Steps for Managing and Leveraging Data

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Does your institution rely on manual processes to handle data?

Institutions today generate vast amounts of data that come in different forms: transactional data such as deposit activity or loan disbursements, and non-transactional data such as web activity or file maintenance logs. When employees handle data manually, through mouse and keyboard, it puts your institution at risk for inefficient reporting, security threats and, perhaps most importantly, becoming obsolete to your customers.

Take a look at how data is moved through your organization. Exploring targeted improvements can result in actionable, timely insights and enhanced strategic decision-making.

First, focus on areas that may have the biggest impact, such as a process that consumes outsized amounts of time, staff and other resources.

What manual processes exist in your institution’s day-to-day business operations? Can board reporting be streamlined? Do directors and executives have access to meaningful, current data? Or should the institution explore a process that makes new opportunities possible, like improving data analytics to learn more about customer engagement?

Build Your Data Strategy
Crawl — The first step toward effectively managing data is to take stock of what your bank currently has. Most institutions depend on their core and ancillary systems to handle the same information. Various inputs go into moving identical data, like customer or payment information, from one system to another — a process that often involves spreadsheets. The issue of siloed information grows more prominent as institutions expand their footprint or product offering and adopt new software applications.

It’s helpful for directors and executives to ask themselves the following questions to take stock:

  • What is our current data strategy?
  • Does our data strategy align with our broader institution strategy?
  • Have we identified pain points or areas of opportunity for automation?
  • Where does our data reside?
  • What is missing?
  • In a perfect world, what systems and processes would we have?

Depending on complexity, it is likely a portion of the bank’s strategy will look at how to integrate disparate systems. While integration is an excellent start, it is only a means to an end in executing your bank’s broader digital strategy.

Prioritize ROI Efforts and Execute
Walk — Now that the bank has developed a plan to increase its return on investment, it is time to execute. What does that look like? Executives should think through things like:

  • If I could improve only one aspect of my data, what would that be?
  • What technical skills are my team lacking to execute the strategy?
  • Where should I start: build in-house or work with a third party?
  • Are there specific dashboards or reports that would be transformational for day-to-day business operations and strategic planning?
  • What digital solutions do our customers want and need?

Enable Self-Service Reporting
Run — The end goal of any bank’s data strategy is to help decision-makers make informed choices backed by evidence and objectivity, rather than guesswork and bias.

Innovative institutions have tools that make reporting accessible to all decision makers. In addition to being able to interact with data from multiple systems, those tools provide employees with dashboards that highlight key metrics and update in real time, generating the pulse of organizational performance.

With the combination of self-service reporting and data-driven dashboards, leaders have the means to answer tough questions, solve intractable challenges and understand their institution in new ways. It’s a transformative capability — and the end goal of any effort to better manage data.

The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting, investment, or tax advice or opinion provided by CliftonLarsonAllen LLP (CliftonLarsonAllen) to the reader.

Research Report: A Practical Guide to ESG

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For years, investors and activists have worked to compel large, public companies to report their stance on environmental, social and governance issues — better known as ESG. And recently, additional pressure has come from bank regulators on one specific ESG risk: climate. Smaller banks, meanwhile, see the writing on the wall and are taking steps to beef up their ESG programs.

As regulated entities, banks are no strangers to many elements of ESG, which Bank Director explores in the newly launched research report Choose Your Path: A Practical Guide to ESG, which is sponsored by Crowe LLP. Board structure and composition, cybersecurity and data privacy, risk management and regulatory compliance are all areas that fall under the governance umbrella. Social elements, which include financial access, diversity and community involvement, also incorporate into day-to-day operations as financial institutions comply with fair lending rules and other regulations. But it’s the ‘E’ for environmental — specifically, measuring greenhouse gas emissions — that frustrates some bankers who would rather focus on serving their communities than spending time and resources on that complex assessment.

