Time for Boards to Clean House and Recession-Proof the Bank

Written by

Bank boards can prepare for potentially tough economic times by becoming well versed in the balance sheet and cultivating a culture of credible challenge, said speakers throughout the first day of Bank Director’s Bank Board Training Forum, held in Nashville on Sept. 11-12.

In the wake of the spring regional bank failures of Silicon Valley Bank, Signature Bank and First Republic Bank, the industry has revisited whether or not directors can really govern risk. While they have redoubled their efforts on liquidity, they now need to contemplate what might happen to their institution’s balance sheet over the next four quarters and beyond. 

“2023 is a lost year for banks,” said Dan Flaherty, a managing director at the investment bank Janney Montgomery Scott. “If you have to make an investment or strategic decision that can accelerate getting to greener pastures, this is the time to do it.”

Balance sheet management and interest rate risk are urgent areas of focus for many banks. High interest rates have finally appeared in deposit costs. The spring banking crisis accelerated a deposit exodus and ignited greater competition. This is on top of the “huge” unrealized losses that banks are carrying on securities and fixed-rate loans, some of which may resolve themselves during the next two to five years depending on the direction of the federal funds rate, Flaherty said.

Boards should be asking management about the outlook for the underlying cost of funding and asset yield that go into the projected 12-month return on assets, said Brian Leibfried, partner and managing director at the investment bank Performance Trust Capital Partners. He gave the example of a bank that had projected a 70 basis point cost of funds; the actual cost of funds was 1.2%. This skewed metrics like the bank’s net interest margin, earnings and return on assets.

“The balance sheet could produce different returns,” he said. “Can the bank weather those different returns?”

Given that, boards and management teams should have a sense of how fast the assets and deposits on their balance sheet could reprice, and how long it could take unrealized losses to accrete back. Some banks may need to take dramatic action, said Eve Rogers, an audit partner at the public accounting, consulting and technology firm Crowe LLP.

“Now is the time to clean house,” she said. “There’s no reward in being more profitable [this year] versus building profitability for future years.”

Rogers added that banks may want to launch market expansion efforts in order to compete for deposits or grow a customer base. Some banks may decide to consider limited balance sheet restructuring that monetizes their unrealized loss but gives them cash and flexibility to reinvest those funds into higher-yielding opportunities or preservation of capital. Flaherty said he expects the fourth quarter may be peppered with announcements of banks selling loans or securities and booking their loss. 

Forward-looking banks should also think about mitigating losses and making their balance sheet “recession-proof,” said Sydney Menefee, a former regulator at the Office of the Comptroller of the Currency and a partner at Crowe. Bank boards may expect to record losses in a recession, but losses flow through other line items on the balance sheet. Have they explored what might happen to the balance sheet if the economy enters a long period of slow growth? 

The way for boards to get at those answers is by asking questions, said Leslie Schreiner, the director of diversity and inclusion at Federal Home Loan Bank of Atlanta.

“Questions are the tools of the board,” she says. To that end, it will be crucial for directors to press management on the assumptions and processes they used to model returns or come up with strategic decisions going into 2024.

Managing Interest Rate Risk With Stronger Governance

Written by

Many banks were caught off guard by the rapid pace of interest rate hikes over the past year. Now that the initial shock has hit, bank directors are questioning how to manage interest rate risk better and prepare for disruptions.

While rising rates are part of market cycles, rates rarely increase at their recent velocity. Between March 2022 and June 2023, the federal funds rate rose from 0.25% to 5.25%, a 500-basis point increase in less than 15 months.

A High Velocity Rise Caught Bank Leaders Off Guard
Not since the 1970s have rates increased at this pace in such a short time frame. Even in the cycle preceding the 2008 financial crisis, rates rose from 1% in 2004 to 5.25% in 2006 over 24 months. The latest interest rate hikes are steeper — and come at a time when banks were already awash in cash and liquidity. With excess cash, less loan demand and no place to park their money in recent years, many banks purchased securities, which historically have been a safe bet in such times.

But few boards were prepared for rates to increase so quickly. Since March 2022, continual increases in the federal funds rate have reduced the value of banks’ fixed-rate assets and shortened the maturity of their deposits. Two bank collapses in March 2023 demonstrated how quickly interest rate risk can grow into a liquidity risk and reputation risk.

