advisory board member for the Federal Deposit Insurance Corp. Under her leadership, Howard Bank recently announced its fifth acquisition in five years, which will make it a $2.1 billion asset institution. It has maintained a commitment to high touch service throughout each integration.

When you started at Howard Bank, what did you want to do differently with innovation?
We have always viewed our differentiation as high touch expertise and advice. Therefore, we tried not to be leading edge from an innovation perspective. However, we also recognized that to attract small and medium-sized businesses that we should not and would not ask our customers to make a choice between competitive products and delivery available at larger banks and our high touch advice. So we have always had to be competitive and with a more sophisticated customer base, the bar was set higher.

Over the years, how has your digitization strategy changed?
We opened the doors in 2004 with online banking, online check images, hand scan safe deposit boxes—not your typical start-up community bank mix. Over time, we have become more and more committed to being leading edge in the utilization of information to inform our decisions, optimize our processes and advise our customers. Our recent project with [commercial lending platform] nCino is an example of this commitment. Our commitment to a new universal banker branch model is another.

You were once quoted as saying, “Thriving is different than survival and relevance is more than profitability.” What does it take for a bank to thrive AND stay relevant in this competitive environment?
It requires, first, great clarity of strategy: “What do you want to do, how and when, for whom?” And that requires being able to articulate the more painful, “What do you not want to do or whom are you not targeting?” The second requirement is a long-term vision because relevance requires constant investment in the business—in people and technology. It also requires access to capital, both financial and human, to facilitate those investments.

Finally, it requires flexibility because the world changes at a faster rate than ever before and it is important to be able to reallocate resources to what our customers feel is relevant for them. Our high growth trajectory requires a mindset throughout the organization that acknowledges the need for change. For example, we have attracted five teams from other banks in five years. We’ve done five acquisitions in five years, the most recent and largest just announced in August. We’ve accomplished seven capital raises in 13 years, the most recent and largest in January of this year.

After being involved in several M&A deals, what lessons have you learned about integrating technology platforms to ensure business continuity?
First, we always remember to view integration from a customer’s perspective. There is always disruption involved in a merger, some sense of “I did not ask for this,” and flowery promises do not alleviate the skepticism even when an in-market merger is perceived by a community as being positive. So we plan, plan and plan to ensure that customers never lose functionality and if possible, gain something in the process. This means being willing internally to change the “host” systems as well as the acquired bank systems. It means viewing integrations as an opportunity, not a necessary evil, to take the best of both and occasionally the best-of-breed, not just as a way to save costs and slam things together but as a way to enhance the combined systems. We have a cross-functional team who has worked together on each transaction, some who started on the acquired side who are now sitting as an acquirer and their experience and perspective are invaluable. That team always has representatives from each bank for each function. Conversions are not for amateurs or the faint of heart so constant communication between providers and users is also important for successful platform integration.