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Well, here we are about two weeks from the Federal Trade Commission’s June 1, 2010 Red Flags Rule enforcement date.  While this date has been a bit of a moving target for the past year or so, I believe this one will stick.  It appears that the new reality is one in which individual trade associations and advocacy groups will, one by one, seek relief from enforcement and related penalties post-June 1.  Here’s why I say that: The American Bar Association has already file suit against the FTC, and in October, 2009, The U.S. District Court for the District of Columbia ruled that the Red Flags Rule is not applicable to attorneys engaged in the practice of law.  While an appeal of this case is still pending, in mid-March, the U.S. District Court for the District of Columbia issued another order declaring that the FTC should postpone enforcement of the Red Flags Rule “with respect to members of the American Institute of Certified Public Accountants” engaged in practice for 90 days after the U.S. Court of Appeals for the District of Columbia renders an opinion in the American Bar Association’s case against the FTC.” Slippery slope here.  Is this what we can expect for the foreseeable future? A rather ambiguous guideline that leaves openings for specific categories of “covered entities” to seek exemption?  The seemingly innocuous element to the definition of “creditor” that includes “businesses or organizations that regularly defer payment for goods or services or provide goods or services and bill customers later” is causing havoc among peripheral industries like healthcare and other professional services. Those of you in banking are locked in for sure, but it ought to be an interesting year as the outliers fight to make sense of it all while they figure out what their identity theft prevention programs should or shouldn’t be.  

A common request for information we receive pertains to shifts in credit score trends. While broader changes in consumer migration are well documented – increases in foreclosure and default have negatively impacted consumer scores for a group of consumers – little analysis exists on the more granular changes between the score tiers. For this blog, I conducted a brief analysis on consumers who held at least one mortgage, and viewed the changes in their score tier distributions over the past three years to see if there was more that could be learned from a closer look. I found the findings to be quite interesting. As you can see by the chart below, the shifts within different VantageScore tiers shows two major phases. Firstly, the changes from 2007 to 2008 reflect the decline in the number of consumers in VantageScore B, C, and D, and the increase in the number of consumers in VantageScore F. This is consistent with the housing crisis and economic issues at that time. Also notable at this time is the increase in VantageScore A proportions. Loan origination trends show that lenders continued to supply credit to these consumers in this period, and the increase in number of consumers considered ‘super prime’ grew. The second phase occurs between 2008 and 2010, where there is a period of stabilization for many of the middle-tier consumers, but a dramatic decline in the number of previously-growing super-prime consumers. The chart shows the decline in proportion of this high-scoring tier and the resulting growth of the next highest tier, which inherited many of the downward-shifting consumers. I find this analysis intriguing since it tends to highlight the recent patterns within the super-prime and prime consumer and adds some new perspective to the management of risk across the score ranges, not just the problematic subprime population that has garnered so much attention. As for the true causes of this change – is unemployment, or declining housing prices are to blame? Obviously, a deeper study into the changes at the top of the score range is necessary to assess the true credit risk, but what is clear is that changes are not consistent across the score spectrum and further analyses must consider the uniqueness of each consumer.

By: Wendy Greenawalt Optimization has become somewhat of a buzzword lately being used to solve all sorts of problems. This got me thinking about what optimizing decisions really means to me? In pondering the question, I decided to start at the beginning and really think about what optimization really stands for. For me, it is an unbiased mathematical way to determine the most advantageous solution to a problem given all the options and variables. At its simplest form, optimization is a tool, which synthesizes data and can be applied to everyday problems such as determining the best route to take when running errands. Everyone is pressed for time these days and finding a few extra minutes or dollars left in our bank account at the end of the month is appealing. The first step to determine my ideal route was to identify the different route options, including toll-roads, factoring the total miles driven, travel time and cost associated with each option. In addition, I incorporated limitations such as required stops, avoid main street, don’t visit the grocery store before lunch and must be back home as quickly as possible. Optimization is a way to take all of these limitations and objectives and simultaneously compare all possible combinations and outcomes to determine the ideal option to maximize a goal, which in this case was to be home as quickly as possible. While this is by its nature a very simple example, optimizing decisions can be applied to home and business in very imaginative and effective means. Business is catching on and optimization is finding its way into more and more businesses to save time and money, which will provide a competitive advantage. I encourage all of you to think about optimization in a new way and explore the opportunities where it can be applied to provide improvements over business-as-usual as well as to improve your quality of life.  

