What Silicon Valley Bank’s Failure Means for Incentive Compensation

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The day Silicon Valley Bank failed on March 10, the bank paid out millions in bonuses to senior executives for its 2022 performance, according to the Federal Reserve’s April postmortem analysis and the bank’s proxy statement. Those bonuses were paid despite ongoing regulatory issues, including a May 2022 enforcement action.

As details trickle out about Silicon Valley Bank’s and Signature Bank’s failures, it’s becoming clear that regulators are interested in greater regulation and scrutiny of incentive plans. 

Among key risk management gaps, Federal Reserve Vice Chair for Supervision Michael Barr found fault in Silicon Valley Bank’s board compensation committee, noting that holding company SVB Financial Group’s “senior management responded to the incentives approved by the board of directors; they were not compensated to manage the bank’s risk, and they did not do so effectively.” Further, he wrote in the Fed’s April report: “We should consider setting tougher minimum standards for incentive compensation programs and ensure banks comply with the standards we already have.” 

It’s likely that supervisors will revisit examinations for banks between $50 billion and $250 billion in assets, which received regulatory relief following the 2018 rollback, says Todd Leone, a partner at the compensation firm McLagan. But supervisors recognized deficiencies in SVB’s incentive compensation governance prior to its failure, Barr revealed. Changes — via legislation and enhanced supervision — may occur, along with the finalization of incentive compensation and clawback rules coming out of the 2010 Dodd-Frank Act. 

Following the failures of Silicon Valley Bank and Signature Bank, lawmakers including U.S. Sen. Gary Peters, D-Mich., urged regulators to finalize Section 956 of Dodd-Frank, which requires regulators to issue rules for institutions above $1 billion in assets around the prohibition of excessive incentive compensation arrangements that encourage inappropriate risks, and mandate disclosure of incentive compensation plans to a bank’s federal regulator. Leone says that the rule was proposed with credit risk in mind, but its application could be expanded to consider liquidity.

The agencies tasked with this joint rulemaking, which include the Federal Deposit Insurance Corp., Federal Reserve, and the U.S. Securities and Exchange Commission, issued a request for comment on a proposed rule in 2016.

For public banks, the SEC finally released its clawback rule tied to Dodd-Frank in 2022. Put simply, the rule will require public companies to adopt policies that allow for the recovery of compensation in certain scenarios, including earnings restatements. The policy must be disclosed. Troutman Pepper expects that companies will have to comply as early as August. Gregory Parisi, a partner at the law firm, believes additional scrutiny on clawback policies will trickle down through the industry to smaller banks.

Clawback policies should cover numerous scenarios. “If the only triggers you have are tied to financial restatements, then it’s probably not broad enough,” says Daniel Rodda, a partner at Meridian Compensation Partners.

U.S. Sen. Elizabeth Warren, D-Mass., and U.S. Rep. Josh Hawley, R-Mo., introduced legislation on March 29 that would authorize the FDIC to claw back compensation when a bank fails.

Beyond the Dodd-Frank rules, banks should consider how to strengthen their governance practices to better tie compensation to risk. “… Incentive compensation arrangements should be compatible with effective risk management and controls,” wrote Barr in April, citing the 2010 Interagency Guidance on Sound Incentive Compensation Policies. Those arrangements “should be supported by strong corporate governance practices, including active and effective oversight by boards of directors,” he added.

Barr also pointed out that SVB’s compensation committee didn’t receive performance evaluation materials from CEO Greg Becker, relying instead on his recommendations. 

“There can be times where [the board relies] on a verbal discussion around performance with the CEO,” says Rodda, “but having it documented in the materials and making sure that those performance evaluation materials include commentary from risk as part of the performance evaluation, those are certainly good processes to have in place.”

SVB said risk management was a “key component of compensation decisions” in its proxy statement filed on March 3, just days before the bank’s failure, but listed return on equity, total shareholder return and stock price appreciation as specific measurements for 2022 incentive payments. 

Rodda recommends that boards consider a combination of metrics that include capital ratios and risk-adjusted returns — not just profitability and growth — and incorporate qualitative approaches that could consider feedback from regulators and an overall view of risk management.

On May 31, 2022, supervisors flagged SVB’s incentive compensation process as a Matter Requiring Immediate Attention (MRIA) by the board, ordering the compensation committee to develop “mechanisms to hold senior management accountable for meeting risk management expectations.” SVB’s compensation committee was in the process of changing its incentive structure and approved bonuses in January 2023 that were paid out in March despite the bank’s dramatic deposit loss, according to the Barr report. 

“There should be a structured opportunity within the incentive program to evaluate the effectiveness of risk management,” says Rodda. “And if there are items that have been flagged by the regulators as critical and indicate that risk is not being managed well, then the committee should use its judgment to impact payouts based on that.”

