Credit Lending

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By: Tom Hannagan Part 3 This post continues my discussion of the reasons for going through the time and trouble to analyze risk-based pricing for loans. I mentioned before that the second general major justification for going through the effort to risk-adjust loan pricing as a normal part of the lending function is financial. I thought it might help put this into perspective by offering rough numbers that relate to risk-adjusted profit performance, bottom line earnings and expand on the premise that risk has a cost. Lending, in the leveraged/banking sense, involves credit risk, market (interest rate) risk and operational risk. The fourth area, the risk of unexpected loss, is covered by capital. Unmitigated risk will eventually impact earnings and common equity.  The question is when and by how much? It’s important to understand that the cost of risk mitigation efforts depend on the various risk characteristics of the bank’s loans and loan portfolio. The differential cost of market risk As an example, a floating rate loan that reprices every month involves little market risk, requiring little if any expense to offset. Compare it to a five-year fixed rate, interest-only loan that involves greater exposure to market risk. That risk costs something to offset. The difference in annualized marginal funding cost ranges widely depending on the steepness of the yield curve on the date the loan is closed. The difference between Federal Home Loan Banks 30-day rates and five-year bullet funding today, for instance, is close to 200 basis points. If risk-based loan pricing models don’t reflect this difference by using a matched marginal funding cost, the bank is voluntarily assuming some or all of the market (or interest rate) risk. Multiply an implied 200 bps risk-based funding cost difference by $100M in average loan balances and the implied annualized additional risk-free funding expense is $2,000,000. Multiply that by the average life of the portfolio to get the full risk-adjusted cost difference that the bank is assuming. And that’s just for the market risk. The implied cost of credit risk A loan with a pass risk rating of ‘2’ involves a lower likelihood of defaulting than a loan with a pass risk rating of ‘4.’ The lower risk (grade 2) loan, therefore, involves less of an Allowance for Loan Lease and Losses reserve requirement and an implied lower provisioning expense than the higher risk (grade 4) loan. Depending on the credit regimen and net loss experience of a given bank, the difference in the implied annualized expected loss due to credit risk could be 40 bps or more. Multiply the implied 40 bps credit risk cost difference by $100M in average loan balances and the implied annualized additional risk-adjusted credit expense is $400,000. Multiply that by the average tenor of the portfolio to get the full risk-adjusted cost difference to the bank. The implied difference in administrative (or operations) expenses These expenses include all mitigated (insured) operational risk. An owner occupied commercial mortgage is normally much less expensive to monitor than a line of credit backing a construction project. Those cost differences often range into several thousand dollars per annum. If, in our example of the $100M portfolio, our average credit is $400K, then we have around 250 loans. These loans multiplied by $3,000 in fully-absorbed annual non-interest expense differences would amount to $750K. A competent risk-adjusted loan pricing effort would take this cost difference into account. Again, multiply that yearly amount by the average life of the portfolio to get the full cost difference that the bank is incurring. In reality, the three sample portfolios above would not overlap perfectly. The total actual assets from the above examples would lie between $100M and $300M. However, the total pretax cost difference of these three sample risk-based costs adds up to $3.15M per annum. The after-tax negative impact on risk-adjusted earnings is therefore about $2M yearly. So, the impact on ROA would be between 2.00% (if the three portfolios overlapped perfectly, for $100M in total assets) down to .67% (if there was no overlap, for $300M in total assets). This is a huge difference in earnings, on a risk-adjusted and fully cost-absorbed basis. Finally, the amount of risk-based capital needed to back loans with differing risk characteristics, for purposes of unexpected loss, can be substantially different. This can be looked at as a difference in the implied cost of capital or in the performance ratio of ROE. In a simple application, the implied required equity might range from say 6% on the lower-risk loans up to 8% for moderate risk (average pass grade risk rating). If the portfolio in question is earning 1% ROA, the difference in risk-based equity would result in an ROE of either 12.5% for the higher risk loans versus 16.7% for the lower risk loans. The differences in fully risk-based ROE, or RAROC, could easily be more dramatic than this. As stated before, if these differences are not “priced” into the loans somehow, the bank is not getting paid for the risk it is incurring or it is charging the lower risk borrowers a rate that pays for the added risk expenses of the higher risk borrowers. The business risk to the bank then becomes losing the better clients over time rather than attracting the riskier deals. An economic look at performance We are not talking in terms of “normal” accounting practices or “typical” quarterly reporting periods. We do use general ledger numbers to start the analysis process by relying on actual balances, rates and maturities. But, GAAP doesn’t address risk. So the risk adjustments are a more “economic” look at performance. Eventually, the risk reduction approach and the GL-based results will even out. The question is not “if” risk will eventually surface, but when and how it will manifest itself in GL results. We’ve seen a lot of this in the news the past eighteen months – and there’s likely more to come as the economy is in a downturn phase. Going through the effort is worth it Once risk is created by making a loan or placing a bet, someone owns it. The reason to go through the effort to price loans (and relationships) on a fully risk-adjusted basis is to understand the impact of risk at the only point in time when you can do something about getting paid for it – at the time the loan is agreed upon. After that, the bank is pretty much along for the ride. Risk-adjusted pricing is smart banking. It not only puts some teeth in the bank’s already existing risk management policies, it is justifiable to the client and it makes sense to most lending officers.

