The Promise, and Peril, of Risk Technology

The pandemic has underlined how essential risk technology is for proactive and responsive financial institutions.

Prior to the coronavirus outbreak, bank risk managers were already incorporating such technology to manage, sift and monitor various inputs and information. The pandemic has complicated those efforts to get a handle on emerging and persistent risks — even as it becomes increasingly critical to incorporate into day-to-day decision-making.

Data, and getting insights from it, has always been central to how risk managers have worked. That hasn’t changed,” says Sandeep Mangaraj, an industry executive at Microsoft who focuses on digital banking transformations.

Prior to the pandemic, concerns about operational risk had increased “somewhat” or “significantly” among 51% of CEOs, chief risk officers and directors responding to Bank Director’s 2020 Risk Survey, which was completed just before the pandemic. More than half also revealed heightened concerns around cybersecurity, credit and interest rate risk, and strategic risk.

That survey also found respondents indicating there was room for technology to improve their compliance with Bank Secrecy Act and anti-money laundering rules (76%), know your customer (50%) requirements, and vendor management requirements.

One way executives and risk managers can keep up is by incorporating risk technology to help sift through reams of data to derive actionable insights. These technologies can create a unified view of risk across exposure types and aggregation levels — product, business line, region — so executives can see how risk manifests within the bank. Some of these solutions can also capture and provide real-time information, supplementing slower traditional sources or replacing end-of-day reports.

But the pandemic led more than half of respondents to Bank Director’s 2020 Technology Survey to alter or adjust their technology roadmaps — including 82% of respondents at institutions with more than $10 billion in assets. Two-thirds said they would upgrade existing technology; just 16% planned to add technology to improve regulatory compliance.

Artificial intelligence holds a lot of promise in helping banks more efficiently and effectively comply with regulations and manage risk. Many banks are still early in their risk technology journeys, and are working to identify areas or situations that can be serviced or assisted by risk technologies. Forty-six percent of respondents to Bank Director’s Technology Survey say they are not utilizing AI yet.

Those that have are applying it to situations like fraud monitoring, which generates large amounts of data that the bank can correlate and act on, Mangaraj says. Others have applied it to process intelligence and process improvement, or used it to enhance the control environment. Key to the success of any AI or risk-technology endeavor is finding the right, measurable application where a bank can capture value for heightened risk or capabilities.

“We have a client who uses AI to monitor trader conversations that can proactively flag any compliance issues that may be coming up,” he says. “There are lots and lots of ways in which you can start using it. Key is identify cases, make sure you have clear measurement of value, monitor it and celebrate it. Success breeds success.”

The addition and incorporation of innovative risk technologies coincides with many banks’ digital transformations. While these changes can often complement each other, they can also make it difficult for a bank to manage and measure its risk, or could even introduce risk.

A strong management team, effective controls and active monitoring of the results are essential keys to a bank’s success with these technology endeavors, says James Watkins, senior managing director at the Isaac-Milstein Group. Watkins served at the FDIC for nearly 40 years as the senior deputy director of supervisory examinations, overseeing the agency’s risk management examination program.

“It’s time for a fresh look of the safeguards and controls that banks have in place — the internal controls and the reliability of the bank system’s and monitoring apparatuses. All of those are extremely important,” he says.

Bank executives and boards of directors must have the processes and procedures in place to ensure they’re using this technology and contextualizing its outcomes in a prudent manner.

“I think the importance of general contingency planning, crisis management strategies, thinking strategically — these are all areas that boards of directors and senior management really need to be attuned to and be prepared for,” Watkins says.

Keeping Optimism Alive

We are all in survival mode.

While the health and safety of one’s constituents takes top billing, keeping a business relevant — and viable — during these times should top the shortlist of any board’s agenda.

And while nobody has a compass to navigate these times, we at least have the means to aggregate an incredible amount of information and insight, vis-a-vis BankBEYOND.

With many fatigued from virtual conferences, we challenged ourselves to bring concise, novel ideas to a hugely influential audience. We followed Steve Jobs’ principle of design, working backward from the user’s experience to present board-level issues in new ways on BankDirector.com.