Recently, the Commerce Department reported that consumer spending levels continued to rise in February, increasing for the fifth straight month *, while flat income levels drove savings levels lower. At the same time, media outlets such as Fox Businesses, reported that the consumer “shopping cart” ** showed price increases for the fourth straight month. Somewhat in opposition to this market trend, the Q4 2009 Experian-Oliver Wyman Market Intelligence Reports reveal that the average level of credit card debt per consumer decreased overall, but showed increases in only one score band. In the Q4 reports, the score band that demonstrated balance increases was VantageScore A – the super prime consumer - whose average balance went up $30 to $1,739. In this time of economic challenge and pressure on household incomes, it’s interesting to see that the lower credit scoring consumers display the characteristics of improved credit management and deleveraging; while at the same time, consumers with credit scores in the low-risk tiers may be showing signs of increased expenses and deteriorated savings. Recent delinquency trends support that low-risk consumers are deteriorating in performance for some product vintages. Even more interestingly, Chris Low, Chief Economist at FTN Financial in New York was quoted as saying "I guess the big takeaway is that consumers are comfortably consuming again. We have positive numbers five months in a row since October, which I guess is a good sign,".  I suggest that there needs to be more analysis applied within the details of these figures to determine whether consumers really are ‘comfortable’ with their spending, or whether this is just a broad assumption that is masking the uncomfortable realities that lie within.

In the past few days I’ve read several articles discussing how lenders are taking various actions to reduce their exposure to toxic mortgages – some, like Bank of America, are engaging new principal repayment programs.*  Others, (including Bank of America) are using existing incentive programs to fast-track the approvals of short-sales to stunt their losses and acquire stronger lenders on existing real-estate assets. Given the range of options available to lenders, there are significant decisions to make regarding the creditworthiness of existing consumers and which treatment strategies are best for each borrower, these decisions important for assessing credit risk, loan origination strategies and loan pricing and profitability.  Experian analysis has uncovered the attributes of borrowers with various borrowing behaviors: strategic defaulters, cash-flow managers, and distressed borrowers, each of whom require a unique treatment strategy. The value of credit attributes and predictive risk scores, like Experian Premier Attributes and VantageScore, has never been higher to lenders. Firms like Bank of America are relying on credit delinquency attributes to segment eligible borrowers for its programs, and should also consider that more extensive use of attributes can further sub-segment its clients based on the total consumer credit profile. Consumers who are late on mortgage payments, yet current on other loans, may be likely to re-default; whereas some consumers may merely need financial planning advice and enhanced money management skills. As lenders develop new methods to manage portfolio risk and deal with toxic assets on their portfolios, they should also continue to seek new and innovative analytics, including optimization, to make the best decisions for their customers, and their business. *  LA Times, March 25, 2010, ‘Bank of America to reduce mortgage principal for some borrowers’