Published: February 5, 2009 by Guest Contributor

This post is a feature from my colleague and guest blogger, Stephanie Butler, manager of Process Architects in Advisory Services at Baker Hill, a part of Experian. Are you tired of the economic doom and gloom yet?  I am.  I’m not in denial about what is happening -- far from it.  But, we can wallow or move forward, and I chose to move forward.  Let’s look at a few of the many lessons that can be learned from the year and some action steps for the future. 1. Collateral does not make a bad loan good  Remember this one? If you didn’t relearn this in 2008, you are in trouble.  Using real estate as collateral does not guarantee a loan will be paid back.  In small business/commercial lending, we should be looking at time in business, repayment trends and personal credit.  In consumer lending, time with an employer, time at the residence and net revolving burden are all key.  If these are weak, collateral will not make things all better. 2. Balance the loan portfolio  Too much of a good thing is ultimately never a good thing.  First, we loaded our portfolios with real estate because real estate could never go bad.  Now, financial institutions are trying to diversify out of real estate and move into the “next great thing.”  Is it consumer credit cards, commercial C&I, or small business lines of credit?  It’s anyone’s guess.  The key is to balance the portfolio.  A balanced portfolio can help smooth the impact of economic trends and help managing uncertainty.  We all know that policy requires monitoring industry concentrations.  But, balancing the portfolio means more than that.  You also need to look at the product mix, collateral taken, loan size and customer location.  Are you too concentrated in unsecured lending?  How about lines of credit?  Are all of your customers in three zip codes? 3. Proactive vs. reactive The days of using past dues for portfolio risk management are gone.  We need to understand our customers by using relationship management and looking for proactive markers to anticipate problems.  Whether this is done manually or through the use of technology, a process must be in place to gather data, analyze and anticipate loans that may need extra attention.  Proactive portfolio risk management can lessen potential charge-offs and allow the bank to renegotiate loans from a position of strength. Be sure to check my next post as Stephanie continues with tips on how to get back to risk management basics.

Published: February 4, 2009 by Guest Contributor

Part 2 My colleague, Prince Varma, Senior Client Partner -- Portfolio Growth and Client Management, shares his advice on the best practices for portfolio risk management in these trying times. Boy; this is an interesting time. Banks today are at a critical threshold -- the biggest question that they are trying to answer is, \"How do we continue to grow -- or at least avoid contracting -- without sacrificing profitability or credit quality?” The urge to overcompensate, or engage in ultra conservative lending practices, must be resisted.  That said, we are already seeing a trend in which mid-sized and regional lenders are abandoning mid-tier credit. This vacuum is being filled by community banks and credit unions which are implementing aggressive risk-based pricing programs in order to target the small business market. These organizations are also introducing \"safe and secure\" campaigns that specifically target existing clients of banks in the news -- and attempting to entice those clients to switch over. We are strongly urging banks to engage in an analysis of their existing portfolios in order to pinpoint opportunities for expanding their relationships with existing key clients. Many senior executives are expressing apprehension about undertaking new projects given current levels of uncertainty.  Our best advice is two-fold.. First, focus on identifying those areas where process remediation will have long term and sustained value. Second, do not allow uncertainty to paralyze your internal improvement efforts.  Strong business cases lead to good decisions; don\'t let fear and apprehension cloud what you know needs to be done.

Published: January 30, 2009 by Guest Contributor

By: Tom Hannagan Part 2 This post continues my discussion of the reasons for going through the time and trouble to analyze risk-based pricing for loans. For the discussion of the key elements involved in risk-adjusted loan pricing, please visit my earlier posts. In my last blog we discussed reason number one: good corporate governance. Governance, or responsible and disciplined leadership, makes a lot of sense and promotes trust and confidence which has been missing lately in many large financial institutions. The results can be seen in the market in multiples now and are associated with both the struggling companies and, through guilt by association, the rest of the industry.  But, let’s move beyond the “soft” reason. The second major justification for going through the effort to risk-adjust loan pricing as a normal part of the lending function is financial. Profit performance By financial, we mean profit performance or bottom line earnings. This reason relies on the key belief that risk has a cost. Just because risk can be difficult to measure and/or is not addressed within GAAP, doesn’t mean it can’t ultimately cost you something. If, for any reason, you believe you can get away with taking on any unmitigated risk without it ever costing anything, do not continue reading this or any of my other posts. You are wasting your valuable time. Risk will surface The saying that “risk will out,” I believe, is true. The question is not if risk will eventually surface, but when, how and how hard it will bite.  Risk can be transferred (hedges, swaps and so on), but it doesn’t disappear from the universe. Once risk is created, someone owns it. The news headlines of the past 18 months are replete with stories of huge writedowns of toxic assets. The securitized assets and/or their collateral loans always contained risk – from the moment the underlying loan was closed. The loans and their payment streams were sliced a dozen ways, repackaged and resold. The risk was also sliced up, but like mercury, it all remained in the system.  Another familiar casino saying that brings this to mind is: “If you don’t know who the ‘mark’ at the table is, it’s you.” There are now several world class examples of such marks. Some have now failed completely and many more would have without federal intervention. Lending, in the leveraged/banking sense, involves all major types of risk: credit risk, market risk, operational risk and business risk. And, beyond the identifiable and potentially insurable portions of these risks, like any business, it includes the risk of unexpected loss, which needs to be covered by capital. Banks have developed policies and guidelines to mitigate, identify and measure many of their risks. These all fall under the world of risk management and these efforts all cost something. There is no free way to offset risk – other than not doing the loan at all. But lending is the business of banking, isn’t it? Further, the risk mitigation efforts cost more or less depending on the various risk characteristics of the bank’s loan portfolio each loan. For instance, a floating rate loan involves little market risk and requires little if any expense to offset. A five-year fixed rate, interest-only loan involves a lot of market risk and that costs something to offset. Alternatively, a loan with a pass risk rating of ‘2’ involves a much lower likelihood of defaulting than a loan with a pass risk rating of ‘4’. The lower risk loan; therefore, involves less of an ALLL (Allowance for Loan and Lease Losses) reserve and provisioning expense.  Also, an owner occupied commercial mortgage is normally much less expensive to monitor than a credit backing a floor plan or construction project. Those cost differences could be reflected in the pricing. Finally, for today, the amount of risk capital needed to back these kinds of differing loan characteristics, for purposes of unexpected loss, is substantially different. If these kinds of differences are not priced into the loans somehow, one of two situations exists: Either the bank is not getting paid for the risk it is incurring; or, If it is, it is charging the lower risk borrowers a rate that pays for added risk-adjusted expenses of the higher risk borrowers. The business risk to the bank then becomes losing the better clients over time in lieu of attracting the riskier deals. This process has a name: adverse selection. The ongoing expenses of risk mitigation and the negative impact of unexpected losses on retained earnings, over time, materially hurt the bank’s earnings. Someone is paying for all of the risks of being in the business of lending and it’s usually one of two groups: the customers or the shareholders. In the worst of cases, it’s also the taxpayers. The idea of risk-based pricing, at the loan level, is to have the clients pay for the risks the bank is incurring on their behalf by pricing the loan appropriately from the beginning. As a result: This tends to protect, and often enhance, the bank’s financial performance; It is clever; It puts some teeth in the bank’s already existing risk management policies; It is justifiable to the client; and It even makes sense to most lending officers. Fortunately, loan pricing analysis is a scalable activity and possible for most any size bank. It is a smarter way of banking than a one-size-fits-all approach -- even without considering the governance improvement.  