Our North Star in crafting the BankBEYOND agenda and experience: Respecting viewers’ time while surfacing issues that are both specific and relevant to their interests and responsibilities. Hence, our focus on issues that are strategic, risky and potentially expensive.

Since March, the industry has witnessed — and undergone — a rapid evolution of financial services. As a result, officers and directors must now assess the potential of their bank’s business in a post Covid-19 world. Growing a bank prudently and profitably took center stage at our Acquire or Be Acquired Conference in January; today, I suspect many boards and executives today emphasize efficiency to protect their franchise’s value. Indeed, a 50% efficiency ratio used to be the stretch goal for many banks; now, that might be closer to 35%.

Banks across the country are grappling with the tough choices they will need to make to rapidly bring those ratios down while delivering consistent service across physical and digital channels. We appreciate how so many institutions quickly embraced new technologies to solve specific business challenges, like the rollout of the Small Business Administration’s Paycheck Protection Program. In recent merger announcements, the drive to leverage technologies proved a primary catalyst for striking a deal. In fact, that’s where many efficiency gains come from.

However, boards realize that many of these technology additions can be expensive, which is why economies of scale becomes critical. We have seen how mergers can become the most expeditious way to generate meaningful economies of scale. But of course, much of the bank space is stuck in neutral at the moment when it comes to bank M&A.

We know that BankBEYOND’s audience has the responsibility for finding answers, rather than identifying barriers. We are tackling issues like:

  • Setting high-priority, short-term goals;
  • Keeping optimism and a sense of purpose alive; and
  • Weaving the best of the past eight months into everything the bank does going forward.

These are only three of the topics we’ll address with the help of various advisors and executives. Unlike a digital conference, with specific dates and watch times, we release families of videos and presentations at 8 a.m. CST. Beginning Monday, Nov. 9, we explore strategic and governance issues. The next day, we add information geared to the audit committee and risk committee. We conclude on Wednesday, Nov. 11, by sharing content developed for the compensation and nominating/governance committees.

BankBEYOND tees up the topics that allow for proactive — not reactive — change. By placing a premium on complex issues that all directors must address, we strengthen the knowledge of a bank’s board. And we rarely find a strong board at anything but a strong bank.

Beware Third-Quarter Credit Risk

Could credit quality finally crack in the third quarter?

Banks spent the summer and fall risk-rating loans that had been impacted by the coronavirus pandemic and recession at the same time they tightened credit and financial standards for second-round deferral requests. The result could be that second-round deferrals substantially fall just as nonaccruals and criticized assets begin increasing.

Bankers must stay vigilant to navigate these two diametric forces.

“We’re in a much better spot now, versus where we were when this thing first hit,” says Corey Goldblum, a principal in Deloitte’s risk and financial advisory practice. “But we tell our clients to continue proactively monitoring risk, making sure that they’re identifying any issues, concerns and exposures, thinking about what obligors will make it through and what happens if there’s another outbreak and shutdown.”

Eight months into the pandemic, the suspension of troubled loan reporting rules and widespread forbearance has made it difficult to ascertain the true state of credit quality. Noncurrent loan and net charge-off volumes stayed “relatively low” in the second quarter, even as provisions skyrocketed, the Federal Deposit Insurance Corp. noted in its quarterly banking profile.

The third quarter may finally reveal that nonperforming assets and net charge-offs are trending higher, after two quarters of proactive reserve builds, John Rodis, director of banks and thrifts at Janney Montgomery Scott, wrote in an Oct. 6 report. He added that the industry will be closely watching for continued updates on loan modifications.

Banks should continue performing “vulnerability assessments,” both across their loan portfolios and in particular subsets that may be more vulnerable, says James Watkins, senior managing director at the Isaac-Milstein Group. Watkins served at the FDIC for nearly 40 years as the senior deputy director of supervisory examinations, overseeing the agency’s risk management examination program.

“Banks need to ensure that they are actively having those conversations with their customers,” he says. “In areas that have some vulnerability, they need to take a look at fresh forecasts.”