By: Tom Hannagan An autonomic movement describes an action or response that occurs without conscious control. This, I fear, may be occurring at many banks right now related to their risk-based pricing and profit picture for several reasons. First, the credit risk profile of existing customers is subject to continuous change over time. This was always true to some extent. But, as we’ve seen in the latest economic recession, there can be a sizeable risk level migration if enough stress is applied. It is most obvious in the case of delinquencies and defaults, but is also occurring with customers that have performing loans. The question is: how well are we keeping up with the behind-the-scenes changes risk ratings/score ranges? The changes in relative risk levels of our clients are affecting our risk-based profit picture -- and required capital allocation -- without conscious action on our part. Second, the credit risk profile of collateral categories is also subject to change over time. Again, this is not exactly new news. But, as we’ve seen in the latest real estate meltdown and dynamics affecting the valuation of financial instruments, to name two, there can be huge changes in valuation and loss ratios. And, this occurs without making one new loan.  These changes in relative loss-given-default levels are affecting our risk-based expected loss levels, risk-adjusted profit and capital allocation, in a rather autonomic manner. Third, aside from changes in risk profiles of customers and collateral types, the bank’s credit policy may change. The risk management analysis of expected credit losses is continuously (we presume) under examination and refinement by internal credit risk staff. It is certainly getting unprecedented attention by external regulators and auditors. These policy changes need to be reflected in the foundation logic of risk-based pricing and profit models. And that’s just in the world of credit risk. Fourth, there can also be changes in our operating cost structure, including mitigated operational risks, and product volumes that affect the allocation of risk-based non-interest expense to product groups and eventually to clients. Although it isn’t the fault of our clients that our cost structure is changing, for better or worse, we nonetheless expect them to bear the burden of these expenses based on the services we provide to them. Such changes need to be updated in the risk-based profit calculations. Finally, there is the market risk piece of risk management.  It is possible if not likely that our ALCO policies have changed due to lessons from the liquidity crisis of 2008 or the other macro economic events of the last two years. Deposit funds may be more highly valued, for instance. There may also be some rotation in assets from lending. Or, the level of reliance on equity capital may have materially changed. In any event, we are experiencing historically low levels for the price of risk-free (treasury rate curve) funding, which affects the required spread and return on all other securities, including our fully-at-risk equity capital. These changes are occurring apart from customer transactions, but definitely affect the risk-based profit picture of each existing loan or deposit account and, therefore, every customer relationship. If any, let alone all, of the above changes are not reflected in our risk-based performance analysis and reporting, and any pricing of new or renewed services to our customers, then I believe we are involved in autonomic changes in risk-based profitability.

By:Wendy Greenawalt In my last few blogs, I have discussed how optimizing decisions can be leveraged across an organization while considering the impact those decisions have to organizational profits, costs or other business metrics. In this entry, I would like to discuss how this strategy can be used in optimizing decisions at the point of acquisition, while minimizing costs. Determining the right account terms at inception is increasingly important due to recent regulatory legislation such as the Credit Card Act. These regulations have established guidelines specific to consumer age, verification of income, teaser rates and interest rate increases. Complying with these regulations will require changes to existing processes and creation of new toolsets to ensure organizations adhere to the guidelines. These new regulations will not only increase the costs associated with obtaining new customers, but also the long term revenue and value as changes in account terms will have to be carefully considered. The cost of on-boarding and servicing individual accounts continues to escalate, and internal resources remain flat. Due to this, organizations of all sizes are looking for ways to improve efficiency and decisions while minimizing costs. Optimization is an ideal solution to this problem. Optimized strategy trees can be easily implemented into current processes and ensure lending decisions adhere to organizational revenue, growth or cost objectives as well as regulatory requirements.  Optimized strategy trees enable organizations to create executable strategies that provide on-going decisions based upon optimization conducted at a consumer level. Optimized strategy trees outperform manually created trees as they are created utilizing sophisticated mathematical analysis and ensure organizational objectives are adhered to. In addition, an organization can quantify the expected ROI of a given strategy and provide validation in strategies – before implementation. This type of data is not available without the use of a sophisticated optimization software application.  By implementing optimized strategy trees, organizations can minimize the volume of accounts that must be manually reviewed, which results in lower resource costs. In addition, account terms are determined based on organizational priorities leading to increased revenue, retention and profitability.