Published: January 29, 2009 by Guest Contributor

Part 1 In reality, we are always facing potential issues in our small business portfolio, it is just the nature of that particular beast. Real problems occur, though, when we begin to take the attitude that nothing can go wrong, that we have finally found the magic formula that has created the invincible portfolio.  We’re in trouble when we actually believe that we have the perfect origination machine to generate a portfolio that has a constant and acceptable delinquency and charge-off performance. So, we all can agree that we need to keep a watchful eye on the small business portfolio.  But how do we do this?  How do we monitor a portfolio that has a high number of accounts but a relatively low dollar amount in actual outstandings? The traditional commercial portfolio provides sufficient operating income and poses enough individual client credit risk that we can take the same approach on each individual credit and still maintain an acceptable level of profitability.  But, the small business portfolio doesn’t generate sufficient profitability nor has individual loan risk to utilize the traditional commercial loan portfolio risk management techniques. Facing these economic constraints, the typical approach is to simply monitor by delinquency and address the problems as they arise.  One traditional method that is typically retained is the annual maturity of the lines of credit.  Because of loan matures, financial institutions are performing annual renewals and re-underwriting these lines of credit -- and complete that process through a full re-documentation of the line. We make nominal improvements in the process by changing the maturity dates of the lines from one year to two or three year maturities or, in the case of real estate secured lines, a five year maturity.  While such an approach reduces the number of renewals that must be performed in a particular year, it does not change the basic methodology of portfolio risk management, regularly scheduled reviews of the lines.  In addition, such methodology simply puts us back to the use of collections to actually manage the portfolio and only serves to extend the time between reviews. Visit my next post for the additional pitfalls around individual risk rating and ways to better monitor your small business portfolio.

Published: January 15, 2009 by Guest Contributor

By: Tom Hannagan I have referred to risk-adjusted commercial loan pricing (or the lack of it) in previous posts. At times, I’ve commented on aspects of risk-based pricing and risk-based bank performance measurement, but I haven’t discussed what risk-based pricing is -- in a comprehensive manner. Perhaps I can begin to do that now and in my next posts. Risk-based pricing analysis is a product-level microcosm of risk-based bank performance. It begins by looking at the financial implications of a product sale from a cost accounting perspective. This means calculating the revenues associated with a loan, including the interest income and any fee-based income.  These revenues need to be spread over the life of the loan, while taking into account the amortization characteristics of the balance (or average usage for a line of credit). To save effort (and to provide good client relationship management), we often download the balance and rate information for existing loans from a bank’s loan accounting system. To “risk-adjust” the interest income, you need to apply a cost of funds that has the same implied market risk characteristics as the loan balance. This is not like the bank’s actual cost of funds for several reasons. Most importantly, there is usually no automatic risk-based matching between the manner in which the bank makes loans and the term characteristics of its deposits and/or borrowing. Once we establish a cost of funds approach that removes interest rate risk from the loan, we subtract the risk-adjusted interest expense from the revenues to arrive at risk-adjusted net interest income, or our risk-adjusted gross margin. We then subtract two types of costs. One cost includes the administrative or overhead expenses associated with the product. Our best practice is to derive an approach to operating expense breakdowns that takes into account all of the bank’s non-interest expenses. This is a “full absorption” method of cost accounting. We want to know the marginal cost of doing business, but if we just apply the marginal cost to all loans, a large portion of real-life expenses won’t be covered by resulting pricing. As a result, the bank’s profits may suffer. We fully understand the argument for marginal cost coverage, but have seen the unfortunate end. Using this lower cost factor can hurt a bank’s bottom line. Administrative cost does not normally require additional risk adjustment, as any risk-based operational expenses and costs of mitigating operation risk are already included in the bank’s general ledger for non-interest expenses. The second expense subtracted from net interest income is credit risk cost. This is not the same as the bank’s provision expense, and is certainly not the same as the loss provision in any one accounting period.  The credit risk cost for pricing purposes should be risk adjusted based on both product type (usually loan collateral category) and the bank’s risk rating for the loan in question. This metric will calculate the relative probability of default for the borrower combined with the loss given default for the loan type in question. We usually annualize the expected loss numbers by taking into account a multi-year history and a one- or two-year projection of net loan losses. These losses are broken down by loan type and risk rating based on the bank’s actual distribution of loan balances. The risk costs by risk rating are then created using an up-sloping curve that is similar in shape to an industry default experience curve. This assures a realistic differentiation of losses by risk rating. Many banks have loss curves that are too flat in nature, resulting in little or no price differentiation based on credit quality. This leads to poor risk-based performance metrics and, ultimately, to poor overall financial performance. The loss expense curves are fine-tuned so that over a period of years the total credit risk costs, when applied to the entire portfolio, should cover the average annual expected loss experience of the bank. By subtracting the operating expenses and credit risk loss from risk-adjusted net interest income, we arrive at risk-adjusted pre-tax income. In my next post I’ll expand this discussion further to risk-adjusted net income, capital allocation for unexpected loss and profit ratio considerations.