Compensation issues like these will be covered during Bank Director’s Bank Board Training Forum in Nashville, Sept. 11-12, 2023.

This article was updated to correct a reference to Section 956.

Banking’s March Madness Postgame

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After every significant banking crisis, it becomes clear what transpired and how it could have been avoided.

There are two key takeaways from the March bank failures that directors and their senior management team should capitalize on. They should put on a new set of lens and take a fresh look at:

  1. Enterprise risk management practices.
  2. Liquidity risk measurement and management.

What happened in March resulted mainly from a breakdown in management and governance. It is a reminder that risk management is highly interconnected among liquidity, interest rate, credit, capital and reputation risks. Risk management must be a mindset that permeates the entire institution, is owned by the c-suite and is understood by the board.

Here are a few things for directors to ponder while revisiting enterprise risk management governance:

  • Be realistic about potential risks. Listen to, and address, data-driven model outcomes. Refrain from influencing results to reflect a preferred narrative.
  • Understand key assumptions and their sensitivities. Assumptions matter.
  • Bring data to the surface and breathe life into it; value data analytics.
  • Accept that the days of “set it and forget it” policy limits and assumptions are over.
  • Revisit attitudes regarding validating risk management processes and models: Are they a check the box “exercise” or a strategically important activity?
  • Ask what could go wrong and what should we monitor? How thorough and realistic are preemptive and contingency strategies?
  • Acknowledge that stress testing is not for bad times — by then, it’s too late.
  • Cultivate an environment of productive, effective challenge.

Banks and their asset/liability management committees are under stronger regulatory microscopes. They will be asked to defend risk management culture, processes, risk assessments, strategies and overall risk governance. Be prepared.

Telling Your Liquidity Management Story
The March bank failures accentuated the critical importance of an effective liquidity management process — not just in theory, but in readiness practice. Your institution’s liquidity story matters.

Start with your liquidity definition. Most define liquidity by stating a few key ratios they monitor – but that’s not expressing one’s liquidity philosophy. Bankers struggle to put their liquidity definition into words, which can lead to an inadvertent focus on ratios that conflict with actual philosophy. This can result in suboptimal outcomes and unintended consequences. One definition banks could adopt is: “Liquidity is my bank’s ability to generate cash quickly, at a reasonable cost, without having to take losses.”

A bank can readily construct a productive framework around a meaningful definition. Given the notoriety around unrealized losses on assets and potentially volatile deposits, be clear that how the bank manages its liquidity does not depend on selling assets.

Construct a liquidity framework that supports this notion with four elements:

  1. Funding diversification.
  2. Concentration and policy limits.
  3. Collateral management.
  4. Stress testing and contingency planning.

Funding diversification should consider Federal Home Loan Bank, Federal Reserve programs, repurchase agreements (repos), brokered and listing service deposits and fed funds lines. The ability to manage larger relationships with insured deposit programs, such as reciprocal and one-way, FHLB letters of credit and customer repos is also an integral part of funding diversification. Make sure your institution tests all sources periodically and understand settlement timelines.

Funding concentrations must be on your radar. The board and executives need to establish policy limits for all wholesale deposit and borrowing sources, by type and in aggregate. There should also be limits that apply to specific customer deposit types such as public, specialty/niche, reciprocal and others. The bank should track and monitor uninsured deposits, especially those that are tied to broader, larger relationships, and reflect that in operating and contingency liquidity plans. Take a deep dive into your bank’s deposit data; there is a significant difference between doing a core deposit study and studying your deposits.

Collateral doesn’t matter unless it is readily available for use. Ensure all available qualifying loan and security collateral are pledged to the FHLB and Fed. Determine funding availability from each reliable source and monitor capacity relative to uninsured deposits, especially the aggregate of “whale” accounts.

Also, understand how each funding source could become restricted. Ensure your contingency liquidity management process captures this with well-defined stress tests that simulate how quickly, and to what degree, a liquidity crisis could materialize. Understand what it would take to break the bank’s liquidity, and ensure that key elements fueling this event are monitored and preemptive strategies are clearly identified.

Step back and look at your institution’s risk management policies, keeping in mind that they can become unnecessarily restrictive, despite good intentions. Avoid using “if, then” statements that force specific actions versus a thoughtful consideration of alternative actions. Your bank needs appropriately flexible policies with guardrails, not straightjackets.

The conversation on risk management and related governance at banks needs to change. Start with a fresh set of lens and a willingness to challenge established collective wisdom. Dividends will accrue to banks with the strongest risk management cultures and frameworks, with an appreciation for the important role of assumption sensitivity and overall stress testing. Ensure that clarity drives strategy — not fear.

Dusting Off Your Asset/Liability Management Policies

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Directors reviewing their bank’s asset/liability management policy in the wake of recent bank failures should avoid merely reacting to the latest crisis.