Both Watkins and Goldblum recommend that banks conduct granular, loan-level credit reviews with the most current information, when possible. Goldblum says this is an area where institutions can leverage analytics, data and technology to increase the efficiency and effectiveness of these reviews.

Going forward, banks should use the experiences gained from navigating the credit uncertainty in the first and second quarter to prepare for any surprise subsequent weakening in credit. They should assess whether their concentrations are manageable, their monitoring programs are strong and their loan rating systems are responsive and realistic. They also should keep a watchful eye on currently performing loans where borrower financials may be under pressure.

It is paramount that banks continue to monitor the movement of these risks — and connect them to other variables within the bank. Should a bank defer a loan or foreclose? Is persistent excess liquidity a sign of customer surplus, or a warning sign that they’re holding onto cash? Is loan demand a sign of borrower strength or stress? The pandemic-induced recession is now eight months old and yet the industry still lacks clarity into its credit risk.

“All these things could mean anything,” Watkins says. “That’s why [banks need] strong monitoring and controls, to make sure that you’re really looking behind these trends and are prepared for that. We’re in uncertain and unprecedented times, and there will be important lessons that’ll come out of this crisis.”

Community Risks That Community Banks Should Address

States and counties are starting to reopen after a prolonged period of sheltering in place due to the Covid-19 pandemic.

Many community banks that function as the primary lenders to small businesses in the rural Midwest have yet to see a significant negative financial impact because of the shutdown. In fact, many community banks stand to receive significant loan origination fees from the U.S. Small Business Administration for participating in the Paycheck Protection Program. They’re also flush with cash, report the community bank CEOs I’ve asked, as many borrowers haven’t used their PPP loan funds and consumers have been holding their stimulus payments in their checking accounts.

But just because things look stable from a financial perspective doesn’t mean there isn’t risk in your community and to your bank. Let’s take a brief look at some issues community banks should be monitoring today:

Increasing personal debt caused by prolonged unemployment. Unemployed Americans received an unprecedented amount of unemployment benefits that for the most part ended on July 31, 2020. What are Americans doing now? Some furloughed employees have been recalled, but others weren’t. When income is scarce, the use of credit cards, overdraft protection, and personal loans increases. What is your bank doing to monitor the increasing financial pressure of your individual borrowers and account holders?

Delayed business closures. Small businesses without a significant online presence are finding it difficult to operate in this new environment. “Nonessential” small businesses survived the shutdown by using government funds, furloughing employees, drawing on credit lines, or using personal savings. The lost sales may not have been deferred to a later date. Instead, they are truly lost and won’t be recaptured. Without a fast and heavy recovery for small businesses, they may be forced to close and may not be able to support their current debt load. How is your bank monitoring the performance of your small business customer?

Reduced need for office and retail space. With the increase in employees working remotely, especially at businesses that typically use commercial office space, the perceived need for office space is declining. Once a lease term expires, community banks should expect some commercial borrowers to experience reduced rental income as tenants negotiate for less square footage or overall lower rates. Are you tracking the going rate for rent per square foot in your market?

Increased fraud risk. When people experience all three sides of the fraud triangle (rationalization, opportunity, and pressure), they’re more likely to commit fraud. Identification of the fraud can be significantly delayed. A bookkeeping employee whose spouse has been laid off can rationalize the need for the company’s money, has the opportunity to take it, and feels the financial pressure to use it for personal needs. This person may be able to cover it for a short time; but, covering it becomes more difficult as it grows. That can happen within the bank or at any of your commercial borrowers.

Community banks have yet to see a dramatic increase in past dues or downgrades in loan ratings; it’s likely too early to see the financial stress. Several community banks are adding earmarked reserves to the allowance for loan losses in each loan category as “Covid-related.” However, community banks should carefully evaluate loans that were “on the bubble” prior to the shutdown, were granted some form of deferral by the bank, or are in certain industries like hospitality. Interagency guidelines permit banks to not account for these loans as troubled debt restructures (TDR) if they meet certain criteria, but banks are still responsible for maintaining a proper allowance. A loan in deferral may need an increased reserve, even if it isn’t accounted for as a TDR. The time it takes for that stress to show (called “loss emergence period” in accounting) is longer than many think.