Published: January 7, 2009 by Guest Contributor

By: Tom Hannagan Here’s a further review of results from the Uniform Bank Performance Reports, courtesy of the FDIC, through the third quarter of this year. (See my Dec. 18 post.) The UBPR is based on quarterly call reports that insured banks are required to submit. I wanted to see how the various profit performance components compare to the costs of credit risks discussed in my previous post. The short of it is that banks have a ways to go to be fully pricing for both expected and unexpected risk. (See my Dec. 5 blog dealing with risk definitions.) The FDIC compiles peer averages for various bank size groupings. Here are some findings for the two largest groups, covering 490 reporting banks. Here are the results: Peer Group 1 consists of 186 institutions with over $3 billion in average total assets for the first nine months. • Net interest income was 5.34 percent of average total assets for the period. This is down, as we might expect based on this year’s decline in the general level of interest rates, from 6.16 percent in 2007. • Net interest expense was also down from 2.98 percent in 2007 to 2.16 percent for the nine months to September 30th. • Net interest margin, the difference between the two metrics, was down slightly from 3.16 percent in 2007 to 3.14 percent so far in 2008, or a loss of 2 basis points. It should be noted that net interest margins have been in steady decline for at least ten years, with a torturous regular drop of 2 to 5 basis points per annum in recent years. This year’s drop is not that bad, although it does add to the difficulty in generating bottom-line profits. To find out a bit more about the drop in margins, especially in light of the steady increase in lending over the same past decade, I looked at loans yields. • Loan yields averaged 6.22 percent for 2008, down (again, expectedly) from 7.32 percent in 2007. This is a drop of 110 basis points or a decline of 15 percent. • Meanwhile, rates paid on interest-earning deposits dropped from 3.41 percent in 2007 to 2.48 percent so far in 2008. This 93 basis point decline represents a 27 percent lower cost of interest-bearing deposits.   It seems as though margins should have improved somewhat -- not declined for these banks.   Digging a bit deeper, I see two possible reasons. • First, total deposit balances declined from 72 percent of average assets to 70 percent, meaning a larger amount had to be borrowed to fund assets. • Second, non-interest bearing demand deposits declined from 4.85 percent of average assets to 4.49 percent.   So, fewer deposit balances relative to total asset size, along with a lower proportion of interest-cost-free deposits, appear to have made the difference. Unfortunately, the ”big news” is that margins were only down a bit. Let’s move on to fee income. Non-interest income, again, as a percent of average total assets, was down to 1.14 percent from 1.23 percent in 2007. For this bank group, fees have also been steadily declining relative to asset size, down from 1.49 percent of assets in 2005. A lot of fee income is deposit based, and largely based on non-interest bearing deposits – and, thus, a source of pressure on fee income. Operating expenses constituted some good news as they declined from 2.63 percent to 2.61 percent of average assets. That’s 2 basis points to the good. Hey, an improvement is an improvement. Historically this metric has generally moved down, but irregularly from year to year. The number stood at 2.54 percent in 2006, for instance. As a result of the slight decline in margins and the larger percentage decline in fee income, the Peer Group 1 efficiency ratio lost ground from 57.71 percent in 2007 to only 58.78 percent in 2008. That means the every dollar in gross revenue [net interest income plus fee income] cost them almost 58 cents in administrative expenses so far this year. This metric averaged 55 cents in 2005/2006. The total impact of margin performance, fee income and operating expenses, if you’ve been tallying along, is a net decline of 0.09 percent on total assets. When we add this to the 2008 increase in provision expense of 57 basis points, we arrive at a total decline in pre-tax operating income of 0.66 percent on total assets. (See my Dec. 18 post.) That is a total decline of 44 percent from the pre-tax performance in 2007 for banks over $3 billion in assets. It would appear that banks are not pricing enough risk into their loan rates yet – for their own bottom line performance. This would be further confirmed if you compared bank loan rates to the historic risk spreads and absolute rates that the market currently has priced into investment grade and other corporate bonds. They are probably at extremes but still they say more credit risk is present than bank lending rates/yields would indicate.   For Peer Group 2, consisting of 304 reporting banks between $1 billion and $3 billion in assets: • Net interest income was 5.87 percent of average total assets for the period. This is also down, as expected, from 6.73 percent in 2007. • Net interest expense was also down from 3.07 percent in 2007 to 2.39 percent for the nine months to September 30th. • Net interest margin, was down from 3.66 percent in 2007 to 3.48 percent so far in 2008, or a loss of 18 basis points. These margins are at somewhat higher levels than found in Peer Group 1, but the drop of .18 percent was much larger than the decline in Peer Group 1.   As with all banks, net interest margins have been in steady chronic decline, but the drops for Peer Group 2 have been coming in larger chunks the last two years, down 18 points this year so far, after dropping 16 points from 2006 to 2007. Behind the drop in margins, loans yields are 6.69 percent for 2008, down from 7.82 percent in 2007. This is a drop of 113 basis points or a decline of 14 percent. Meanwhile rates paid on interest-earning deposits dropped from 3.70 percent in 2007 to 2.85 percent so far in 2008. This 85 basis point decline represents a 23 percent lower cost of interest-bearing deposits. Again, with a steeper decline in interest costs, you’d think margins should have improved somewhat. That didn’t happen. I notice the same two culprits. • Total deposit balances declined from 78 percent of average assets to 76 percent, meaning, again, a larger amount had to be borrowed to fund assets. • Also, non-interest bearing demand deposits continued an already steady decline from 5.58 percent of average assets in 2007 to 5.08 percent.   Fewer deposit balances relative to total asset size…along with a lower proportion of interest-cost-free deposits…and we know the result. Now, about fee income for these banks… Non-interest income, again as a percent of average total assets, was down to 0.92 percent from 0.95 percent in 2007. For this bank group, fees have also been steadily declining relative to asset size, down from 1.04 percent of assets in 2005. A smaller non-interest bearing deposit base, without other new and offsetting sources of fee income, will mean pressure on this metric. Operating expenses constituted some good news here as well. They declined from 2.79 percent to 2.75 percent of average assets. That’s 4 basis points to the good. Historically this metric has been flatter for this size bank, moving up or down a bit from year to year. As a result of the not-so-slight decline in margins and the continued decline in fee income, the Peer Group 2 efficiency ratio lost ground from 59.52 percent in 2007 to only 61.86 percent in 2008. That means the every dollar in gross revenue cost these banks almost 62 cents in administrative expenses so far this year. This metric averaged 56 cents in 2005/2006. The total impact of margin performance, fee income and operating expenses is a net decline of 0.17 percent on total assets. When we add this to the 2008 increase in provision expense of 36 basis points, we arrive at a total decline in pre-tax operating income of 0.53 percent on total assets. (See my Dec. 18 post.) That is a total decline of 34 percent from the pre-tax performance in 2007. As I concluded above, more credit risk is present than bank lending rates/yields would indicate. Although all 490 banks are declining in efficiency, the larger banks have a scale edge in this regard. The somewhat smaller banks seem to have an edge in pricing loans, but not regarding deposits. Although up dramatically in 2007 and even more this year for both groups, the Peer Group 2 banks seem to be suffering fewer credit losses relative to their asset size than their larger brethren. Both groups have resulting huge profit declines, but the largest banks are under the most pressure through this period. It’s interesting to note that, with higher loan yields and fewer apparent losses, Peer Group 2 banks are somewhat better at risk-adjusted loan pricing than the largest bank group. Results are results. The fourth quarter numbers aren’t expected to show a lot of improvement as the general economy continues to slow and credit issues continue. I’ll comment on entire year’s results in posts early next year.     Next year, too, look for my comments on risk management solutions especially relevant to enterprise risk management.

