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So here it is! The moment you all have been waiting for–the top ten hot topics of 2009 (in no particular order of importance). 1. Portfolio Risk Management – You should really focus on this topic in 2009. With many institutions already streamlining the origination process, portfolio management is the logical next step. While the foundation is based in credit quality, portfolio management is not just for the credit side. 2. Review of Data (aka “Getting Behind the Numbers”) – We are not talking about scorecard validation; that’s another subject. This is more general. Traditional commercial lending rarely maintains a sophisticated database on its clients. Even when it does, traditional commercial lending rarely analyzes the data. 3. Lowering Costs of Origination – Always a shoe-in for a goal in any year! But how does an institution make meaningful and marked improvements in reducing its costs of origination? 4. Scorecard Validation – Getting more specific with the review of data. Discuss the basic components of the validation process and what your institution can do to best prepare itself for analyzing the results of a validation. Whether it be an interim validation or a full-sized one, put together the right steps to ensure your institution derives the maximum benefit from its scorecard. 5. Turnaround Times (Response to Client) –Rebuild it. Make the origination process better, stronger and faster. No; we aren’t talking about bionics here — nor how you can manipulate the metrics to report a faster turnaround time. We are talking about what you can do from a loan applicant perspective to improve turnaround time. 6. Training – Where are all the training programs? Send in all the training programs! Worry, because they are not here. (Replace training programs with clowns and we might have an oldies song.) Can’t find the right people with the right talent in the marketplace? 7. Application Volume/Marketing/Relationship Management – You can design and execute the most efficient origination and portfolio management processes. But, without addressing client and application volume, what good are they? 8. Pricing/Yield on Portfolio – “We compete on service, not price.” We’ve heard this over and over again. In reality, the sales side always resorts to price as the final differentiator. Utilizing standardization and consistency can streamline your process and drive improved yields on your portfolio. 9. Management Metrics – How do I know that I am going in the right direction? Strategize, implement, execute, measure and repeat. Learn how to set your targets to provide meaningful bottom line results. 10. Operational Risk Management – Different from credit risk, operational risk and its management, operational risk management deals with what an institution should do to make sure it is not open to operational risk in the portfolio. Items totally in the control of the institution, if not executed properly, can cause significant loss. Well, that’s it. We encourage your feedback on this list. Let us know which of these ten topics is a priority for your institution and what specific areas in each topic you would like to see addressed.

I’m speculating a bit here, but I have a feeling that as the first wave of Red Flag rule examinations occurs, one of the potential perceived weak points in your program(s) may be your vendor relationships. Of particular note are collections agencies. Per the guidelines, “Section 114 applies to financial institutions and creditors.” Under the FCRA, the term “creditor” has the same meaning as in section 702 of the Equal Credit Opportunity Act (ECOA), 15 U.S.C. 1691a.15 ECOA defines “creditor” to include a person who arranges for the extension, renewal or continuation of credit, which in some cases could include third-party debt collectors. Therefore, the Agencies are not excluding third-party debt collectors from the scope of the final rules and “a financial institution or creditor is ultimately responsible for complying with the final rules and guidelines even if it outsources an activity to a third-party service provider.” A general rule of thumb in any examination process is to look closely at activities that are the most difficult for the examinee to control. Third-party relationship management certainly falls into this category. So, make sure your written and operational programs have procedures in place to ensure and regularly monitor appropriate Red Flag compliance — even when customer (or potential customer) activities occur outside your walls. Good luck!

By: Tom Hannagan Part 2 Return on Equity (ROE) ROE is the risk-adjusted profit divided by the equity amount associated with the loan in question. ROE = Risk-adjusted profit Equity amount of the loan There are two large advantages to using ROE. One, you can use it to compare profit performance across asset-based and non-asset-based products. This can’t be done with ROA – if there’s no “A”, you can’t create the ratio. This seems to be a crucial consideration if you are serious about cross-selling non-asset-based products (such as deposits and a long list of non-credit financial services) and if you are serious about being a truly client relationship oriented organization. Second, by using ROE you have the possibility of risk-adjusting the amount of equity used in the denominator of the calculation. Adjusting the equity amount based on risk, in a credible manner, creates risk-adjusted ROE, or what is referred to as risk adjusted return on capital (RAROC). The equity amount applied to the loan represents all of the remaining risk or unexpected loss (UL).instance that we did not account for in the steps that got us to the risk-adjusted profit result. RAROC, or risk-adjusted ROE, is a fully risk-adjusted representation of relative value. This level of risk-based performance measurement also has the advantage of relating pricing and relationship management activities to the bank’scapital management process. So far, we have covered several of the key parts of how risk-based pricing can work. In doing so, we have discussed how the various elements involved in pricing relate to the bank’s books and policies. The loan balance, rate and fee data relates to the banks actual general ledger amounts. The administrative costs are also derived from actual non-interest expenses. The cost of funds is aligned with the policies used in ALSO and in IRR management processes. The cost of credit risk is related to the bank’s credit and provisioning policies. The taxes are the bank’s actual average experience. And, for banks using ROE/RAROC, the equity allocation is related to the bank’s overall risk posture and its capital sufficiency policies. I stated earlier that “Risk-based pricing analysis is a product-level microcosm of risk-based bank performance”. It is that and more. In addition to pricing’s linkage to financial figures and results, risk-based pricing should also be a reflection of the bank’s most critical risk management policies and governance processes.
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