Bank Directors Can Focus on Strong Governance, Risk Mitigation
Now that they have experienced an unprecedented event, bank directors are questioning what they can do to prepare for future interest rate shocks. But banks don’t necessarily need new risk management strategies. What they should do now is use the risk-mitigating levers available to them and act with strong governance.

Most banks already have asset-liability management committees that meet quarterly to stress test the balance sheet with instantaneous shocks, ramps and nonparallel yield curves. While going through the motions every quarter might appease regulators, it won’t prepare banks for black swan events. Banks need to hold these stress-testing meetings more frequently and make them more than compliance exercises.

In addition, bank directors should review assumptions used in their asset-liability management report packages. Some directors take these assumptions at face value without questioning how they were calculated or if they reflect reality. Yet the output of a model is only as good as the integrity of its underlying conventions or specifications.

Additional Strategies Require a Focus on Execution
Repricing products, changing product mix or employing derivatives can be other effective tools for managing risk. But again, the key is in execution. Some banks fear alienating customers or the community by repricing or changing products that are safer for the bank but might not be preferred by the customer. For example, some institutions prefer to book fixed-rate loans to meet customer demand, even though floating-rate loans might help the bank better manage risk.

While derivatives can add risk if not properly understood and managed, they can be a highly effective tool to manage interest rate risk if used early in the cycle. Once rate changes are underway, a derivative might no longer be helpful or might be cost-prohibitive.

Even as the Federal Reserve contemplates its next move, bank directors can look at the recent past as a learning experience and an opportunity to better prepare for the future.

Liquidity Risk Looms in 2023

Written by

Liquidity and interest rate risk dominated bankers’ minds following a series of rapid interest rate hikes by the Federal Reserve, and deposit pricing has proven to be a particular challenge. In 2023, bank leaders will likely focus much of their time on various strategies aimed at growing low-cost deposits while also increasing lending, says Craig Sanders, a partner with Moss Adams. At the same time, bank executives and directors are also confronting growing concerns around cybersecurity risk and regulatory scrutiny of certain fees, such as overdraft charges. 

Topics include: 

  • Liquidity Management  
  • Cybersecurity Expertise 
  • Third-Party Risk Oversight 
  • Responding to More Scrutiny on Fees 

Bank Director’s 2023 Risk Survey, sponsored by Moss Adams, explores several key risk areas, including interest rate risk, credit risk, cybersecurity and emerging issues. The survey results are further explored in the second quarter issue of Bank Director magazine.

Hedging in the Spotlight After Banks Failed to Mitigate Interest Rate Risk

Written by

Even as progressively higher interest rates throughout 2022 caused increasingly large unrealized losses on banks’ books, they rarely hedged that risk.

In fact, banks with fragile funding, like high concentrations of uninsured deposits, sold or reduced their hedges in 2022 as interest rates climbed, according to a new paper from university researchers. Rising interest rates have caused long-term assets, such as bonds and loans that pay a fixed rate, to decline in value. One way for banks to mitigate that risk is to use interest rate swaps, contracts that banks can purchase to turn fixed rate assets into floating rate assets. That eliminates the potential for unrealized losses to increase if rates continue to increase.

Banks are weighed down by the declining value of their assets. Ninety-seven percent of 435 major exchange listed U.S. banks reported that the fair value of their loans was below their carried value at the end of 2022, according to The Wall Street Journal citing data provided by S&P Global Market Intelligence. The difference was a $242 billion loss, reversing a paper gain of $96 billion at year-end 2021. The unrealized loss equated to 14% of those banks’ total equity and 21% of their tangible common equity.

“In some ways, the cake is baked. If I own a bunch of fixed rate bonds or I’ve made a bunch of fixed rate loans that are below market [interest rates] … there’s not a lot you can do,” says Ben Lewis, managing director and global head of sales for financial institutions at Chatham Financial. “But one of the things that’s super interesting about the current environment is that you can actually get paid to hedge.”

Only about 6% of aggregate assets at U.S. banks are hedged by swaps, according to the April research paper “Limited Hedging and Gambling for Resurrection by U.S. Banks During the 2022 Monetary Tightening?” Researchers calculated the swap coverage using call report data from the first quarter of 2022, and quarterly and annual filings.

Companies that offer a way to hedge against interest rate risk say swaps are even more attractive for banks right now given the inverted yield curve: long-term bonds have a lower yield than short-term bonds. That tends to indicate a recession is more likely.