Managing the balance sheet has come under a microscope since a run on deposits brought down Silicon Valley Bank, the banking subsidiary of SVB Financial Group, and Signature Bank, leading regulators to close the two large institutions. While most community banks do not have the same deposit concentrations that caused these banks to fail, bank boards should ask their own questions about their organization’s asset/liability strategies.

A bank’s asset/liability management policy spells out how it will manage a mismatch between its assets and liabilities that could arise from changing interest rates or liquidity requirements. It essentially provides the bank with guidelines for managing interest rate risk and liquidity risk, and it should be reviewed by the board on an annual basis.

“With both Silicon Valley Bank and Signature Bank, you had business models that were totally different from a regular bank, whether it’s a community bank, or a regional or even a super regional, the composition of their asset portfolios, the composition of their funding sources, were really different,” says Frank “Rusty” Conner, a partner at the law firm Covington & Burling. “Anytime you have a semi-crisis or crisis like we’ve had, you’re going to reassess things.”

Conner identifies three key flaws at play today that mirror the savings and loan crisis of the 1980s and 90s: an over-concentration in certain assets, a mismatch between the maturities of assets and liabilities, and waiting too long to recognize losses.

Those are all lessons that directors should consider when they revisit their bank’s asset/liability management policies and programs, he says.“Is there any vulnerability in our policies that relates to concentration or mismatch, or failing to address losses early?”

In order to do that, directors need to understand their bank’s policies well enough to ask intelligent and challenging questions of the bank’s management. The board may or may not have that particular subject matter expertise on its risk, audit or asset/liability committee, or in general, says Brian Nappi, a managing director with Crowe LLP.

“I don’t think there’s a deficiency in policies per se,” he adds. “It’s the execution.”

Nappi recommends that boards seek to “connect the dots” between their company’s business strategy and how that could fare in a changing interest rate environment.

Conner raises a similar point, questioning why some banks had so much money invested in government securities when the Federal Reserve was telegraphing its intent to eventually raise interest rates.

“That whole issue just looks so clear in hindsight now, and maybe that’s unfair,” he says. “But why is it that we didn’t anticipate that, and are we in a better position today to anticipate similar types of developments in the future?”

Boards could consider bringing in an outside expert to review the asset/liability management policy, says Brandon Koeser, a senior analyst with RSM US. A fresh set of eyes, such as an accounting firm, consultant or even a law firm, can help the board understand if its framework is generally in line with other institutions of its size and whether it’s keeping pace with changes in the broader economy.

“You also want to think about the [asset/liability management] program itself, separate from the policy, and how often you’re actually going through and reviewing to make sure that it’s keeping pace with change,” Koeser adds.

Steps to Take: Revisiting the Asset/Liability Management Policy

  • Establish and understand risk limits.
  • Consider how to handle policy exceptions.
  • Define executive authority for interest rate risk management.
  • Outline reports the board needs to monitor interest rate risk.
  • Establish the frequency for receiving those reports.
  • Evaluate liquidity risk exposure to adverse scenarios.
  • Understand key assumptions in liquidity stress testing models.
  • Review guidelines around the composition of assets and liabilities.
  • Monitor investment activities and performance of securities.
  • Review contingency funding plans.

Directors should also ask management about any liquidity stress testing the bank may be engaging in. Do directors fully understand the key assumptions in the bank’s stress testing models, and do they grasp how those key assumptions could change potential outcomes?

And if executives tell the board that the bank’s balance sheet can withstand a 30% run off of deposits in a short period of time, directors shouldn’t be satisfied with that answer, says Matt Pieniazek, CEO of Darling Consulting Group, a firm that specializes in asset/liability management. The board should press management to understand exactly how bad losses would need to be to break the bank.

“Directors don’t know enough to ask the question sometimes. They’re afraid to show their stress testing breaking the bank,” he says. “They need to have the opposite mindset. You need to understand exactly what it would take to break the bank. What would it take to create a liquidity crisis? How bad would it have to get?”

Sometimes policies tend to be too rigid or not descriptive enough, adds Pieniazek.

“The purpose of policies is not to put straighBtjackets around people,” he says. “If you have to look to policies for guidance, you want to make sure that they have an appropriate amount of flexibility and not too much unnecessary restrictiveness.”

Many banks’ policy limits concerning the use of wholesale funding — such as Federal Home Loan Bank advances and brokered deposits — are too strict and unnecessarily constrained, Pieniazek says. “A lot of them will have limits, but they’re inadequate or the limits are not sufficient, both individually and in the aggregate.”

An example of this might be a policy that stipulates the bank can tap FHLB funding for up to 25% of its assets and the Federal Reserve discount window for up to 15% but restricts the bank from going above 35% in the aggregate.

