
In this article…
Lorem ipsum dolor sit amet, consectetur adipiscing elit. Phasellus at nisl nunc. Sed et nunc a erat vestibulum faucibus. Sed fermentum placerat mi aliquet vulputate. In hac habitasse platea dictumst. Maecenas ante dolor, venenatis vitae neque pulvinar, gravida gravida quam. Phasellus tempor rhoncus ante, ac viverra justo scelerisque at. Sed sollicitudin elit vitae est lobortis luctus. Mauris vel ex at metus cursus vestibulum lobortis cursus quam. Donec egestas cursus ex quis molestie. Mauris vel porttitor sapien. Curabitur tempor velit nulla, in tempor enim lacinia vitae. Sed cursus nunc nec auctor aliquam. Morbi fermentum, nisl nec pulvinar dapibus, lectus justo commodo lectus, eu interdum dolor metus et risus. Vivamus bibendum dolor tellus, ut efficitur nibh porttitor nec.
Pellentesque habitant morbi tristique senectus et netus et malesuada fames ac turpis egestas. Maecenas facilisis pellentesque urna, et porta risus ornare id. Morbi augue sem, finibus quis turpis vitae, lobortis malesuada erat. Nullam vehicula rutrum urna et rutrum. Mauris convallis ac quam eget ornare. Nunc pellentesque risus dapibus nibh auctor tempor. Nulla neque tortor, feugiat in aliquet eget, tempus eget justo. Praesent vehicula aliquet tellus, ac bibendum tortor ullamcorper sit amet. Pellentesque tempus lacus eget aliquet euismod. Nam quis sapien metus. Nam eu interdum orci. Sed consequat, lectus quis interdum placerat, purus leo venenatis mi, ut ullamcorper dui lorem sit amet nunc. Donec semper suscipit quam eu blandit. Sed quis maximus metus. Nullam efficitur efficitur viverra. Curabitur egestas eu arcu in cursus.
H1
H2
H3
H4
Lorem ipsum dolor sit amet, consectetur adipiscing elit. Vestibulum dapibus ullamcorper ex, sed congue massa. Duis at fringilla nisi. Aenean eu nibh vitae quam auctor ultrices. Donec consequat mattis viverra. Morbi sed egestas ante. Vivamus ornare nulla sapien. Integer mollis semper egestas. Cras vehicula erat eu ligula commodo vestibulum. Fusce at pulvinar urna, ut iaculis eros. Pellentesque volutpat leo non dui aliquet, sagittis auctor tellus accumsan. Curabitur nibh mauris, placerat sed pulvinar in, ullamcorper non nunc. Praesent id imperdiet lorem.
H5
Curabitur id purus est. Fusce porttitor tortor ut ante volutpat egestas. Quisque imperdiet lobortis justo, ac vulputate eros imperdiet ut. Phasellus erat urna, pulvinar id turpis sit amet, aliquet dictum metus. Fusce et dapibus ipsum, at lacinia purus. Vestibulum euismod lectus quis ex porta, eget elementum elit fermentum. Sed semper convallis urna, at ultrices nibh euismod eu. Cras ultrices sem quis arcu fermentum viverra. Nullam hendrerit venenatis orci, id dictum leo elementum et. Sed mattis facilisis lectus ac laoreet. Nam a turpis mattis, egestas augue eu, faucibus ex. Integer pulvinar ut risus id auctor. Sed in mauris convallis, interdum mi non, sodales lorem. Praesent dignissim libero ligula, eu mattis nibh convallis a. Nunc pulvinar venenatis leo, ac rhoncus eros euismod sed. Quisque vulputate faucibus elit, vitae varius arcu congue et.
Ut convallis cursus dictum. In hac habitasse platea dictumst. Ut eleifend eget erat vitae tempor. Nam tempus pulvinar dui, ac auctor augue pharetra nec. Sed magna augue, interdum a gravida ac, lacinia quis erat. Pellentesque fermentum in enim at tempor. Proin suscipit, odio ut lobortis semper, est dolor maximus elit, ac fringilla lorem ex eu mauris.
- Phasellus vitae elit et dui fermentum ornare. Vestibulum non odio nec nulla accumsan feugiat nec eu nibh. Cras tincidunt sem sed lacinia mollis. Vivamus augue justo, placerat vel euismod vitae, feugiat at sapien. Maecenas sed blandit dolor. Maecenas vel mauris arcu. Morbi id ligula congue, feugiat nisl nec, vulputate purus. Nunc nec aliquet tortor. Maecenas interdum lectus a hendrerit tristique. Ut sit amet feugiat velit.