“Regardless of when banks hedge, they’re eliminating future rate risk,” says Isaac Wheeler, head of balance sheet strategy at Derivative Path. “But if a bank didn’t do it a month ago and it hedged today instead, it now gets 100 basis point higher spread on a floating rate basis, which is a lot better.”

Interest rate risk is a concern because banks face rising funding costs, resulting in net interest margin compression. Both Derivative Path and Chatham Financial help banks with hedges and report a pickup in activity since the March banking crisis. Wheeler says concerns about NIM compression are driving banks to focus on hedging loans; hedging activity at his firm is now split equally between loans and securities.

Lewis says the community banks he’s working with are using hedging to avoid the impact of worst-case rate scenarios on their long-term assets. “They’re willing to give up some income today or potentially future income tomorrow to manage that risk,” he says.

But one reason why banks may hesitate to add swaps now is because the swap locks in whatever unrealized loss the bank already has on the asset. While the asset’s market value won’t further erode, the swap means there’s no ability to reverse the unrealized loss if rates fall. A bank that believes rates will begin falling in 2023 may decide to wait for the unrealized loss on the asset to reverse.

In either case, it’s a good idea for bank boards to be skeptical about interest rate predictions. Directors should ask management about contingency plans if rates move in a way they didn’t model and should explore how different rate environments impact their margin and earnings. They may decide to hedge a portion of their longer-term assets to reduce pressure on their NIM without locking in too many of their unrealized losses.

“Banks get to choose what risks they can take, and I think now more than ever, the idea of taking interest rate risk isn’t appealing,” Wheeler says. “A lot of banks eventually realize that they don’t want to be in the business of taking rate risk, or that’s not how they want to generate earnings. They want to lean into the other things that they’re better at, while trying to reduce rate risk.”

Why It’s Not Too Late for Interest Rate Swaps

Written by

“Has the train left the station? Are we trying to bolt the door after the horse has left the stable?”

These are the types of questions community bank directors are asking in the aftermath of the largest single-year interest rate increase since 1980. Playing catch-up in its fight to control inflation, the Federal Reserve’s rate hikes in 2022 were both unexpected and larger than any previous decades. One year later, some industry observers have begun to argue that an overly aggressive Fed may soon need to reverse course to prevent a recession. If the worst is truly behind us, this line of argument goes, why should a bank executive invest time in 2023 to install interest rate hedging capabilities?

Because, we argue, there will always be uncertainty regarding the direction and speed of change in interest rates. Swaps give institutions enormous power because they have the ability to exchange that uncertainty (floating rate) for certainty (fixed rate).

Here are three strategies we think banks with direct access to interest rate derivatives will deploy in 2023. These ideas are timeless but are particularly relevant based on where we are today in the economic cycle:

1. Individual Loans
A borrower hedging program enables a bank to retain a floating-rate asset while the borrower secures fixed-rate financing via a swap. With on-balance sheet loan rates jumping from the mid-3% range to as high as 6% to 7%, booking the fixed-rate loan seems like the best thing to do. But weak or negotiable prepayment language often means that a fixed-rate loan really behaves like a one-way floater. For example, a loan booked at 6.5% today will never move higher — but if the market corrects lower, you can expect a call from the borrower looking for a downward rate adjustment.

Some banks without access to hedging tools have placed their borrowers into loan-level interest rate swaps by involving an outside party in the loan agreement. These indirect swaps are designed as a convenience product for small banks to get their toe in the water and accommodate larger borrowers with a long-term fixed rate. By keeping the community bank swap-free, indirect programs also prevent the bank from considering the following two balance sheet strategies that protect and enhance net interest margin.

2. Securities Portfolio
Perhaps the greatest pain point related to interest rates that banks experience in 2022 was marking the securities portfolio to market prices and booking the resulting unrealized losses in the accumulated other comprehensive income, or AOCI, account. Banks without swaps installed were forced to choose between two bad options during the excess liquidity surge of 2020: hold onto cash that earned virtually nothing or purchase low-yielding long-term bonds to pick up maybe 100 basis points. Institutions with access to swaps had a third choice: keep the first two years of the higher-yielding asset and then swap the final eight years to a floating rate. Swaps used to fine-tune the duration of a bond provide the double benefit of converting to a higher floating yield today (handy when the fed funds is around 4.33%) and creating a gain in the AOCI account to offset the losses booked on the bond.