Along those lines, directors should make sure management can identify all qualifying collateral the bank might use to borrow from the Federal Reserve or FHLB, taking into account collateral that may have been pledged elsewhere. And directors should revisit any overly rigid policies that could tie executives’ arms in a liquidity crunch. A policy stipulating that a bank will sell securities first may prove too inflexible if it means having to sell those securities at a loss, for instance.

A board will also want to understand whether its asset/liability management plan considers the life cycle of a possible bank run. In that kind of scenario, how much would the bank depend upon selling assets in order to meet those liquidity needs? And what’s the plan if some of its securities are underwater when that happens?

While the most recent banking crisis doesn’t necessarily mean bank boards need to overhaul their asset/liability management policies, they should at least review those policies with some key questions and lessons in mind.

“If your regulator comes in, and they see dust on the cover of the ALM policy,” says Koeser, “and they see that the liquidity stress test or scenario analysis aren’t appropriately incorporating shocks or stressors, it could be a difficult conversation to have with your regulator on why there weren’t changes.”

Additional Resources
Bank Director’s Board Structure Guidelines include a resource focused on ALCO Committee Structure. The Online Training Series includes units on managing interest rate risk and model validation. For more about stress testing to incorporate liquidity, read “Bank Failures Reveal Stress Testing Gaps.”

2023 Risk Survey Results: Deposit Pressures Dominate

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In 2023, the overarching question on bank leaders’ minds is how their organization will fare in the next crisis.

That manifested in increased concerns around interest rates, liquidity, credit and consumer risk, and other issues gauged in Bank Director’s 2023 Risk Survey, sponsored by Moss Adams LLP. The survey was fielded in January, before a run on deposits imperiled several institutions and regulators began closing banks in March, including $209 billion SVB Financial Corp.’s Silicon Valley Bank.

Well before this turmoil, bank executives and board members were feeling the pressure as the Federal Open Market Committee raised rates, leading bankers to selectively raise deposit rates and control their cost of funds. Over the past year, respondent concerns about interest rate risk (91%), credit risk (77%) and liquidity (71%) all increased markedly. Executives and directors also identify cybersecurity (84%) and compliance (70%) as areas where their concerns have increased, but managing the balance sheet has become, by and large, their first priority.

Bank leaders name deposit pricing (51%) and talent retention (50%) among the top strategic challenges their organization faces in 2023. Sixty-one percent say their bank has experienced some deposit loss, with minimal to moderate impacts on their funding base, and another 11% say that deposit outflows had a significant impact on their funding base.

Net interest margins improved for a majority (53%) of bank leaders taking part in the survey, but respondents are mixed about whether their bank’s NIM will expand or contract over 2023.

Three-quarters of bank executives and board members report that business clients remain strong in spite of inflation and economic pressures, although some are pausing growth plans. As commercial clients face increasing costs of materials and labor, talent pressures and shrinking revenues, that’s having an impact on commercial loan demand, some bankers say. And as the Federal Reserve continues to battle inflation against an uncertain macroeconomic backdrop, half of respondents say their concerns around consumer risk have increased, a significant shift from last year’s survey.

Key Findings

Deposit Pressures
Asked about what steps they might take to manage liquidity, 73% of executives and directors say they would raise interest rates offered on deposits, and 62% say they would borrow funds from a Federal Home Loan Bank. Less favored options include raising brokered deposits (30%), the use of participation loans (28%), tightening credit standards (22%) and using incentives to entice depositors (20%). Respondents say they would be comfortable maintaining a median loan-to-deposit ratio of 70% at the low end and 90% at the high end.

Strategic Challenges Vary
While the majority of respondents identify deposit pricing and/or talent retention as significant strategic challenges, 31% cite slowing credit demand, followed by liquidity management (29%), evolving regulatory and compliance requirements (28%) and CEO or senior management succession (20%).

Continued Vigilance on Cybersecurity
Eighty-seven percent of respondents say their bank has completed a cybersecurity assessment, with most banks using the tool offered by the Federal Financial Institutions Examination Council. Respondents cite detection technology, training for bank staff and internal communications as the most common areas where they have made changes after completing their assessment. Respondents report a median of $250,000 budgeted for cybersecurity-related expenses.

Stress On Fees
A little over a third (36%) of respondents say their bank has adjusted its fee structure in anticipation of regulatory pressure, while a minority (8%) did so in response to direct prodding by regulators. More than half of banks over $10 billion in assets say they adjusted their fee structure, either in response to direct regulatory pressure or anticipated regulatory pressure.

Climate Discussions Pick Up
The proportion of bank leaders who say their board discusses climate change at least annually increased over the past year to 21%, from 16% in 2022. Sixty-one percent of respondents say they do not focus on environmental, social and governance issues in a comprehensive manner, but the proportion of public banks that disclose their progress on ESG goals grew to 15%, from 10% last year.

