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The Federal Trade Commission announced on April 30, one day before the intended May 1 Red Flags Rule enforcement deadline, a third extension of that deadline to August 1, 2009. It's like showing up to class without your homework and the teacher is out sick that day….kind of. The first extension from November 1, 2008 to May 1, 2009 seems to center on the general confusion among many market sectors around their level of coverage under the Identity Theft Red Flags Rule. This latest delay seems to be a result of pushback from businesses with a lower risk of identity theft occurrences and a more "known" consumer base.So, it looks like we have at least three more months of preparation time. This can be a good thing for all institutions regardless of their current Red Flag guidelines readiness status. Those who scrambled to get a program in place now have time to fine tune it. Those that were hoping for another extension have it. Those who still question what their program should look like or if they are even covered can look forward to some more clarifying information out soon.Some key takeaways from the announcement:The FTC announcement does not impact other federal agency enforcement deadlines dating back to November 1, 2008.Specific to institutions that may have a perceived lower risk of identity theft, or businesses that generally know their customers personally, the Commission will be publishing more clarifying language and sample process (in the form of a template) to help those types of businesses comply with the Rule.Finally, this quote from the announcement sums it up: “Given the ongoing debate about whether Congress wrote this provision too broadly, delaying enforcement of the Red Flags Rule will allow industries and associations to share guidance with their members, provide low-risk entities an opportunity to use the template in developing their programs, and give Congress time to consider the issue further,” FTC Chairman Jon Leibowitz said.

By: Tom Hannagan As I'm preparing for traveling to the Baker Hill Solution Summit next week, I thought I would revisit the ideas of risk-based loan pricing. Risk Adjusted Loan Pricing – The Major Parts 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. You begin 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 in providing 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-result of too many sales — that use this lower cost factor — 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 we’ll expand this discussion further to risk-adjusted net income, capital allocation for unexpected loss and profit ratio considerations.

1. Portfolio 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. What do you think? As the end of April approaches, are these still hot topics in your financial institution?