While a swap today cannot erase past unrealized losses, it is a game changer for the CFO and treasurer to have the ability to take control of portfolio duration.

3. Wholesale Funding
Higher interest rates have also led depositors to move their funds, leading banks to grow their wholesale funding from sources such as FHLB advances. Banks without access to swaps will often ladder out term fixed-rate advances to longer maturity dates, using a product that includes both a yield curve premium and a liquidity premium. A bank with hedging capabilities can accomplish the same objective by keeping the actual funding position short and floating. From there, the funding manager can conserve the liquidity premium and achieve a more efficient all-in borrowing cost by using pay-fixed swaps to create the ladder. Additionally, the swap always provides a two-way make-whole, where a traditional fixed-advance includes a down-rate penalty but no benefit when rates rise.

While some bankers still view interest rate derivatives as risky, the rapidly changing conditions experienced in 2022 suggest that the greater risk may be attempting to manage the balance sheet without access to these powerful tools. Today, more than 40 years since their creation, one thing is certain: it’s not too late for any bank to start using interest rate derivatives.

Deposit Costs Creep Up Following Rate Increases

Written by

The rapidly rising interest rate environment is beginning to impact the funding dynamics at banks as deposit competition increases and they pay up for time deposits.

While rising rates are generally good for lending, the unrelenting climb in interest rates hasn’t been uniformly positive for banks. Since the pandemic, many banks have had historic deposit growth and liquidity. The aggressive and continuous rising interest rate environment could change that. 

There was a 1.1% drop in total deposits at all Federal Deposit Insurance Corp.-chartered banks in the third quarter, according to a November report from analysts at Janney Montgomery Scott. Excluding time deposits like certificates of deposits, or CDs, core deposits dropped 2%. But over that time, 40% of banks reported positive deposit growth in excess of 1%. That could mean that as core deposits leave banks, they are growing time deposits. 

The median cost of deposits for banks in the Kroll Bond Rating Agency universe more than doubled in the third quarter to 37 basis points. 

“No longer content with letting the hot money exit, this sharp increase in deposit costs is the product of a strategy of rate increases designed to stem outflows of less sticky or rate sensitive deposits,” wrote KBRA in a Nov. 15 report.  

One reason for this deposit shift is consumers and businesses are leveraging technology to move their funds into higher rate accounts. Core deposit outflows in future quarters could be unpredictable for institutions: they might happen at a faster pace or higher volume than a bank is prepared for, or a few large, important deposit relationships may leave. This could deplete available cash on hand that an institution would use for ongoing operations or to fund new loan opportunities. 

“The last time we went through a significantly rising rate environment, in the 1970s, money market funds did not exist. People were captive to the bank,” says Nate Tobik, CEO of CompleteBankData and author of “The Bank Investor’s Handbook.” “Now we’re [repeating] the ‘70s, except there are alternatives.”

One option banks had in the past to raise short-term liquidity — selling securities marked as available for sale (AFS) — may be off the table for the time being. The bank space carried a total unrealized loss, mostly tied to bonds, of more than $450 billion in the second quarter, according to the FDIC. This loss is recorded outside of net income, in a call report line item called accumulated other comprehensive income. Selling AFS securities right now would mean the bank needs to record the loss. 

“Over the past couple weeks, we have had multiple discussions with community bankers that have been very focused on deposit generation,” wrote attorney Jeffrey Gerrish, of Gerrish Smith Tuck, in a late October client newsletter. “Unfortunately, many of these community banks have a securities portfolio that is so far under water they really don’t see the ability to sell any securities to generate cash because they cannot afford to take the loss. This is a very common scenario and will result in a pretty healthy competition for deposits over the next 12 to 24 months.”

In response, banks will need to consider other options to raise alternative funds fast. Noncore funding can include brokered CDs, wholesale funding or advances from the Federal Home Loan Banks system. Tobik says CDs appeal to banks because they are relatively easy to raise and are “time deterministic” — the funding is locked for the duration of the certificate. 

All of those products come at a higher rate that could erode the bank’s profit margin. 

Another ratio to watch at this time is the liquidity ratio, wrote Janney analysts in a Nov. 21 report. The liquidity ratio, which compares liquid assets to total liabilities, is used by examiners as a more “holistic” alternative to ratios like loans-to-deposits. The median liquidity ratio for all publicly traded banks at the end of the third quarter was 20%, with most banks falling in a distribution curve ranging from 10% to 25%.