In this report, Bank Director provides intelligence for bank boards and leadership teams seeking to better understand the current regulatory and investor landscape, and uncover what’s relevant for their own organizations. Inside, you’ll find:

  • A quick overview of how ESG has become a language of sorts to describe a company’s activities to investors and other stakeholders
  • Where Washington stands on ESG
  • How investors have focused their attention
  • How banks leverage ESG to uncover new opportunities, including how three community banks have identified core areas that are relevant to their own operations
  • Key material matters for banks to prioritize
  • What role boards could play in ESG oversight, and questions directors might ask

“[A]s disclosures grow, [investors] have more information to make comparable decisions, and that will just continue to grow because of the regulatory environment,’’ says Chris McClure, a partner at Crowe who leads the firm’s ESG team.

On Dec. 2, 2022, the Federal Reserve issued a request for comment on proposed principles for institutions over $100 billion in assets. These principles focus on climate-related financial risks: everything from ​​governance and policies and procedures to strategic planning and risk management. It’s in line with similar guidance issued by the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corp.

At least one Fed Governor doesn’t believe the guidance is necessary: “Climate change is real, but I disagree with the premise that it poses a serious risk to the safety and soundness of large banks and the financial stability of the United States,” stated Christopher Waller. “The Federal Reserve conducts regular stress tests on large banks that impose extremely severe macroeconomic shocks and they show that the banks are resilient.”

In 2023, the Securities and Exchange Commission is expected to finalize its rule around climate disclosure, adding another element of compliance for all publicly traded companies — not just the biggest banks. While some exemptions are anticipated for smaller companies, the rule would expect companies to share how climate-related risks are managed and governed, along with the material impacts of these risks on operations and strategy. Companies could be required to measure greenhouse gas emissions — including emissions by vendors and clients — and share their goals for transitioning to a greener economy.

At the same time, governments in conservative states are working to oppose these rules, going after banks and asset managers that they believe discriminate against the oil and gas or gun sectors. It’s a tricky environment to navigate. Increasingly, some disclosure will be mandated, at least for publicly traded institutions. But bank leaders will still determine their own strategies for the road ahead — and banks that are successful will find the path that’s right for their organization.

To access the report, click here.

If you have feedback on the contents of this report, please contact Bank Director’s vice president of research, Emily McCormick, at [email protected].

How to Craft a Succession Planning Process

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The financial services industry is facing a substantial succession bubble, with an expected 50% board and senior management turnover by 2025, driven by generational and business model changes. In addition, the recent pandemic accelerated the baby boomer generation to exit more rapidly than predicted prior to the pandemic.

Most experts agree: The high demand for senior leadership talent will continue into the foreseeable future. In the face of a highly competitive talent cycle,  coupled with many banks increasing in business complexity, does your institution have confidence in the current board and senior leadership composition to guide your organization through the next five years?

Over the years, the Chartwell Partners’ Financial Services Team has helped clients evaluate their board and senior leadership team against the strategic plans for the bank to help our clients make confident leadership decisions. We have successfully used a four-step process we find effective that includes:

Step 1: Intake
Engage a third party or appoint a director to lead the planning. Meet with key stakeholders, such as the chair, lead director or CEO to understand the business strategic objectives, the current leadership dynamic and unique cultural elements that drive effective leadership transition plans. The ultimate goal is to align leadership decisions to the future business objectives.

Step 2: Planning
Create a tailored plan to define outcomes, outlining defined action plans and a timeline. In our case, we work with the decision-making team to provide guidance on executing against the defined plan — whether it’s testing a current succession plan or executing internal leadership assessments and processes to provide leadership insight supporting board or management changes.

Step 3: Assessment
Leveraging in-person executive assessments, coupled with data-driven online assessment service, the point person should meet with the select executives and provide in-depth insights into the leadership team. They can also provide perspective on the leadership team compared to outside executive options to provide the decision makers a thorough leadership analysis.

Step 4: Reporting
Following assessment, the project lead should produce a report based on the desired outcomes defined by the decision team, which may include a well-defined succession plan or a guide to an internal leadership selection process. Reports should be tailored to the specific needs of the bank, so key stakeholders can be confident in the executive leadership decisions.