Published: December 23, 2008 by Guest Contributor

By: Tom Hannagan I reviewed the Uniform Bank Performance Reports (UBPR: (http://www2.fdic.gov/ubpr/ReportTypes.asp ) for selected clients through the third quarter of this year. The UBPR is a compilation of the FDIC, based on the call reports submitted by insured banks. The FDIC reports peer averages for various bank size groupings.   Here are a few findings for the two largest groups, covering 490 banks. Peer Group 1 consists of 186 institutions over $3 billion in average total assets for the first nine months. Net loans accounted for 67.59 percent of average total assets, up from 65.79 percent in 2007. Loans, as a percent of assets, have increased steadily since at least 2005. The loan-to-deposit ratio for the largest banks was also up to 97 percent, from 91 percent in 2007 and 88 percent in both 2006 and 2005. So, it appears these banks are lending more, at least through the September quarter, as an allocation of their asset base and relative to their deposit source of funding. In fact, net loans grew at a rate of 11.51 percent for the group through September, which is down from the average growth rate of 15.07 percent for the years 2005 through 2007.  But, it is still growth. For Peer Group 2, consisting of 304 reporting banks between $1billion and $3 billion in assets, net loans accounted for 72.57 percent of average total assets, up from 71.75 percent in 2007. Again, the loans as a percent of assets have increased steadily since at least 2005. The loan-to-deposit ratio for these banks was up to 95 percent, from 92 percent in 2007 and an average of 90 percent for 2006 and 2005. So, these banks are also lending more, at least through the September quarter, as a portion of their asset base and relative to their deposit source of funding. In fact, net loans grew at a rate of 12.57 percent for the group through September, which is up from 11.94 percent growth in 2007 and down from an average growth of 15.04 percent for 2006 and 2005.  Combined, for these 490 largest institutions, loans were still growing through September. More loans probably mean more credit risk. Credit costs were up. The Peer Group 1 banks reported net loan losses of 0.67 percent of total loans, up from 0.28 percent in 2007, which was up from an average of 18 basis points on the portfolio in 2006/2005.  The Group 2 banks reported net loan losses of 0.54 percent, also up substantially from 24 basis points in 2007, and an average of 15 basis points in 2006/2005. Both groups also ramped up their reserve for future expected losses substantially. The September 30th allowance for loan and lease losses (ALLL) as a percent of total loans stood at 1.52 percent for the largest banks, up from 1.20 percent in 2007 and an average of 1.11 percent in 2006/2005. Peer Group 2 banks saw their allocation for losses up to 1.40 percent from 1.22 percent in 2007 and 1.16 percent in 2006. So, lending is up even in the face of increased write-offs, increased expected losses and the burden of higher expenses for these increased loss reserves. Obviously, we would expect this to negatively impact earnings. It did, greatly. Peer Group 1 banks saw a decline in return on assets to 0.42 percent, from 0.96 percent in 2007 and an average of 1.26 percent in 2006/2005. That is a decline in return on assets (ROA) of 56 percent from 2007 and a decline of 68 percent from the 2006/2005 era. Return on equity declined even more. ROE was at 5.21 percent through September for the large bank group, down from 11.97 percent in 2007. ROE stood at 14.36 percent in 2005. For the $1 billion to $3 billion banks, ROA stood at 0.66 percent for the nine months, down from 1.08 percent in 2007, 1.30 percent in 2006 and 1.33 percent in 2005. The decline in 2008 was 39 percent from 2007. Return on equity (ROE) for the group was also down at 7.71 percent from 12.37 percent in 2007. The drops in profitability were not entirely the result of credit losses, but this was by far the largest impact from 2007 and earlier. The beefed-up ALLL accounts would seem to indicate that, as a group, the banks expect further loan losses in the remainder of 2008 and into 2009.  All of these numbers pre-dated the launch of the TARP program, but it is clear that banks had not contracted lending through the first three quarter of 2008, even in the face of mounting credit issues, cost of credit, challenges regarding loan pricing and profitability, net interest margins,  and the generally declining economic picture. It will be interesting to see how things unfold in the next several quarter [See my December 5th post about ROE versus ROA.] Disclosure: No positions.