The 20% median is still 4% higher than the median ratio in the fourth quarter of 2019. The effective federal funds rate got as high as 2.4% in summer 2019, compared to 3.08% in October. Janney did find that banks between $1 billion and $10 billion had “relatively lower levels” of liquidity compared to their smaller and bigger peers.

But for now, they see little to worry about, but a lot to keep their eyes on. “Our analysis shows that while liquidity has tightened slightly by several measures since a [fourth quarter 2021] peak, banks still maintain much higher levels of liquidity than prior to the pandemic and have plenty of capacity to take on additional wholesale funding as needed to supplement their core funding bases,” they wrote.

Going forward, banks will need to balance the tension between managing their liquidity profile and keeping their cost of funds low. What is the line between excess liquidity and adequate liquidity? How many deposit relationships need to leave any given bank before it starts a liquidity crunch? What is cost of paying more for existing deposits, versus the potential cost of bringing in wholesale or brokered deposits? 

The answers will be different for every bank, but every bank needs to have these answers.

The Return of the Credit Cycle

Written by

It has been like waiting for the second shoe to fall.

The first shoe was the Covid-19 pandemic, which forced the U.S. economy into lockdown mode in March 2020. Many banks prepared for an expected credit apocalypse by setting up big reserves for future loan losses — and those anticipated losses were the second shoe. Sure enough, the economy shrank 31.4% in the second quarter of 2020 as the lockdown took hold, but the expected loan losses never materialized. The economy quickly rebounded the following quarter – growing an astonishing 38% — and the feared economic apocalypse never occurred.

In fact, two and a half years later, that second shoe still hasn’t dropped. To this day, the industry’s credit performance since the beginning of the pandemic has been uncommonly good. According to data from S&P Global Market Intelligence, net charge-offs (which is the difference between gross charge-offs and any subsequent recoveries) for the entire industry were an average of 23 basis points for 2021. Through the first six months of 2022, net charge-offs were just 10 basis points.

Surprisingly, the industry’s credit quality has remained strong even though U.S. economic growth was slightly negative in the first and second quarters of 2022. The Bureau of Economic Analysis, which tracks changes in the country’s gross domestic product, had yet to release a preliminary third quarter number when this article published. However, using its own proprietary model, the Federal Reserve Bank of Atlanta estimated in early October that U.S. GDP in the third quarter would come in at 2.9%.

This would suggest that the industry’s strong credit performance will continue for the foreseeable future. But an increasing number of economists are anticipating that the U.S. economy will enter a recession in 2023 as a series of aggressive rate increases this year by the Federal Reserve to lower inflation will eventually lead to an economic downturn. And this could render a significant change in the industry’s credit outlook, leading to what many analysts refer to as a “normalization of credit.”

So why has bank loan quality remained so good for so long, despite a bumpy economy in 2022? And when it finally comes, what would the normalization of credit look like?

Answering the first question is easy. The federal government responded to the pandemic with two major stimulus programs – the $2.2 trillion CARES Act during President Donald Trump’s administration, which included the Paycheck Protection Program, and the $1.9 trillion American Rescue Plan Act during President Joe Biden’s administration — both which pumped a massive amount of liquidity into the U.S. economy.

At the same time, the Federal Reserve’s Federal Open Market Committee cut the federal funds rate from 1.58% in February 2020 to 0.05% in April, and also launched its quantitative easing policy, which injected even more liquidity into the economy through an enormous bond buying program. Combined, these measures left both households and businesses in excellent shape when the U.S. economy rebounded strongly in the third quarter of 2020.

“You had on one hand, just a spectacularly strong policy response that flooded the economy with money,” says R. Scott Siefers, a managing director and senior research analyst at the investment bank Piper Sandler & Co. “But No. 2, the economy really evolved very quickly on its own, such that businesses and individuals were able to adapt and change to circumstances [with the pandemic] very quickly. When you combine those two factors together, not only did we not see the kind of losses that one might expect when you take the economy offline for some period of time, we actually created these massive cushions of savings and liquidity for both individuals and businesses.”