Two other significant financial impacts to banks relate to overdraft fees and interchange fees. As spending decreased, so did overdrafts and associated fee income. And without the discretionary debit card swipes, interchange fees fell significantly as well.

How much of the above information will you use as you prepare the 2021 budgets this fall? What will your baseline for 2021 be: 2019 or 2020? Regardless, assess the risks to the bank and plan accordingly.

This article is for general information purposes only and is not to be considered as legal advice. This information was written by qualified, experienced BKD professionals, but applying this information to your particular situation requires careful consideration of your specific facts and circumstances. Consult your BKD advisor or legal counsel before acting on any matter covered in this update.

Five Ways PPP Accelerates Commercial Lending Digitization

The Small Business Administration’s Paycheck Protection Program challenged over 5,000 U.S. banks to serve commercial loan clients remotely with extremely quick turnaround time: three to 10 days from application to funding. Many banks turned to the internet to accept and process the tsunami of applications received, with a number of banks standing up online loan applications in just several days. In fact, PPP banks processed 25 times more loan applications in 10 days than the SBA had processed in all of 2019. In this first phase of PPP, spanning April 3 to 16, banks approved 1.6 million applications and distributed $342 billion of loan proceeds.

At banks that stood up an online platform quickly, client needs drove innovation. As institutions continue down this innovation track, there are five key technology areas demonstrated by PPP that can provide immediate value to a commercial lending business.

Document Management: Speed, Security, Decreased Risk
PPP online applications typically provided a secure document upload feature for clients to submit the required payroll documentation. This feature provided speed and security to clients, as well as organization for lenders. Digitized documents in a centrally located repository allowed appropriate bank staff easy access with automatic archival. Ultimately, such an online document management “vault” populated by the client will continue to improve bank efficiency while decreasing risk.

Electronic Signatures: Speed, Organization, Audit Trail
Without the ability to do in-person closings or wait for “wet signature” documents to be delivered, PPP applications leveraged electronic signature services like DocuSign or AdobeSign. These services provided speed and security as well as a detailed audit trail. Fairly inexpensive relative to the value provided, the electronic signature movement has hit all industries working remotely during COVID-19 and is clearly here to stay.

Covenant Tickler Management: Organization, Efficiency, Compliance
Tracking covenants for commercial loans has always been a balance between managing an existing book of business while also generating loan growth. Once banks digitize borrower information, however, it becomes much easier to create ticklers and automate tracking management. Automation can allow banker administrative time to be turned toward more client-focused activities, especially when integrated with a document management system and electronic signatures. While many banks have already pursued covenant tickler systems, PPP’s forgiveness period is pushing banks into more technology-enabled loan monitoring overall.

Straight-Through Processing: Efficiency, Accuracy, Cost Saves
Banks can gain significant efficiencies from straight-through processing, when data is captured digitally at application. Full straight-through processing is certainly not a standard in commercial lending; however, PPP showed lenders that small components of automation can provide major efficiency gains. Banks that built APIs or used “bots” to connect to SBA’s eTran system for PPP loan approval processed at a much greater volume overall. In traditional commercial lending, it is possible for data elements to flow from an online application through underwriting to final entry in the core system. Such straight-through processing is becoming easier through open banking, spelling the future in terms of efficiency and cost savings.

Process Optimization: Efficiency, Cost Saves
PPP banks monitored applications and approvals on a daily and weekly basis. Having applications in a dynamic online system allowed for good internal and external reporting on the success of the high-profile program. However, such monitoring also highlighted problems and bottlenecks in a bank’s approval process — bandwidth, staffing, external vendors and even SBA systems were all potential limiters. Technology-enabled application and underwriting allows all elements of the loan approval process to be analyzed for efficiency. Going forward, a digitized process should allow a bank to examine its operations for the most client-friendly experience that is also the most cost and risk efficient.

Finally, these five technology value propositions highlight that the client experience is paramount. PPP online applications were driven by the necessity for the client to have remote and speedy access to emergency funding. That theme should carry through to commercial banking in the next decade. Anything that drives a better client experience while still providing a safe and sound operating bank should win the day. These five key value propositions do exactly that — and should continue to drive banking in the future.