Stress Testing Adjustments
Just over three-quarters of respondents say their bank conducts an annual stress test. In comments, offered before the Federal Reserve added a new component to its stress testing for the largest banks, many bank leaders described the ways that they’ve changed their approach to stress testing in anticipation of a downturn. One respondent described adding a liquidity stress test in response to increased deposit pricing and unrealized losses in the securities portfolio.

To view the high-level findings, click here.

Bank Services members can access a deeper exploration of the survey results. Members can click here to view the complete results, broken out by asset category and other relevant attributes. If you want to find out how your bank can gain access to this exclusive report, contact [email protected].

2023 Risk Survey: Complete Results

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Bank Director’s 2023 Risk Survey, sponsored by Moss Adams LLP, finds interest rates and liquidity risk dominating bank leaders’ minds in 2023.

The survey, which explores several key risk areas, was conducted in January, before a run on deposits imperiled several institutions, including $209 billion SVB Financial Corp., which regulators closed in March. Bank executives and board members were feeling pressure on deposit costs well before that turmoil, as the Federal Open Market Committee raised the federal funds rate through 2022 and into 2023.

Over the past year, respondent concerns about interest rate risk (91%), credit risk (77%) and liquidity (71%) all increased markedly. Executives and directors also identify cybersecurity and compliance as areas where their concerns have increased, but managing the balance sheet has become, by and large, their first priority.

Bank leaders name deposit pricing as the top strategic challenge their organization faces in 2023, and a majority say their bank has experienced some deposit loss, with minimal to significant impacts on their funding base. Most respondents say their No. 1 liquidity management strategy would be to raise the rates they pay on deposits, followed by increasing their borrowings from a Federal Home Loan Bank.

While SVB operated a unique business model that featured a high level of uninsured deposits and a pronounced concentration in the tech industry, many banks are facing tension as deposits reprice faster than the loans on their books.

Net interest margins improved for a majority of bank leaders taking part in the survey, but respondents are mixed about whether their bank’s NIM will expand or contract over 2023.

Click here to view the complete results.

Key Findings

Deposit Pressures
Asked about what steps they might take to manage liquidity, 73% of executives and directors say they would raise interest rates offered on deposits, and 62% say they would borrow funds from a Federal Home Loan Bank. Less favored options include raising brokered deposits (30%), the use of participation loans (28%), tightening credit standards (22%) and using incentives to entice depositors (20%). Respondents say they would be comfortable maintaining a median loan-to-deposit ratio of 70% at the low end and 90% at the high end.

Strategic Challenges Vary
While the majority of respondents identify deposit pricing and/or talent retention as significant strategic challenges, 31% cite slowing credit demand, followed by liquidity management (29%), evolving regulatory and compliance requirements (28%) and CEO or senior management succession (20%).

Continued Vigilance on Cybersecurity
Eighty-seven percent of respondents say their bank has completed a cybersecurity assessment, with most banks using the tool offered by the Federal Financial Institutions Examination Council. Respondents cite detection technology, training for bank staff and internal communications as the most common areas where they have made changes after completing their assessment. Respondents report a median of $250,000 budgeted for cybersecurity-related expenses.

Stress On Fees
A little over a third (36%) of respondents say their bank has adjusted its fee structure in anticipation of regulatory pressure, while a minority (8%) did so in response to direct prodding by regulators. More than half of banks over $10 billion in assets say they adjusted their fee structure, either in response to direct regulatory pressure or anticipated regulatory pressure.

Climate Discussions Pick Up
The proportion of bank leaders who say their board discusses climate change at least annually increased over the past year to 21%, from 16% in 2022. Sixty-one percent of respondents say they do not focus on environmental, social and governance issues in a comprehensive manner, but the proportion of public banks that disclose their progress on ESG goals grew to 15%, from 10% last year.

Stress Testing Adjustments
Just over three-quarters of respondents say their bank conducts an annual stress test. In comments, offered before the Federal Reserve added a new component to its stress testing for the largest banks, many bank leaders described the ways that they’ve changed their approach to stress testing in anticipation of a downturn. One respondent described adding a liquidity stress test in response to increased deposit pricing and unrealized losses in the securities portfolio.

Community Bankers Emphasize Calmness, Stability Amid Crisis

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You can’t communicate too much during a banking crisis – even when your bank is not the one actually experiencing the crisis.

After regulators shut down SVB Financial Group’s Silicon Valley Bank and Signature Bank two weeks ago, community bankers across the nation began working behind the scenes to field questions from their boards, their clients and their frontline staff. They checked their access to the Federal Reserve’s discount window and sought to reassure customers and directors of their own institution’s liquidity position.