The second question — what would a normalized credit environment look like? — is harder to answer. Ebrahim Poonawala, who heads up North American bank research at Bank of America Securities, says the bank’s economists are forecasting that the U.S. economy will enter a relatively mild recession in 2023 from the cumulative effects of four rate increases by the Federal Reserve — including three successive hikes of 75 basis points each, bringing the target rate in September to 3.25%. The federal funds rate could hit 4.4% by year-end if inflation remains high, and 4.6% by the end of 2023, based on internal projections by the Federal Reserve.

“There’s obviously a lot of debate around the [likelihood of a] recession today, but generally our view is that we will gradually start seeing [a] normalization and higher credit losses next year, even if it were not for an outright recession,” Poonawala says. While a normalized loss rate would vary from bank to bank depending on the composition of its loan portfolio, Poonawala says a reasonable expectation for the industry’s annualized net charge-off rate would be somewhere between 40 and 50 basis points.

That would be in line with the six-year period from 2014 through 2020, when annual net charge-offs for the industry never rose above 49 basis points. And while loan quality has been exceptional coming out of the pandemic, that six-year stretch was also remarkably good — and remarkably stable. And it’s no coincidence that it coincides with a period when interest rates were at historically low levels. For example, the federal funds rate in January 2014 was just 7 basis points, according to the Federal Reserve Bank of St. Louis’ FRED online database. The rate would eventually peak at 2.4% in July 2019 before dropping back to 1.55% in December of that year when the Federal Reserve began cutting rates to juice a sagging economy. And yet by historical standards, a federal funds rate of even 2.4% is low.

Did this sustained low interest rate environment help keep loan losses low during that six-year run? Siefers believes so. “I don’t think there’s any question that cheap borrowing costs were, and have been, a major factor,” he says.

If interest rates do approach 4.6% in 2023 — which would raise the debt service costs for many commercial borrowers — and if the economy does tip into a mild recession, the industry’s loan losses could well exceed the recent high point of 49 basis points.

“There is a case to be made that a recession could look a bit more like the 2001-02 [downturn] in the aftermath of the dot-com bubble [bursting],” says Poonawala. “You saw losses, but it was an earnings hit for the banks. It wasn’t a capital event.”

That recession lasted just eight months and the decline in GDP from peak to trough was just 0.3%, according to the National Bureau of Economic Research. The industry’s net charge-off ratio rose to an average of 107 basis points in 2002 before dropping to 86 basis points in 2003, 59 basis points in 2004 and bottoming out at 39 basis points in 2006.

This same cyclical pattern repeated itself in 2008 — the first year of the financial crisis – when the average net charge-off rate was 1.30%. The rate would peak at 2.67% in 2010 before declining to 68 basis points in 2013 as the economy gradually recovered.

When we talk about the normalization of credit, what we’re really talking about is the return of the normal credit cycle, where loan losses rise and fall with the cyclical contraction and expansion of the economy. Banks have experienced something akin to a credit nirvana since 2014, but it looks like the credit cycle will reappear in 2023 — aided and abetted by higher interest rates and an economic downturn.

Strengthening Financial Performance in a Rising Rate Environment

Written by

Interest rate volatility has been a dominant theme this year and inflation worries have begun morphing into recession fears.

For banks, rising rates are generally a positive trend; they tend to result in higher deposit franchise values and higher net interest margins. While unrealized losses in the available for sale bond portfolio also typically increase during rising rate environments, adhering to a disciplined investment framework can help bank leaders avoid knee-jerk reactions and put unrealized losses into the right context (discussed previously here).

As rates continue to rise, it’s time to check the pulse on your institution’s pricing model. In addition to pricing assets accurately, a successful bank also focuses on funding cheaply, using a number of models to identify relative value and hedging interest rate risk when necessary. Here, we’ll dive deeper into three principles that can help institutions strengthen their financial performance.

Principle 1: Disciplined Asset Pricing
Capital requirements mean that a bank has a finite capacity to add assets to its balance sheet. Each asset going on the balance sheet must be critically evaluated to ensure it meets your institution’s specific performance goals and risk mandates.

Using a risk-adjusted return on capital (RAROC) framework for asset pricing and relative value assessment helps establish a consistent, sustainable decision-making framework for capital allocation. Clearly, different assets have different risks and returns. An effective financial manager ensures that the bank is meeting its hurdle rates, or return on capital, and that the model and assumptions are as accurate as possible.