Addressing the Income Inequality Imperative Before It’s Too Late

There’s an unofficial adage in journalism that three similar events make a story. One car wreck at a particular intersection is an accident. Two accidents are an unfortunate coincidence. Three times is a trend — and an issue to discuss and address.

So it was hard not to start worrying when three different guests — an entrepreneur, a former regulator and a longtime financial services consultant — mentioned the same potential fear on Promontory Network’s podcast “Banking with Interest.” They all worried that rising economic inequality, which has been exacerbated by the Covid-19 crisis, could spur widespread social unrest beyond anything we’ve seen to date.  

“Things can go really bad,” entrepreneur and Shark Tank costar Mark Cuban told me in April, well before the brutal police killing of George Floyd in late May sparked nationwide protests in response to racial injustice and inequality. “We’ve seen riots. We’ve seen small businesses burn down.”

One recent warning came from Karen Shaw Petrou, managing partner of Federal Financial Analytics. Petrou is one of the most thoughtful voices in the financial services industry; since 2018, she has been adamant that income inequality is an increasing — and underappreciated — risk to the financial system.

You have empirical and theoretical evidence that the more economically unequal a nation is, the more fragile its financial system,” Petrou told me in June. “I worry… that prolonged economic inequality, combined with the kinds of crises it keeps precipitating, will also lead to rage. History is not inspiring on the topic of what happens to societies with profound inequality.”

John Hope Bryant, the founder, chairman and CEO of Operation Hope, a not-for-profit dedicated to financial literacy and economic inclusion, agreed.

“Societies don’t crater from the top down,” he told me. “They crater from the bottom in. You cannot have 1% doing great, 15% doing pretty good and 80% plus doing pretty crappy and expect that to be sustainable.”

They are hardly alone. Both Citigroup CEO Michael Corbat and JPMorgan Chase & Co. Chairman and CEO Jamie Dimon flagged economic inequality as a growing threat to financial and political stability. And Brian Brooks, Acting Comptroller at the Office of the Comptroller of the Currency, acknowledged to me that systemic inequities need to be addressed.

“People are not actually crying out because the system is a terrible system, right? They’re crying out because the system that has worked for a bunch of people has totally excluded other people for a fairly long period of time,” he told me. “And the banking system can fix that.”

Among other things, Brooks wants to reexamine how credit scores are calculated and how current models shut minority Americans out of the finance system.

Economic inequality predates the spread of the coronavirus. The wealth gap between the richest and poorest families more than doubled from 1989 to 2016, according to the Pew Research Center. The data is particularly grim for African Americans. The average wealth of white households was seven times the average of black households in 2016, according to a recent post by Petrou. White Americans owned 85% of U.S. household wealth at the end of 2019, she wrote, while Black Americans held just 4.2%.

But the coronavirus crisis is set to make the problem far worse.

“Low-income households have experienced, by far, the sharpest drop in employment, while job losses of African-Americans, Hispanics, and women have been greater than that of other groups,” Federal Reserve Chairman Jerome Powell told lawmakers recently. “If not contained and reversed, the downturn could further widen gaps in economic well-being that the long expansion had made some progress in closing.”

There are proposed solutions. Petrou has called for the creation of an “Equality Bank,” controlled by a consortia of banking companies to “rewrite the profit equation to serve low- and moderate-income households.” This bank could offer short-term, low-dollar loans to consumers through the banking system, without the often-onerous rates and terms of existing products like payday loans.

Bryant has called for a new Marshall Plan to combat the problem, including calling for a universal income for workers making less than $60,000 per year,  a national financial literacy mandate, and a redesigned education system that includes a free college education for most students.

“You need a mass of people to be highly educated,” Bryant said. “This is not rocket science. It’s the radical movement of common sense. As you educate more people, and raise credit scores along with it, you get more economic energy. You get more small business startups, you get more job creation. You get higher educational engagement. You get better skilled workers. You get less societal friction. This is an investment, not a giveaway.”