At the conclusion of the four steps, it is important to communicate the plans with the team and instill board confidence in the organization. In addition, it is critical to consistently evaluate the leaders against the strategic plan and ensure they are growing and developing leaders the organization can follow. Ultimately, the board owns the responsibility for the CEO and holds them accountable for the development of their team; however, it is always important the designated committee of the board be in touch with management team succession planning. Effective succession planning takes intentional focus from the board. Banks that are proactive about succession planning increase the likelihood of a successful outcome transitioning boards and management teams.

How the New FASB Standard on Revenue Recognition May Impact Banks

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revenue-maze.jpgThe Financial Accounting Standards Board (FASB) recently released its long-awaited standard addressing revenue recognition. Existing U.S. generally accepted accounting principles (GAAP) were largely developed on a piecemeal basis and are industry- or transactional-focused. Consequently, economically similar transactions sometimes resulted in different revenue recognition. Accounting Standards Update (ASU) 2014-09, “Revenue From Contracts With Customers (Topic 606),” adopts a standardized approach for revenue recognition. This was a joint effort with the International Accounting Standards Board (IASB), resulting in converged guidance under both GAAP and International Financial Reporting Standards (IFRS). Of course, companies will report the same total amount of revenue over time, but the timing of the recognition could be accelerated or delayed when compared with current practices. 

A Core Principle and a Five-Step Approach

The new ASU is based on a core principle: “Recognize revenue to depict the transfer of promised goods or services to customers in an amount that reflects the consideration to which the entity expects to be entitled in exchange for those goods or services.” To achieve this principle, the guidance spells out several steps that a company must take when determining when to recognize revenue on its financial statements.

  1. Identify the contract with a customer.
  2. Identify the separate performance obligations in the contract.
  3. Determine the transaction price.
  4. Allocate the transaction price to the separate performance obligations.
  5. Recognize revenue when (or as) performance obligations are satisfied.

Is This a Big Deal for Banks? 

The new ASU could be a challenge from two perspectives. First, there are certain industries for which there will be wholesale changes, including the software, telecommunication and real estate industries. For the banking industry, wholesale changes are not expected—largely because much of a bank’s revenue comes from financial instruments (including debt securities, loans and derivatives), and many of those are scoped out. That is not to say that banks won’t be affected, because most will. But for most banks, the effect is not likely to be significant.

Second, the challenge for banks (as well as other industries) will be taking the core principle and accompanying steps and figuring out how the guidance applies. In other words, the five steps provided are not written with a specific industry in mind, so a shift in thinking will be necessary to evaluate how the accounting will change for those transactions that will apply to banks. A few areas of potential application for banks include:

  • Loyalty point programs
  • Asset management fees
  • Credit card interchange fees
  • Deposit account fees

Effective Dates

The boards provided a lengthy implementation time for the new rules, giving companies time to develop and put in place new controls and processes. The ASU is effective for public companies for annual reporting periods (including interim reporting periods within) beginning after Dec. 15, 2016; early implementation is not allowed. For nonpublic companies, the guidance is effective for annual reporting periods beginning after Dec. 15, 2017, and interim and annual reporting periods thereafter. Early adoption is permitted for nonpublic companies with certain caveats.

Help Is on the Way

In addition to establishing a revenue recognition working group to own the guidance, the American Institute of Certified Public Accountants (AICPA) created 16 different industry task forces charged with providing industry-specific guidance. One of those 16 task forces is the depository institutions revenue recognition task force. With the issuance of the standard, the work now can begin.

In addition, the FASB and the IASB are forming a joint transition resource group, which will consist of 15 to 20 specialists representing preparers, auditors, regulators, users, and other stakeholders. Its objective will be to promote effective implementation and transition.

At just more than 700 pages, the new standard is the longest the FASB has ever issued. This was a major undertaking by the boards, and given the girth of the standard and the fact that it is not industry specific, it’s safe to say it’s just going to take time to digest. 