By: Wendy Greenawalt Marketing is typically one of the largest expenses for an organization while also being a priority to reach short and long-term growth objectives. With the current economic environment, continuing to be unpredictable many organizations have reduced budgets and focused on more risk and recovery activities. However, in the coming year we expect to see improvements and organizations renew their focus to portfolio growth. We expect that campaign budgets will continue to be much lower than what was allocated before the mortgage meltdown but organizations are still looking for gains in efficiency and response to meet business objectives. Creation of optimized marketing strategies is quick and easy when leveraging optimization technology enabling your internal resources to focus on more strategic issues. Whether your objective is to increase organizational or customer level profit, growth in specific product lines or maximizing internal resources optimization can easily identify the right solution while adhering to key business objectives. The advanced software now available enables an organization to compare multiple campaign options simultaneously while analyzing the impact of modifications to revenue, response or other business metrics. Specifically, very detailed product offer information, contact channels, timing, and letter costs from multiple vendors and consumer preferences can all be incorporated into an optimization solution. Once defined the complex mathematical algorithm factors every combination of all variables, which could range in the thousands, are considered at the consumer level to determine the optimal treatment to maximize organizational goals and constraints. In addition, by incorporating optimized decisions into marketing strategies marketers can execute campaigns in a much shorter timeframe allowing an organization to capitalize on changing market conditions and consumer behaviors. To illustrate the benefit of optimization an Experian bankcard client was able to reduced analytical time to launch programs from 7 days to 90 minutes while improving net present value. In my next blog, we will discuss how organizations can cut costs when acquiring new accounts.  

By: Tom Hannagan While waiting on the compilation of fourth quarter banking industry results, I thought it might be interesting to relate the commercial real estate (CRE) risk management position facing commercial banks from the third quarter. CRE risk is an important consideration in enterprise risk management and for loan pricing and profitability. The slowdown in the global economy has affected CRE credit risk because of increased vacancy rates, halted development projects, and the loss of value affecting commercial properties. As CRE loans come up for renewal, many will find that there have equity deficits and that they are facing tightened credit standards. If a commercial property loan started life at 80 percent loan to value, and the property value has dropped 25 percent, the renewed loan balance will be down at least 25 percent, requiring a substantial net payoff from the borrower. This net cash payoff requirement would be tough to accomplish in good times and all-but-impossible for many borrowers in this economy. After all, the main reason for the decline in property value to begin with is its reduced cash flow performance. Following the third quarter numbers, total U.S. commercial real estate is generally estimated at $3.4 to $3.5 trillion. Commercial banks owned just over half of that debt, or about $1.8 trillion according to Federal Reserve and FDIC sources. The (possibly only) good news with that total is that commercial banks owned a relatively small share of the commercial-mortgage-backed securities (CMBS) slice of CRE exposure. CMBS assets were 21 percent of total CRE credit or $714 billion, but banks owned a total of $54 billion, which represented only 3 percent of total bank CRE assets. Unfortunately, the opposite is true for construction lending. U.S. banks, in total, had $486 to $534 billion (depending on the source) in construction and land loans, representing 27 percent to 30 percent of banks’ total CRE holdings. The true credit risk management picture is much more revealing if we cut the numbers by bank size. According to Deutsche Bank research, the largest 97 banks (those with over $10 billion in total assets) had $14.8 trillion in total assets and $1.0 trillion of the banking industry’s CRE credits.  This amounts to about 7 percent of the total assets for this group of larger banks. The 7,500 community banks, with aggregate assets of $2 trillion, had about $786 billion in CRE lending. This amounts to about 28 percent of total assets. That is roughly four times the level of exposure found in the larger banks. The 7 percent level of credit risk average exposure at the large bank group is less than their average level of equity or risk-based capital. For the banks under the $10 billion level, the 28 percent level of CRE exposure is almost three times their average equity position. The riskiest portion of CRE lending is clearly the construction and land development loans. The subtotals in this area confirm where the cumulative risk lies. Again, according to Deutsche Bank research, the largest 97 banks had $299 billion of the banking industry’s $534 billion in construction loans. Although this is 56 percent of total bank construction lending, it amounts to only 2 percent of this group’s total assets.  The 7,500 community banks had aggregate construction loans of $235 billion. This amounts to about 8.5 percent of total assets. That is a bit over four times the level of exposure found in the larger banks. The 2 percent level of construction credit risk exposure at the large bank group is one-fourth of their average level of common equity. At banks under the $10 billion level, the 8.5 percent level of CRE exposure, compared to total assets, is about the same as their average equity position. According to Moody’s, bank have already taken about $90 billion in net loan losses in CRE assets through the third quarter of 2009. That means the industry has perhaps another $150 billion in write-offs coming. This would total $240 billion in CRE credit losses for the banking industry due to this economic downturn. That would equate to 13.3 percent of the banking industry’s share of total CRE credit. With the decline in commercial property values ranging from 10 percent to 40 percent, a 13 percent loss is certainly not a worst case scenario. Banks have ramped up their loss reserves, and although the numbers aren’t out yet, we know many banks have used the fourth quarter 2009 to further bolster their allowances for loan and lease losses (ALLL). The larger the ALLL, the safer the risk-based equity account. Risk managers are aware of all of this and banks are very actively developing their strategies to handle the refunding requirements and, at the same time, be in a position to explain to regulators and external auditor how they are protecting shareholders. But the numbers are very daunting and not every bank will have enough net cash flow and risk equity to cover the inevitable losses.  