Brooks, meanwhile, has said the OCC is set to launch a pilot project designed to bring together banks, civil rights organizations and academics to tackle wealth creation. Cuban has talked about creating jobs to track and trace the spread of the virus in the short-term and pushed for government investments in low-income housing and companies offering stock to employees so that they have a stake in a firm’s success.

Tackling economic inequality hasn’t been a high priority for many in banking and government. That needs to change — and soon. While people may reasonably disagree on the right solution to this issue, most are of the same mind when it comes to what happens if we don’t try to address it.

We need to lift people “from the bottom-up,” Cuban told me. “We have never thought like that in the past, and we need to. Because if we don’t, oh my goodness … If we screw up, it could get ugly.”

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Avoiding Pitfalls of Covid-19 Modifications for Swapped Loans

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

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

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

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

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

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

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

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

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

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

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

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

How One Bank Flattened Fraud

Argo.pngProtecting the bank and its customers — through cybersecurity measures, identity verification, fraud detection and the like — is vital in ensuring a financial institution’s safety and soundness, as well as its reputation in the marketplace. These investments typically represent significant cost centers, but fraud prevention tools can be an exception to the rule if they’re able to pay for themselves by preventing losses.

The idea is, when you put in a fraud system — and this is where some folks lose it — you want to make sure to catch more fraud than the system costs,” says Ronald Zimmerman, vice president in the operations department at $32.2 billion IBERIABANK Corp., based in Lafayette, Louisiana. “You always have to make sure that the cost doesn’t supersede your savings.”

Zimmerman implemented ARGO OASIS about a year ago. OASIS, which stands for Optimized Assessment of Suspicious Items, uses neural networks and image analytics to detect and prevent fraud. Modeled after the human brain, neural networks are a form of artificial intelligence designed to recognize patterns, making it well suited to identify check alterations, forgeries and other forms of transaction fraud. The solution then provides bank employees with detailed information to enable them to further investigate the activity.

Bank Director’s 2020 Risk Survey found that just 8% of executives and directors report that their bank uses AI technology to improve compliance. One-third are exploring these types of solutions.

IBERIA brought in OASIS to identify fraud in its “two-signature accounts” — customer accounts that require two signatures on a high-dollar check. “We have a queue set up in OASIS to monitor these checks as they come in through clearing. If a signature is missing or is in question, OASIS flags it for review,” Zimmerman says.

One thing about the technology that sets it apart is its check stock validation tool. “You have an overlay button where you can place a questioned check on top of a good check, and you have a little slide bar [so you] can see the small differences,” he says.

That tool alone has helped the bank stop roughly $300,000 in check fraud over the first eight months of use — meaning ARGO has already paid for itself. “We’ve caught a ton of fraud through this product,” says Zimmerman.

And $300,000 is a conservative estimate of the bank’s savings, Zimmerman says, because fraudsters have learned not to target his bank. “Check fraud flattened out, because the fraudsters have probably moved on, knowing that we’ve covered up a hole that was there before.”

ARGO OASIS was recognized as the Best Solution for Protecting the Bank at the 2020 Best of FinXTech Awards in May. ALTR, a blockchain-based security solution, and IDology, which uses big data for identity verification and fraud detection, were also finalists in the category.

Importantly, ARGO helps IBERIA stop fraud efficiently. A task that used to occupy three full-time employees’ time now takes two employees just a couple of hours.

IBERIA will soon merge with Memphis, Tennessee-based First Horizon National Corp. to form a $75 billion company. The deal was driven in part by the pursuit of scale.

Generating efficiencies is essential to better compete with big banks, said First Horizon CEO Bryan Jordan in a 2017 presentation. “We’ve got to be invested in technologies in such a way that we’re at or above table stakes,” he said. “The trick for us will be to … create efficiency in other parts of the business to create money that we can invest in leading-edge technologies and processes that really allow us to be competitive.”

Leveraging AI to reduce compliance busywork is a great place to start.

CEOs Weigh Challenge of Recalling Workers During Pandemic

The Covid-19 pandemic is a crisis at both the personal and corporate level.