Locality Bank, a de novo bank based in Fort Lauderdale, Florida, still has ample liquidity from its capital raising efforts and simply by virtue of being a new bank. The $116 million Locality, which first opened a little over a year ago, reiterated these points in a letter it sent out to clients the day after Silicon Valley Bank was closed by state regulators, CEO Keith Costello says.

“We don’t have a portfolio of low-interest securities or loans,” the letter reads in part. “We have capital of almost three times the level required to have a well-capitalized rating, and our liquidity ratio at 54.17% at month end of February is one of the strongest in the U.S. Our securities portfolio, because we bought our securities when rates went up, has no appreciable decline in value.”

That letter went a long way toward assuaging customer fears around the ongoing banking crisis, Costello says, adding, “We just got a tremendous response from clients who emailed, who called, who just said, ‘Hey, we love that letter. We feel so much better about everything.’”

Communicating with frontline staff has also been critical, says Julieann Thurlow, CEO of Reading Cooperative Bank in Massachusetts. Not only are those workers spending a lot of time interacting with customers, but they also may have their own questions about how ongoing events impact their livelihoods.

“Not every teller reads The Wall Street Journal,” Thurlow says. “So make sure that you actually communicate with them as well because there was a level of uncertainty … ‘Is the banking community in trouble?’”

Some community bankers also took to social media to get the word out, including Jill Castilla, CEO of $358 million Citizens Bank of Edmond. Since the March 12 failure of Silicon Valley Bank, Castilla has taken to Twitter and LinkedIn to provide a rundown of the crisis and explain how Silicon Valley Bank and Signature differed from a typical community bank.

Even larger banks whose stocks have taken a hit sought to distance themselves from those banks. Phil Green, CEO of Cullen/Frost Bankers in San Antonio, Texas, took to CNBC to discuss the subsidiary Frost Bank’s liquidity position. The $53 billion Frost Bank CEO told “Mad Money” host Jim Cramer that the bank has a low loan-to-deposit ratio and roughly 20% of its deposits are held in highly liquid accounts at the Federal Reserve.

Even though Cullen/Frost Bankers’ stock price has taken a hit this year — down more than 10% since Silicon Valley Bank failed, mirroring the fall in the KBW Nasdaq Bank Index this year — Green expressed confidence in the long term.

“Frost Bank’s deposit base has been very strong,” he said, adding “We’ve seen really no unusual activity.”

While Reading Cooperative already tests its liquidity lines on a quarterly basis, the $796-million bank double-checked its access to the Federal Reserve’s discount window after Silicon Valley Bank failed.

“We could almost refinance the entire bank with our liquidity lines,” she says.

Meanwhile, Costello says that a handful of customers made their accounts joint accounts in order to get coverage from the Federal Deposit Insurance Corp., and he said that Locality also tapped its cash service with IntraFi, a privately held deposit placement firm, for the first time. He also added that Locality’s messaging around the crisis and its own liquidity position and relative stability resonated with non-customers, too.

“You find people that aren’t your clients will call you at times like this, too,” Costello says. “We did actually pick up some business as a result.”

Other community bankers also reported a similar experience picking up new business in the crisis. In a post on LinkedIn, Castilla reported that deposits continued to increase at her bank and “my lobby today is full of happy customers!”

Thurlow says Reading Cooperative picked up a few new larger accounts, although she was also cautious not to characterize that as a “flight to safety.”

“It’s not something that we’re marketing or looking to capitalize on,” she says. “This is a time for calm. We’re not looking to create or exacerbate a problem.”

Will Regulators’ Actions Stem Deposit Runs, Banking Crisis?

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Bank regulators rolled out several tools from their tool kit to try to stem a financial crisis this week, but problems remain. 

The joint announcements followed the Friday closure of Silicon Valley Bank and the surprise Sunday evening closure of Signature Bank. 

Santa Clara, California-based Silicon Valley Bank had $209 billion in assets and $175 billion in deposits at the end of 2022 and went into FDIC receivership on March 10; New York-based Signature Bank had $110 billion in assets and $88.6 billion in deposits at the end of 2022 and went into receivership on March 12. Both banks failed without an acquiring institution and the FDIC has set up bridge banks to facilitate their wind downs.

Bank regulators determined both closures qualified for “systemic risk exemptions” that allowed the Federal Deposit Insurance Corp. to cover all the deposits for the failed banks. Currently, deposit insurance covers up to $250,000; both banks focused mainly on businesses, which carry sizable account balances. About 94% of Silicon Valley’s deposits were uninsured, and 90% of Signature’s deposits were over that threshold, according to a March 14 article from S&P Global Market Intelligence.

The systemic risk exemption means regulators can act without Congressional approval in limited situations to provide insurance to the entire account balance, says Ed Mills, managing director of Washington policy at the investment bank Raymond James. 