A mispriced asset isn’t just a risk to margin. It also represents liquidation risk, as assets priced incorrectly to market perceptions of risk have a higher likelihood of poor sale performance, such as losses on sale or failure to sell. The value of the institution can also be impacted if the bank consistently — even marginally — misprices assets. Overall, if an asset is not appropriately priced for the risks and costs associated with it, then a bank should critically evaluate its role on the balance sheet.

Principle 2: The Value of Deposit Funding
Banks benefit from low-cost, sticky funding. Core deposits typically comprise the largest and cheapest funding source, followed by term and wholesale funding and all other, generally short-term, funding sources.

Understanding your funding’s beta is a key first step to unlocking better financial performance.

In this application, beta is a measurement of the relationship between a funding source’s interest rate and an observable market rate; it is the sensitivity of funding cost relative to a change in interest rates.

As rates rise, low beta funding results in greater growth in franchise value compared to high beta funding. As assets reprice to the higher rate environment, balance sheets with low beta funding will see margins steadily widen. Banks with high beta funding tend to exhibit margin compression and declining valuations. Conversely, low beta funding results in more stable valuation as rates rise.

Principle 3: Risk Management in an ALM and RAROC Framework
Borrowers and depositors maximize their own utility, which often presents a dilemma for the financial institutions that serve them. When interest rates are low, borrowers typically want long-term, fixed-rate loans and depositors keep their deposits shorter term.  When interest rates are higher, we typically see the opposite behavior: depositors begin to consider term deposits and borrowers demand more floating rate loans. This dynamic can cause mismatches in asset and liability duration, resulting in interest rate risk exposure. Banks must regularly measure and monitor their risk exposure, especially when rates are on the move.

Significant divergence from neutral rate risk — a closely aligned repricing profile of a bank’s assets and liabilities — exposes a bank’s return on equity and valuation to potential volatility and underperformance when rates move. That’s where hedging comes in. Hedging can assist a bank by reducing asset-liability mismatches, enhancing its competitiveness by locking in spread through disciplined asset pricing and stabilizing financial performance. After all, banks are in the business of lending and safekeeping funds, but must take on risk to generate return. Hedging can reduce discomfort with a bank’s existing or projected balance sheet risks and improve balance sheet strategy agility to better meet customers’ needs.

There are opportunities for banks all along the yield curve. But institutions that don’t hedge compete for assets in the crowded short duration space — often with significant opportunity costs.

Rising rates generally result in stronger margins and valuations for well-funded depositories; disciplined asset pricing in a risk-adjusted framework is critical for financial performance. As a financial professional, it’s important that the board has a firm understanding of what drives deposit franchise value. Take the time to ensure that the entire leadership team understands potential risk in your bank’s ALM composition and be prepared to hedge, if needed.

How High Inflation, High Rates Will Impact Banking

Written by

In the latest episode of The Slant Podcast, former Comptroller of the Currency Gene Ludwig believes the combination of high inflation and rising interest rates present unique risks to the banking industry. Ludwig expects that higher interest rates will lead to more expensive borrowing for many businesses while also increasing their operating costs. This could ultimately result in “real credit risk problems that we haven’t seen for some time.”

While the banking industry is well capitalized and asset quality levels are still high, Ludwig says the combination of high inflation and rising interest rates will be a challenge for younger bankers who have never experienced an environment like this before.

Ludwig knows a lot about banking, but his journey after leaving the Comptroller of the Currency’s office has been an interesting one. After completing his five-year term as comptroller in 1998, Ludwig could have returned to his old law firm of Covington & Burling LLP and resumed his legal practice. Looking back on it, he says he was motivated by two things. One was to put “food on the table” for his family because he left the comptroller’s office “with negative net worth – [and] it was negative by a lot.”

His other motivation was to find ways of fixing people’s problems from a broader perspective than the law sometimes allows. “I love the practice of law,’’ he says. “It’s intellectually satisfying.” But from his perspective, the law is just one way to solve a problem. Ludwig says he was looking for a way to “solve problems more broadly and bring in lawyers when they’re needed.” This led to a prolonged burst of entrepreneurial activity in which Ludwig established several firms in the financial services space. His best known venture is probably the Promontory Financial Group, a regulatory consulting firm that he eventually sold to IBM.