Having sent most of their employees to work from home since March, banks are now making plans to gradually re-integrate them into their old work environment. Doing so while infection rates are still high – and in some locations, still rising – is a human resource challenge unlike any faced in the modern corporate era.

Can banks bring their employees back to the workplace and keep them safe – and are they ready to come back?

I’ve had this conversation with a number of bank CEOs and senior executives in recent months; they all treat office worker repatriation as a serious issue that demands a thoughtful and careful approach. To a person, they express reluctance to force employees to return to an office environment if they fear there is a greater chance of being infected there than in their own homes.

And since all of their banks have operated with a distributed work force for three months or more with little — if any — decline in productivity, there’s no sense of urgency to immediately pull everyone back to the office.

Large banks that operate from office towers in big cities may face the biggest logistical challenges in bringing people back.

In an interview for my story in the third-quarter issue of Bank Director magazine – “Surviving the Pandemic” – Bill Demchak, chairman and CEO at Pittsburgh-based PNC Financial Services Group, gave voice to the cautiousness that many bank leaders feel.

Demchak says his executive team has discussed the timing of when PNC might reopen its 33-story office tower in downtown Pittsburgh. “Should we start bringing people back sometime in June, given that the government says it’s okay?” he asks. “We ultimately decided not to.”

Demchak lists some of the many considerations. The bank would have to partition off sections of the floor space in Plexiglas to maintain social distancing. The software running the elevators would have to be reprogramed to control the flow of people to upper floors, and the small number of people who would be allowed in each car would have to stand facing the interior walls to protect themselves. Seventy percent of PNC employees in the tower also commute on mass transit, which would increase their risk of infection. And since most summer camps in the Pittsburgh area have been cancelled because of the coronavirus, pulling people back into the office would create an immediate child care issue for many.

There are advantages to having your people in the same place. “You get knowledge transfer; people learn new skills and you maintain the culture of behavior and norms that we want to promote as a firm,” Demchak says. “I don’t know that you get any of that by bringing 30% of the senior people back and ticking them off by surrounding them with Plexiglas and making them ride the elevators backwards.”

Fifth Third Bancorp in Cincinnati has already begun to repatriate some of its employees to their old office locations. About half of the bank’s 22,000 workers remained onsite, either in the branches or operations centers, during the pandemic.

The plan is to bring back the remaining 11,000 in three phases, according to Chairman and CEO Greg Carmichael, beginning with an initial 1,000 in phase one who are onsite now, working in social distancing arrangements. “We want to learn, make sure that’s going to go as well as we would expect it to,” he says. “There’s signage that’s required, how many people in an elevator, how many people in a bathroom, food service, all those types of things.” The remaining 10,000 will be brought back in the next two phases. Fifth Third is following recommendations from the Centers for Disease Control and Prevention for Covid-19 workplace health and safety, and going beyond them in some instances.

The bank also had to stock up on large quantities of personal protective equipment, and anyone who has tried to purchase facemasks and hand sanitizers knows they are hard to come by even in small numbers. “We’ve got the hand sanitizers. We’re doing the wipe downs of the workstations, and we’ve got face coverings for all 11,000 employees,” Carmichael says.

The bank has also established an employee hotline to report violations of the new safety rules. “If someone sees a situation they’re not comfortable with, we have a hotline they can call immediately and we’ll address it immediately,” Carmichael says. “We want our employees to know that their safety is job one for us, and making sure we’re protecting them the best we can.”

It’s likely that not every employee will want to return to their old office. “The people that I talk to are really in fairly diametrically opposed camps right now,” says Darren King, the chief financial officer at M&T Bank Corp. in Buffalo, New York. “There’s the crowd that says, ‘I love working from home. I never want to go back to the office.’ And there’s an equally passionate crowd that says ‘As soon as the office is open, let me in. I want out of my house.’”

The trick will be offering flexibility to those employees who prefer to remain home-based, while keeping the office crowd safe. Like most banks, the majority of M&T’s staff have been working remotely through the pandemic; because productivity hasn’t suffered, it may be a matter of choice for some.

“We would not force anyone who’s uncomfortable and able to work from home to come back,” King says.