Part II: The Inspection Process – Compliance Lessons from the Construction Industry

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quality-guarantee.jpgIn the first article of this series I compared the optimal compliance program to a well-built house. You may recall that the construction of a house and a sound compliance program share three key elements: the blueprint, foundation and framework. In this installment, we’ll talk about two more elements that compliance and construction have in common: inspections and maintenance. For the staff involved, this work can be painful to endure, but altogether necessary.

Just like a home inspection, a banking inspection ensures the safety and soundness of the structure. An overlooked mistake can spell a failed inspection, or worse, a structural collapse—and perhaps liability. Even after a passed inspection, periodic maintenance is required. Prompt detection, and swift and thorough remediation of the problem areas, can halt concerns before they worsen, thereby protecting your institution.

So how do you know whether your institution is ready to pass inspection? How do you determine whether you’re conducting the proper periodic maintenance check-ups and routines to keep your compliance programs as effective as possible? The answer is simple: By exercising proper oversight of these programs at the board level. This oversight is carried out by reviewing the right reports with the right content at the right times. 

Boards of directors must ensure that they gather solid intelligence to carry out their fiduciary duties and make informed decisions. One way to do this is to demand high quality reports at predictable intervals. Reports that are flawed or delivered too infrequently may conceal weaknesses that should be addressed. Reports should occur at three basic intervals:  monthly, quarterly, and annually.

Monthly Report

Monthly reports should focus on tactical execution, delivering performance data and metrics. These reports, typically delivered by the compliance team, should cover frontline activity and demonstrate whether the day-to-day work of compliance is being done on time and accurately. Monthly reporting should shine a bright light where weaknesses may exist, and should state the measures being taken to remedy the deficiencies. 

Quarterly Report

Quarterly reports should focus on trends and analytics that demonstrate whether risk exposures are increasing or decreasing. The quarterly report gives insight into how the compliance program is functioning over time. This report should contain information about regulatory trends, upcoming or changing rules and should consider the environmental and operating conditions that could affect the institution’s progress and performance.

These reports should also summarize the results of compliance monitoring activities that occurred during the quarter and which activities are planned in the quarter ahead. This data allows directors to conclude what, if any, internal events or changes will influence the institution. In general, these reports show the up-to-the-minute state of preparedness for exams and audits.

Annual Report

Finally, annual activities such as audits or reviews generate reports on the program’s effectiveness. This annual look-back reflects how well the institution kept its risk exposures to acceptable levels. These types of reports often opine on the overall capabilities of the executive team and compliance management group in carrying out their responsibilities. These reports take an independent look at the program to gauge its effectiveness, efficiency and performance over a historical period.  

Indicators of Poor Reporting

Good intentions can nonetheless produce bad results if the content of reports is inadequate.  When reviewing your institution’s reports, keep in mind these signs of flawed reporting:

  • Reports that are too long or too detailed. Key points cannot be extracted when the volume of information presented obscures the meaning. 
  • Reports that state only facts but provide no evaluative statements. The board needs to understand whether the data being presented is positive or negative.
  • Reports that fail to identify the root causes of weaknesses. Failure to identify the root cause delays implementing corrections. 
  • Reports that identify the root causes of deficiencies, but do not suggest appropriate corrective action. Solutions should be offered in reports. 
  • Reports that only emphasize weaknesses and ignore strengths. Focusing only on the negatives may inappropriately exaggerate the scope or materiality of an identified problem. 
  • Reports that do not reflect the materiality or severity of an issue. Treating every issue uniformly is a sign that perspective may be lacking.

Financial institution boards have a tough assignment: Overseeing the construction of a stable structure that can withstand not only regulatory scrutiny, but the storms of changing economic and regulatory conditions. Maintaining this structure after it’s built is equally daunting. It requires vigilance toward the review and interpretation of quality data, and applying that information to managing risks in an ever-changing climate. Proper reporting ensures proper maintenance of the compliance program, and a well-maintained program that can be clearly articulated to examiners is the key to passing future inspections. 

But, what if, during the inspection process, you realize that something has gone wrong? In the next article of this series I will go over the corrective steps and actions the board should take to repair the compliance program.