By: Amanda Roth Last week, we discussed how pricing with competition is important to ensure sound decision practices are being implemented in the domains of loan pricing and profitability.  The extreme of pricing too high for the market can obviously be detrimental to your organization.  The other extreme can be just as dangerous. Pricing for your profitability, regardless of what the competition is charging in your area, has a few potential issues associated with it regarding management of risk.  For example, the statistics state you can charge 5 percent in your “A” tier and still be profitable, but the competition is charging 7.5 percent for the same tier.  You may be thinking that by offering 5 percent you will attract the “best of the best” to your organization.  However, what your statistics may not be showing you is the risk outside of your applicant base.  If you significantly change the customers you are bringing in, does your risk increase as well, ultimately increasing the cost associated with each loan?   Increased costs will reduce or even eliminate the profitability you had expected. A second potential issue is setting the expectation within the marketplace.  It is often understood with the consumers that when changes occur to the interest rate at the federal level, there will be changes at their local financial institution.  These changes are often very small.  By undercutting your competition by such an extreme amount, your customers may question any attempts to raise rates more than 50bp, if you do experience increased costs as a result of the earlier situation or any other factors.  A safer strategy would be to charge between 6.5 percent and 7 percent, which allows you to obtain some of the best customers, ensure stability within the market, and take advantage of additional profitability while it is available.  This is definitely a winning strategy for all -- and an important consideration as you develop your portfolio risk management objectives.    

By: Amanda Roth Doesn’t that sound strange: Pricing WITH competition?  We are familiar with the sayings of pricing for competition and pricing to be competitive, but did you ever think you would need to price with competition?  When developing a risk-based pricing program, it is important to make sure you do not price against the competition in any extreme.  Some clients decide they want to price lower than the competition regardless of how it impacts their profitability.  However, others price only for profitability without any respect to their competition.  As we discussed last week, risk-based pricing is 80 percent statistics, but 20 percent art -- and competition is part of the artistic portion. Once you complete your profitability analysis (refer to 12/28/2009 posting), you will often need to massage the final interest rate to be applied to loan applications.  If the results of the analysis are that your interest rate needs to be 8.0 percent in your “A” tier to guarantee profitability, but your competition is only charging 6.0 percent, there could be a problem if you go to market with that pricing strategy.  You will probably experience most of your application volume coming to an end, especially those customers with low risk that can obtain the best rates of a lender.  Creativity is the approach you must take to become more competitive while still maintaining profitability.  It may be an approach of offering the 6.0 percent rate to the best 10 percent of your applicant base only, while charging slightly higher rates in your “D” and “E” tiers. Another option may be that you need to look internally at processing efficiencies to determine if there is a way to decrease the overall cost associated with the decision process.  Are there decision strategies in place that are creating a manual decision when more could be automated?  Pricing higher than the market rate can be detrimental to any organization, therefore it is imperative to apply an artistic approach while maintaining the integrity of the statistical analysis. Join us next week to continue this topic of pricing with competition which is, again, an important consideration when developing a risk-based pricing program.  