Published: December 18, 2008 by Guest Contributor

In my last blog, I talked about the overall need for a vision for your loan portfolio and the similarity of a loan portfolio to that of an investment portfolio.  Now that we have that vision in place, we can focus on the overall strategy to achieve that vision. A valuable first step in managing an investment portfolio is to establish a targeted value by a certain time (say, our targeted retirement age).  Similarly, it’s important that we establish our vision for the loan portfolio regarding overall diversification, return and risk levels. The next step is to create a strategy to achieve the targeted state.  By focusing on the gaps between our current state and the vision state we have created, we can develop an action plan for achieving the future/vision state.  I am going to introduce some rather unique ideas here. Consider which of your portfolio segments are overweight?  One that comes to mind would be the commercial real estate portfolio.  The binge that has taken place over the past five plus years has resulted in an unhealthy concentration of loans in the commercial real estate segment.  In this one area alone, we will face the greatest challenge of right-sizing our portfolio mix and achieving the appropriate risk model per our vision. We have to assess our overall credit risk in the portfolios next.  For small business and consumer portfolios, this is relatively easy using the various credit scores that are available to assess the current risk.  For the larger commercial and industrial portfolios and the commercial real estate portfolios, we must employ some more manual processes to assess risk.  Unfortunately, we have to perform appropriate risk assessments (current up-to-date risk assessments) in order to move on to the next stage of this overall process (which is to execute on the strategy). Once we have the dollar amounts of either growth or divestiture in various portfolio segments, we can employ the risk assessment to determine the appropriate execution of either growth or divestiture. Stick with me on this topic because in my next blog we will discuss appropriate risk assessment methodologies and determine appropriate portfolio distributions/segmentations.

Published: December 8, 2008 by Guest Contributor

By: Tom Hannagan I was hoping someone would ask about this. Return on Equity (ROE) is generally net income divided by equity, while Return on Assets (ROA) is net income divided by average assets. There you have it. The calculations are pretty easy. But, what do they mean? ROA tends to tell us how effectively an organization is taking earnings advantage of its base of assets.  This used to be the most popular way of comparing banks to each other -- and for banks to monitor their own performance from period to period. Many banks and bank executives still prefer to use ROA…though typically at the smaller banks. ROE tends to tell us how effectively an organization is taking advantage of its base of equity, or capital. This has gained in popularity for several reasons and has become the preferred measure at larger banks. One huge reason for the growing popularity of ROE is, simply, that it is not asset-dependent. ROE can be applied to any line of business or any product. You must have “assets” for ROA, since one cannot divide by zero. This flexibility allows banks with differing asset structures to be compared to each other, or even for banks to be compared to other types of businesses. The asset-independency of ROE also allows a bank to compare internal product line performance to each other. Perhaps most importantly, this permits looking at the comparative profitability of lines of business like deposit services. This would be difficult, if even possible, using ROA. If you are interested in how well a bank is managing its assets, or perhaps its overall size, ROA may be of assistance. Lately, what constitutes a good and valid portrayal of assets has come into question at several of the largest banks. Any measure is only as good as its components. Be sure you have a good measure of asset value, including credit risk adjustments. ROE on the other hand looks at how effectively a bank (or any business) is using shareholders’ equity. Many observers like ROE, since equity represents the owners’ interest in the business. Their equity investment is fully at risk compared to other sources of funds supporting the bank. Shareholders are the last in line if the going gets rough. So, equity capital tends to be the most expensive source of funds, carrying the largest risk premium of all funding options. Its deployment is critical to the success, even the survival, of the bank. Indeed, capital allocation or deployment is the most important executive decision facing the leadership of any organization. If that isn’t enough, ROE is also Warren Buffet’s favorite measure of performance. Finally, there are the risk implications of the two metrics. ROA can be risk-adjusted up to a point. The net income figure can be risk adjusted for mitigated interest rate risk and for expected credit risk that is mitigated by a loan loss provision. The big missing element in even a well risk-adjusted ROA metric is unexpected loss (UL). Unexpected loss, along with any unmitigated expected loss, is covered by capital. Further, aside from the economic capital associated with unexpected loss, there are regulatory capital requirements. This capital is left out of the ROA metric. This is true at the entity level and for any line-of-business performance measures internally. Since ROE uses shareholder equity as its divisor, and the equity is risk-based capital, the result is, more or less, automatically risk-adjusted. In addition to the risk adjustments in its numerator, net income, ROE can use an economic capital amount. The result is a risk-adjusted return on capital, or RAROC. RAROC takes ROE to a fully risk-adjusted metric that can be used at the entity level and that can also be broken down for any and all lines of business within the organization. As discussed in the last post, ROE and RAROC help a bank get to the point where they are more fully “accounting” for risk – or “unpredictable variability”. Sorry about all of the alphabet soup, but there is a natural progression that I’m pointing to that we do see banks working their way through. That progression is being led by the larger banks that need to meet more sophisticated capital reporting requirements, and is being followed by other banks as they get more interested in risk-adjusted monitoring as a performance measurement. The better bank leadership is at measuring risk-adjusted performance, using ROE or RAROC, the better leadership can become at pricing for all risk at the client relationship and product levels.