The bank regulators also announced a special funding facility, which would help banks ensure they have access to adequate liquidity to meet the demands of their depositors. The facility, called the Bank Term Funding Program or BTFP, will offer wholesale funding loans with a duration of up to one year to eligible depository institutions that can pledge U.S. Treasuries, agency debt and mortgage-backed securities and other qualifying assets as collateral. The combined measures attempt to stymie further deposit runs and solve for the issue that felled Silicon Valley and Signature: a liquidity crunch. 

In a normal operating environment, banks would sell bonds from their available-for-sale securities portfolio to keep up with liquidity demands, whether that’s deposit outflows or additional lending opportunities. Rising rates over the last five quarters means that aggregate unrealized losses in securities portfolios grew to $620 billion at the end of 2022 — losses many banks want to avoid recording. In the case of Silicon Valley, depositors began to pull their money after the bank announced on March 8 it would restructure its $21 billion available-for-sale securities portfolio, booking a $1.8 billion loss and requiring a $2 billion capital raise. 

“The BTFP will be an additional source of liquidity [borrowed] against high-quality securities, eliminating an institution’s need to quickly sell those securities in times of stress,” the Federal Reserve said in its release on the facility. Importantly, the pledged collateral, such as U.S. Treasurys, will be valued at par. That is the “most beneficial portion” of the program and eliminates the discount many of these securities carry given their lower yields, Mills says. 

The hope is that banks pledge their underwater bonds to increase their liquidity should deposits begin to leave their institution. One concern, then, is that banks hesitate to use it as a sign of weakness, Mills says. But he says, “conversations about impacts to earnings and impacts to reputation are secondary to solvency.”

Former Comptroller of the Currency Gene Ludwig tells Bank Director that he appreciates the steps the regulators took, and of President Joe Biden’s messaging that accompanied Sunday’s actions. 

“I realized that for the regulators, because of the speed and the need to react quickly and over a weekend, there was a lot of wood to chop,” he says. “ It takes time, but I think they reacted with vigor.”

Although he wasn’t at the FDIC, Ludwig’s career touches on the importance of deposit coverage. In addition to serving as comptroller in the 1990s, he founded and later sold IntraFi, a reciprocal deposit network. He encourages banks to at least establish lines to the BTFP, since the application and transfers can take time.

It remains to be seen whether regulator actions will be enough to assuage depositors and the broader public. Banks have reportedly borrowed $11.9 billion from the new facility and another $152.8 billion from the discount window, according to a Bloomberg article published the afternoon of March 16. However, the facilities don’t fully address the problem that most banks are carrying substantial unrealized losses in their bond books — which may only continue to grow if the Federal Open Market Committee continues increasing rates.

“This announcement was about stemming the immediate systemic concerns, but it absolutely did not solve all of the banks’ woes,” Mills says.

It’s also possible that those tailored actions may be insufficient for certain institutions that resemble Silicon Valley Bank or Signature Bank. Clifford Stanford, an Atlanta-based partner of law firm Alston & Bird and a former assistant general counsel at the Federal Reserve Bank of Atlanta, remembers how bank failures and weakness would come in waves of activity during the Great Recession and afterward. 

“There’s a lot of unknowns about who’s got what holes in their balance sheet and who’s sitting on what problems,” he says. “Every board of every bank should be asking their management right now: Do we have this problem? If we do have a risk, how are we hedging it? What sort of options do we have to backstop liquidity? What’s our plan?”

A Tax Savvy Solution for Addressing Liquidity Needs

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Supernova Technology’s Loan Operations Manager, Austin Mead, recently shared trends, and insights that he has seen during tax time, as well as tips on how banks can support their clients as they navigate what solutions are available to them for paying their tax bill.

There is a growing trend of clients expecting more from their financial advisor. The share of investors looking to simplify their financial relationships by having banking and wealth management under one roof has risen from 13% in 2018 to 22% in 2021, according to consultancy McKinsey & Co. It’s increasingly important that banks take a holistic approach and have a wide range of solutions. Clients are looking for more than investment advice; they are looking for proactive tax planning, estate planning and debt planning, to name a few.

A Trending Solution for Taxes
Mead recalls the record number of service requests and new lines or draws that Supernova saw the last couple of years during tax time, particularly last year. “We saw about 50% of all draw requests being used for tax payments from April 1 to April 18.” Since 2020, each tax season has gotten busier and busier for his team. “New lines and balances were growing daily due to the reactive demand for a securities-based line of credit or SBLOC, which was mostly driven by capital gain tax obligations.”

Mead says he’s concerned about the down market but was still optimistic since Supernova data is still showing a steady increase for the first several weeks of the year — though not quite as high as last year.