By: Tom Hannagan Apparently my last post on the role of risk management in the pricing of deposit services hit some nerve ends. That’s good. The industry needs its “nerve ends” tweaked after the dearth of effective risk management that contributed to the financial malaise of the last couple of years. Banks, or any business, can prosper by simply following their competitors’ marketing strategies and meeting or slightly undercutting their prices. The actions of competitors are an important piece of intelligence to consider, but not necessarily optimal for your bank to copy. One question is regarding the “how-to” behind risk-based pricing (RBP) of deposits. The answer has four parts. Let’s see. First, because of the importance and size of the deposit business (yes, it’s a line of business) as a funding source, one needs to isolate the interest rate risk. This is done by transfer pricing, or in a sense, crediting the deposit balances for their marginal value as an offset to borrowing funds. This transfer price has nothing to do with the earnings credit rate used in account analysis – that is a merchandising issue used to generate fee income. Fees, resulting from account analysis, when not waived, affect the profitability of deposit services, but are not a risk element. Two things are critical to the transfer of funding credit: 1) the assumptions regarding the duration, or reliability of the deposit balances and 2) the rate curve used to match the duration. Different types of deposit behave differently based on changes in rates paid. Checking account deposit funds tend to be very loyal or “sticky” - they don’t move around a lot (or easily) because of rate paid, if any. At the other extreme, time deposits tend to be very rate-sensitive and can move (in or out) for small incremental gains. Savings, money market and NOW accounts are in-between. Since deposits are an offset (ultimately) to marginal borrowing, just as loans might (ultimately) require marginal borrowing, we recommend using the same rate curve for both asset and liability transfer pricing. The money is the same thing on both sides of the balance sheet and the rate curve used to fund a loan or credit a deposit should be the same. We believe this will help, greatly, to isolate IRR. It is also seems more fair when explaining the concept to line management. Secondly, although there is essentially no credit risk associated with deposits, there is operational risk. Deposit make up most of the liability side of the balance sheet and therefore the lion’s share of institutional funding. Deposits are also a major source of operational expense. The mitigated operational risks such as physical security, backup processing arrangements, various kinds of insurance and catastrophe plans, are normal expenses of doing business and included in a bank’s financial statements. The costs need to be broken down by deposit category to get a picture of the risk-adjusted operating expenses. The third major consideration for analyzing risk-adjusted deposit profitability is its revenue contribution. Deposit-related fee income can be a very significant number and needs to be allocated to particular deposit category that generates this income. This is an important aspect of the return, along with the risk-adjusted funding value of the balances. It will vary substantially for various deposit types. Time deposits have essentially zero fee income, whereas checking accounts can produce significant revenues. The fourth major consideration is capital. There are unexpected losses associated with deposits that must be covered by risk-based capital – or equity. The unexpected losses include: unmitigated operational risks, any error in transfer pricing the market risk, and business or strategic risk. Although the unexpected losses associated with deposit products are substantially less than found in the lending products, they needs to be taken into account to have a fully risk-adjusted view. It is also necessary to be able to compare the risk-adjusted profit and profitability of such diverse services as found within banking. Enterprise risk management needs to consider all of the lines of business, and all of the products of the organization, on a risk-adjusted performance basis. Otherwise it is impossible to decide on the allocation of resources, including precious capital. Without this risk management view of deposits (just as with loans) it is impossible to price the services in a completely knowledgeable fashion. Good entity governance, asset and liability posturing, and competent line of business management, all require more and better risk-based profit considerations to be an important part of the intelligence used to optimally price deposits.      