Published: December 5, 2008 by Guest Contributor

The pendulum has definitely swung back in favor of the credit discipline within financial institutions. The free wheeling credit standards of the past have proven once again to be problematic. So, things like cost of credit, credit risk modeling, and scoring models are back in fashion. The trouble that we have created is that, in an effort to promote greater emphasis on the sales role, we centralized the underwriting function. This centralization allowed the sales team to focus on business development and underwriting, on credit. The unintended result, however, is that we removed the urgent need to develop credit professionals. Instead, we pushed for greater efficiencies and productivity in underwriting -- further stalling any consideration for the development of the credit professional.   Now we find ourselves with more problem credits than we have seen in the past 20 years and the pool of true credit professionals is nearly gone.   Once this current environment is corrected, let\'s be sure to keep balance in mind. Again, soundness, profitability and growth -- in that order of priority.

Published: November 19, 2008 by Guest Contributor

By: Tom Hannagan In previous posts, we’ve dealt with the role of risk-based capital, measuring performance based on risk characteristics and the need for risk-based loan pricing. What about risk mitigation? Some of the greatest sins of the financial industry in the current malaise have been the lack of transparency, use of complex transactions to transfer risk and the creation of off-balance-sheet entities to house dodgy investments. Much has been made of the role of Credit Default Swaps (CDSS) as one of the unregulated markets (and therefore guilty parts) of the current credit meltdown. The regulatory agencies and the media are aghast at the volume (peak of some $62 trillion in notional value) of CDSS that have resulted from a totally private market. The likes of Lehman Brothers, Bear Sterns and AIG were all big issuers of CDSS. And the trillions of notional value of open CDSS is as much as 100 times the underlying value of the actual debt being insured. There are problems here, but it may be worth clarifying the useful risk management activities from the potentially abusive excesses involving such instruments. CDSS are derivative contracts whereby one party buys credit protection from a counterparty. The buyer pays a premium to the seller either in a lump sum or periodically over the life of the contract. If a credit event such as a default on a loan or a bond occurs, the seller of the CDSS pays the holder for the loss or purchases the initial debt, the reference obligation, at a pre-set price.  So, a CDSS is in effect a put option that is deep-out-of-the-money. They expire upon termination and most are never exercised. They are subject to fair-value accounting and can change in value from month to month as the credit markets premiums for similar cover moves up or down. Banks and others can use CDSS to, in effect, adjust the nature of credit risk in their portfolios by both buying and selling such contracts. Asset securitizations, whether mortgage-backed securities or other formulations, are in fact broken-down and re-packaged forms of assets that can be sold -- transferring certain rights, values and risk to another party for payment received. They are complex and therefore mostly opaque to the general public and even many practitioners. They often involve the use of special purpose entities or trusts that can further confuse investors. These tactics have added to the difficulty of the credit crisis and the collapse of capital markets. But, CDSS are contingent in nature and act more like fire insurance or a back-up data center. Such operational expenses are intended to control risks. The accounting treatment is complex and, to an extent (especially as regards the tax treatment), still not well defined by accounting authorities. For most banks, and most CDSS contract, the premium is amortized over the life of the contract. The premium expense entry in their general ledgers is an expense of doing business that is intended to alleviate some credit risk. We are now talking about a covered CDSS, where the bank has extended credit or invested in a debt instrument. Those who purchased uncovered CDSS are gambling on a default occurrence and used CDSS as a more cost-effective (and secretive) alternative to shorting securities. It is somewhat like a naked short. So, a covered CDSS is ultimately an expense associated with protecting the net asset value of a credit transaction. Importantly, this expense should be included in any performance analysis or pricing of the risk-adjusted profitability of the credit obligation and/or client relationship involved. This risk mitigation exercise may be in lieu of a higher required rate or fee on an otherwise uncovered/unmitigated credit transaction, or being satisfied with a lower risk-adjusted return where the bank assumes (self-insures) all of the credit risk. CDSS quotes/costs, similar to rate spreads on corporate bonds, are the open market’s current feeling regarding an entity’s credit quality or relative probability of default. There are some 400 or so participants in the CDSS market, including writers and dealers. Market data is published for many obligations. Even the previously risk-free Treasury securities now have CDSS quotes – and they have gone up considerably in recent months. It is always the buyers’ responsibility to decide if the quoted prices make sense or not and how such quotes should be used in evaluating credit and negotiating lending opportunities in addition to whether or not to purchase this insurance. Finally, the quality of the seller is a consideration. There is no good reason to buy fire insurance from someone that might not be able to pay for your building if it burns down. CDSS have been private party transactions and, as stated earlier, there have been solvency problems with some of the sellers of such instruments. There is now a move under way to create a central exchange for such transactions with both regulations governing the sellers, more standardized contracts and financial backing of the instruments from the exchange. Such an exchange will address both the transparency of the process and the efficiency of market prices. Risk mitigation strategies (risk-based pricing, portfolio risk management, credit risk modeling, etc.) need to be carried out thoughtfully. If something sounds too good to be true, it deserves a deeper look. Your bank’s credit regimen may well be better at evaluating default probability than a marketplace that is prone to feed on its own fears. But, CDSS “insurance” quotes are an outside point of reference and an option to mitigate some credit risk…no pun intended. Here are two interesting sources of information: *  BNET Business Network * Georgetown University -- Law Center