Ludwig’s most recent initiative is the Ludwig Institute for Shared Economic Prosperity, which he started in 2019. Ludwig believes the American dream has vanished for many median- and low-income families, and the institute has developed a new metric which makes a more accurate assessment of how inflation is hurting those families than traditional measurements such as the Consumer Price Index — which he says drastically understates the impact.

Ludwig hopes the Institute’s work gives policymakers in Washington, D.C., a clearer sense of how desperate the situation is for millions of American families and leads to positive action.

This episode, and all past episodes of The Slant Podcast, are available on Bank Director, Spotify and Apple Music.

Tips for Banks to Navigate Top Risks in 2022

Written by

Banks continue to meet unprecedented challenges of the Covid-19 pandemic, geopolitical cyberthreats and increasing public awareness of environment, social and governance (ESG) issues.

With the current landscape posing ever-evolving risks for banks, Moss Adams collaborated with Bank Director to conduct the 2022 Risk Survey and explore what areas are front of mind for bank industry leaders. Top insights from Bank Director’s 2022 Risk Survey include that the vast majority of survey respondents reported that cybersecurity and interest rate risks pose increasing concerns, and they expect these challenges to persist in the second half of the year, due to turbulent economic and geopolitical conditions. The survey also identified that banks increasingly focus on issues related to compliance and regulatory risks.

Cybersecurity Oversight
Concerns about cybersecurity topped the survey responses: 93% of respondents stated that a need for increased cybersecurity grew significantly or somewhat. Bank executives and board members submitted survey responses in January, prior to heightened federal government warnings of increased Russian cyberattacks. Banks’ concerns will likely continue to increase as a result.

Data Breach Rates and Precautions
While only 5% of respondents reported experiencing a data breach or ransomware attack at their own institution in the years 2020 and 2021, 65% reported data breaches at their bank’s vendors. In response, 60% stated they updated their institution’s third-party vendor management policies, processes, or risk oversight.

As a critical U.S. industry, banks follow stringent regulatory requirements for data security. The Federal Financial Institutions Examination Council (FFIEC) cybersecurity assessment tool provides a maturity model for banks to assess their cybersecurity maturity as baseline, evolving, intermediate, advanced or innovative. Ninety percent of respondents completed a cybersecurity assessment over the past 12 months; 61% used the FFIEC’s tool in combination with other methodologies, and another 19% only used the FFIEC’s tool. And 83% of respondents said that the maturity of their bank’s cybersecurity program increased in 2021, compared to previous assessments.

Room for Improvement
Banks noted several areas of improvement for their cybersecurity programs, including training for bank staff (83%), technology to better detect and deter cyberthreats and intrusions (64%) and internal controls (43%). Thirty-nine percent believe they need to better attract and retain quality cybersecurity personnel. Banks’ investments in cybersecurity programs remained flat compared to the 2021 survey, with a median budget of $200,000.

As cybersecurity risks increase, banks should focus on researching and making appropriate investments, as well as implementing comprehensive planning for staff training, technology and governance. At the board level, respondents noted several activities as part of that body’s oversight of the cybersecurity risk management program. Key among these is board-level training (79%), ensuring continual improvements by management of their cybersecurity programs (75%) and being aware of any deficiencies in the bank’s cybersecurity program (71%).

Interest Rate Risk Concerns
The prospect of rising interest rates fueled anxiety for our respondents: 71% noted increased concern. As the Federal Open Market Committee combats higher inflation by hiking interest rates, 74% reported hoping that they wouldn’t raise rates by more than one percentage point by the end of 2022 — which is currently below what’s projected.

Faced with likely rate hikes, banks are looking to their own business models to navigate a potential decrease in overall lending volume and potential pressure on profit margins. Respondents also noted that they were increased their focus in sectors such as commercial and industrial, commercial real estate and construction, or with the Small Business Administration or obtaining other small business loans.

ESG Initiatives
Banks are under increasing pressure to adopt ESG initiatives. More than half of respondents don’t yet focus on ESG issues in a comprehensive manner, and regulators have yet to impose ESG requirements for banks. However, more than half of survey respondents say they have set goals and objectives in a variety of ESG-related areas, primarily in the social and governance verticals — employee development and community needs in particular topped the list.

Only 6% said that investors or other company stakeholders currently look for more disclosure around ESG initiatives, with diversity, equity and inclusion topping the list at 88%. Banks that haven’t established ESG strategies could first identify their top priority areas. These priorities may vary for each organization and will need to consider the values of investors, customers and local community.