By: Amanda Roth The reality of risk-based pricing is that there is not one “end all be all” way of determining what pricing should be applied to your applicants.  The truth is that statistics will only get you so far.  It may get you 80 percent of the final answer, but to whom is 80 percent acceptable?  The other 20 percent must also be addressed. I am specifically referring to those factors that are outside of your control.  For example, does your competition’s pricing impact your ability to price loans?  Have you thought about how loyal customer discounts or incentives may contribute to the success or demise of your program?  Do you have a sensitive population that may have a significant reaction to any risk-base pricing changes?  These questions must be addressed for sound pricing and risk management. Over the next few weeks, we will look at each of these questions in more detail along with tips on how to apply them in your organization.  As the new year is often a time of reflection and change, I would encourage you to let me know what experiences you may be having in your own programs.  I would love to include your thoughts and ideas in this blog.  

By: Tom Hannagan This blog has often discussed many aspects of risk-adjusted pricing for loans. Loans, with their inherent credit risk, certainly deserve a lot of attention when it comes to risk management in banking. But, that doesn’t mean you should ignore the risk management implications found in the other product lines. Enterprise risk management needs to consider all of the lines of business, and all of the products of the organization. This would include the deposit services arena. Deposits make up roughly 65 percent to 75 percent of the liability side of the balance sheet for most financial institutions, representing the lion’s share of their funding source. This is a major source of operational expense and also represents most of the bank’s interest expense. The deposit activity has operational risk, and this large funding source plays a huge role in market risk – including both interest rate risk and liquidity risk. It stands to reason that such risks are considered when pricing deposit services. Unfortunately it is not always the case. Okay, to be honest, it’s too rarely the case. This raises serious entity governance questions. How can such a large operational undertaking, not withstanding the criticality of the funding implications, not be subjected to risk-based pricing considerations? We have seen warnings already that the current low interest rate environment will not last forever. When the economy improves and rates head upwards, banks need to understand the bottom line profit implications. Deposit rate sensitivity across the various deposit types is a huge portion of the impact on net interest income. Risk-based pricing of these services should be considered before committing to provide them. Even without the credit risk implications found on the loan side of the balance sheet, there is still plenty of operational and market risk impact that needs to be taken into account from the liability side. When risk management is not considered and mitigated as part of the day-to-day management of the deposit line of business, the bank is leaving these risks completely to chance. This unmitigated risk increases the portion of overall risk that is then considered to be “unexpected” in nature and thereby increases the equity capital required to support the bank.

By: Amanda Roth The final level of validation for your risk-based pricing program is to validate for profitability.  Not only will this analysis build on the two previous analyses, but it will factor in the cost of making a loan based on the risk associated with that applicant.  Many organizations do not complete this crucial step.  Therefore, they may have the applicants grouped together correctly, but still find themselves unprofitable. The premise of risk-based pricing is that we are pricing to cover the cost associated with an applicant.  If an applicant has a higher probability of delinquency, we can assume there will be additional collection costs, reporting costs, and servicing costs associated with keeping this applicant in good standing.  We must understand what these cost may be, though, before we can price accordingly.  Information of this type can be difficult to determine based on the resources available to your organization.  If you aren’t able to determine the exact amount of time and costs associated with the different loans at different risk levels, there are industry best practices that can be applied. Of primary importance is to factor in the cost to originate, service and terminate a loan based on varying risk levels.  This is the only true way to validate that your pricing program is working to provide profitability to your loan portfolio.