Typically, in a down market, many advisers encourage their clients to hold on to their investments and ride it out verses selling them off, staying true to investing for the long-term strategy. Regardless of what strategy a client may have, if a client has liquidity needs, securities-based lending has been a trending solution banks can recommend at tax time. When talking about the measures Supernova’s partners put in place to ensure their clients avoid elevated risk, Mead says lending partners have proactive credit policies in place to hedge against their clients falling into a collateral call. Advisers are also in close communication with their clients through the adviser and client portals.

“Advisers can have educated conversations with their clients about where their portfolio stands versus the outstanding loan balance. Having insight to advance rates on certain securities plays a huge role in those conversations around rebalancing, paying down the loan, and even raising cash,” he says.

Mead says the top three most common reasons clients open or use a line during tax season is general liquidity, followed by strategic ways to avoid capital gains from the market and capital gains from real estate sales over the past few years. After the beginning of the year, there is a steady increase for line openings and/or usage through Tax Day, but he says the most active time period was April, leading up to Tax Day.

As Mead says, since the beginning of the year, there has been a steady, weekly increase in line opening and usage. It’s important banks start having conversations early with clients to ensure they are prepared for Tax Day and have access to liquidity when they need it.

Commit to Process and Framework in the New Year

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The challenging last three years have done nothing but reinforce our belief that the best-performing community banks, over the long run, anchor their balance sheet management in a set of principles — not in divining the future.

They organize their principles into a coherent decision-making methodology that evaluates all capital allocation alternatives across multiple scenarios, over time, on a level playing field. Unfortunately, however, far too many community bankers rely on forecasts of interest rates and economic conditions, which are then engraved into budgets, compensation programs and guidance provided to stock analysts and asset-liability providers.

If we’ve learned anything recently, it’s that nobody can predict rates — not even the members of the Federal Open Market Committee. A year ago, its median forecast for fed funds today was approximately 0.80%; the reality of 4.50% is 370 basis points above this “prediction.”

Even slight differences between predicted and actual rates can result in significant variances from a bank’s budget, which can pressure management towards reactive strategies based on near-term accounting income, liquidity or capital. We’ve long argued that this approach will usually accumulate less reward, and more risk, than proponents ever expect.

Community banking is challenging, but it needn’t be bewildering. The following decision-making principles can clarify your path and energize your execution:

Know where you are.
Net interest income and economic value simulations in isolation present incomplete and often conflicting portrayals of a bank’s risk and reward profile. To know where your bank is, hold yourself accountable to all cash flows across multiple rate scenarios over time, incorporating both dividends paid to a horizon and the economic value of the bank at that horizon. This framework produces a multi-scenario view of returns to shareholders , across a range of possible futures. Making capital allocation decisions in the context of this profile is everything; developing and consulting it is far more inspiring and leverageable than a mere asset-liability exercise.

Refuse to speculate on rates.
Plenty of wealth has been lost looking through the wrong end of the kaleidoscope. Nobody can predict rates with any utility — not economists, not even the FOMC. Make each marginal capital allocation in the context of your shareholder return profile, avoiding unacceptable risk in any scenario while seeking asymmetric reward in others. The idea is to stack the deck in the bank’s favor, not to guess the next card.

For example, imagine your institution is poised to create more shareholder wealth in rates down scenarios than up, a common reality in the current environment. Should you consider trading some of this for outsized benefits in the opposite direction, or not? Assess potential approaches across multiple scenarios: compare short assets versus long liabilities, test combinations or turn the dial through simple derivative strategies to asymmetrically adjust returns or create functional liquidity.

Price options appropriately.
Banks sell options continually, but seldom consider their compensation. They often price loans to win the business, rather than in comparison to wholesale alternatives, and they often forgo enforceable prepayment penalties. Less forgivably, many banks sell options too cheaply in their securities portfolios, in obtaining wholesale funding or in setting servicing rates. Know who owns each option the bank is short, and determine whether it is priced appropriately by comparing it to possible alternatives and measuring the impact on the bank’s forward-looking return profile.

Evaluate risk and regulatory positions.
To make capital allocation decisions prospectively, principle-based decision-makers assess their risk and regulatory positions prospectively as well. The bank’s enterprise risk management platform should offer an objective assessment of its current capital, asset quality, liquidity and sensitivity to market risk positions, and simulate these on a prospective basis also. The only way to determine if a strategy aligns with management’s specific risk tolerance is to have clarity and confidence in its pro forma impact on risk and regulatory positions. For many, establishing secured borrowing lines and reviewing contingency funding plans in 2023 will be prudent steps.

These principles are timeless — only the conclusions they lead to will vary over time. Those institutions that have already woven them into their organizational fabric are facing 2023 and beyond with confidence; those adopting them now for the first time can soon experience the same.