Published: November 18, 2008 by Guest Contributor

Just as with diet recommendations, moderation needs to be the new motto for credit risk management.  Diets provide for the occasional bag of chips or dessert after dinner, but these same food items become problems if the small quantity or occasional indulgence suddenly becomes the norm.   Similarly, we, in our risk management efforts, put forth guidelines that establish limitations on certain loan types or categories that have been deemed risky should the numbers or quantity become too large a part of the overall portfolio.  Unfortunately, we have a tendency to allow earnings or portfolio growth to cloud our judgment and take an attitude of “just one more.”   In the past several years, we have experienced excesses in commercial real estate, residential development and subprime mortgages.  It is now these excesses that are creating the problems that we are dealing with today.   Bringing back these limitations – in other words, reestablishing the discipline in our portfolio risk management – will go a long way in avoiding these same problems in the future.   As I learned early in my banking career:  “…soundness, profitability and growth…in that order.”

Published: November 13, 2008 by Guest Contributor

Whenever an industry encounters problems, the natural tendency is to play the blame game.  In the banking industry, credit risk managers are looking for who or what to blame for the tide of charge offs and delinquencies in their under-performing loan portfolios and in their commercial loan origination operations.  Credit scoring has definitely taken it on the chin as an easy target during 2008. Is credit scoring the problem? Absolutely not! As with anything, the more complacent we become…and the more we “turn off our brains” and stop thinking…the more risk we assume.  The more we solely rely upon the credit score alone, the more we subject ourselves to the risks inherent in “score and go” lending. We are all well aware that credit scoring measures propensity to repay and not capacity to repay.  Over the past several years, the propensity to repay has been boosted by ever-increasing real estate values and by the refinance boom.  For example, some consumers have been able to survive on a 50 percent debt–to- income due to constant use of credit cards …by paying off those cards with a home mortgage refinance.  That set of behaviors would have shown a propensity to repay…but  was it ever acceptable to have 50 percent of your income go to debt payments?! Statistically it may have worked for a few years, but once real estate values stopped escalating, the problem with lack of capacity to repay reared its ugly head. When it comes to risk management, let’s get back to reality and sound principles.

Published: November 11, 2008 by Guest Contributor

By: Tom Hannagan In my last post, I addressed the need for banks to advance their management of risk to include the relationship between capital and risk in their internal decisions and actions. While it is difficult for me to make this topic very exciting, it can’t be ignored. It very nearly resulted in bankrupting the global financial system. Beyond profitability, bank executives must measure and monitor their risk-based capital because: 1) equity capital represents the ownership interest in a bank; 2) equity capital is by far the most expensive source of funding; and 3) the risk associated with capital sufficiency and continued solvency is important. As Colonel Jessup might confirm, “Yes, we’re talking about mortal danger”. Many are scrambling to apply for the TARP (Troubled Asset Relief Program) capital infusion – and most are getting approved for these windfall funds. (Today’s investment advice from the experts: don’t buy common shares in any bank that applied and was turned down.) Let’s take a look at the impact of these funds. If we were, for example, a $10 billion total asset bank, with say $800 million in equity capital prior to TARP and had roughly $700 million in risk-weighted assets, we might get approved for $200 million in TARP-related preferred shares at a cost of 5 percent (after tax) for the next five years. If, our make believe $10 billion bank was earning an average pre-2008 economic-and-credit-crisis return on assets of 1 percent, or $100 million per annum, what are the implications of the added $200 million in capital on future earnings? That $100 million in “pre-crisis” earnings represented a return on equity of 12.5 percent on our original capital of $800 million. (Stay with me, now…)   Since we need to pay the Feds (our new shareholders) $10 million in preferred dividends per annum in after-tax money, we need to earn an added $16 million in pre-tax operating income just to break even on the deal. That would mean, in our otherwise static model, that earnings need to move from $100 million to $110 million. More importantly, pre-tax income needs to move from say $150 million to $166 million, assuming about a 33 percent effective tax rate. We’ve got the fresh $200 million to work with, assuming we don’t need part of it to cover credit charge-offs or other asset write-downs. To earn $16 million from that $200 million investment, we would need an 8  percent pre-tax operating income (that’s after expenses, folks). I’m open to suggestions at this point...And you thought banking was easy. You do that the old fashion way -- with leverage. You use the $200 million to get someone (depositors, the Federal Home Loan Bank, a Federal Reserve Bank, or anyone else) to give you more money to invest (at a critically important tax-deductible cost) along with your fresh $200 million in preferred equity. Remember, our bank is already operating with leverage, supporting $7 billion in risk-weighted assets, and $10 billion in total assets, with the pre-existing $800 million in capital. Unfortunately, leverage involves at least liquidity risk, and probably market risk -- on top of whatever direct (credit, market, operational) risks are associated with whatever end investment you choose (…and the Feds hope you choose loans). Obviously, the fastest way to get the added leverage, along with a quick addition to earnings assets, is to go buy another bank (and absorb them more successfully than the two of you ran separately). Thus, a new round of consolidation has begun. Regardless of the method used to grow into the TARP money, any bank that doesn’t take into account the risks associated with these decisions/actions is merely kidding itself. TARP funding will not make any real headway in improving risk-adjusted earnings going forward. There is (and always has been) a direct relationship between actual risk and risk-adjusted return.  It is now more important than ever for bank management to monitor and measure their organization’s activities (loan pricing and profitability, investing, deposit taking, investment management, credit risk modeling, buying other banks...and anything else they do) based on the relative risk of those activities and based on the equity capital realistically required to support those risks. This means using return on equity measurement internally as well as at the entity level. I look forward to your comments.

Published: November 11, 2008 by Guest Contributor

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