- Test
- Yes

It is the time of year during which budgets are either in the works or have been completed. Typically, when preparing budgets, we project overall growth in our loan portfolios…maybe. Recently we conducted an informal survey, the results of which indicate that loan portfolio growth is still a major target for 2009. But when asked what specific areas in the loan portfolio — or how loan pricing and profitability — will drive that growth, there was little in the way of specifics available. This lack of direction (better put, vision) is a big problem in credit risk management today. We have to remember that our loan portfolio is the biggest investment vehicle that we have as a financial institution. Yes; it is an investment. We choose not to invest in treasuries or fed funds — and to invest in loan balances instead — because loan balances provide a better return. We have to appropriately assess the risk in each individual credit relationship; but, when it comes down to the basics, when we choose to make a loan, it is our way of investing our depositors’ money and our capital in order to make a profit. When you compare lending practices of the past to that of well-tested investment techniques, we can see that we have done a poor job with our investment management. Remember the basics of investing, namely: diversification; management of risk; and review of performance. Your loan portfolio should be managed using these same basics. Your loan officers are pitching various investments based on your overall investment goals (credit policy, pricing structure, etc.). Your approval authority is the final review of these investment options. Ongoing monitoring is management of the ongoing risk involved with the loan itself. What is your vision for your portfolio? What type of diversification model do you have? What type of return is required to appropriately cover risk? Once you have determined your overall vision for the portfolio, you can begin to refine your lending strategy. I’ll comment on that in my next blog entry.

By: Tom Hannagan In several posts we’ve discussed financial risk management, the role of risk-based capital, measuring profitability based on risk characteristics and the need for risk-based loan pricing (credit risk modeling). I thought it might be worthwhile to take one step back and explain what we mean by the term “risk.” “Risk” means unpredictable variability. Reliable predictions of an outcome tend to reduce the risk associated with that outcome. Similarly, low levels of variability also tend to reduce risk. People who are “set in their ways” tend to lead less risky lives than the more adventuresome types. Insurance companies love the former and charge additional premiums to the latter. This is a terrific example of risk-based pricing. Risk goes to both extremes. It is equally impossible to predict who will win a record amount in the lottery (a good outcome) and who will be struck by a meteor (a very bad outcome for the strikee). Both occurrences represent significant outcomes (very high variability from the norm). However, the probability of either event happening to any one of us is infinitesimally small. Therefore, the actual risk is small – not even enough to bother planning for or mitigating. That is why most of us don’t buy meteor strike insurance. It is also why most of us don’t have a private jet on order. Most of us do purchase auto insurance, even in states that do not require it. Auto accidents (outcomes) happen often enough that actuaries can and do make a lot of good predictions as to both the number of such events and their cost impact. In fact, so many companies are good at this that they can and do compete on their prices for taking on our risk. The result is that we can economically mitigate our individual inability to predict a collision by buying car insurance. Financial services involve risk. Banks have many of the same operational risks as other non-financial businesses. They additionally have a lot of credit risk associated with lending money to individuals and businesses. Further, banks are highly leveraged, borrowing funds from depositors and other sources to support their lending activities. Because banks are both collecting interest income and incurring interest expense, they are subject to market, or interest rate, risk. Banks create credit policies and processes to help them manage credit risk. They try to limit the level of risk and predict how much they are incurring so they can reserve some funds to offset losses. To the extent that banks don’t do this well, they are acting like insurance companies without good actuarial support. It results in a practice called “adverse selection” – incorrectly pricing risk and gathering many of the worst (riskiest) customers. Sufficiently good credit risk management practices control and predict most of the bad outcomes most of the time, at least at portfolio levels. Bad outcomes (losses) that are not well-predicted, and therefore mitigated with sufficient loan-loss reserves, will negatively impact the bank’s earnings and capital position. If the losses are large enough, they can wipe out capital and result in the bank’s failure. Market risk is different than credit risk. The bank’s assets are mostly invested in loans and securities (about 90% of average assets). These loans and securities have differing interest rate structures – some are fixed and some are floating. They also have differing maturities. Meanwhile, the bank’s liabilities, deposits and borrowings also have differing maturities and interest rate characteristics. If the bank’s (asset-based) interest income structure is not properly aligned with the (liability-based) interest expense structure, the result is interest rate risk. As market rates change (up or down), the bank’s earning are impacted (positively or negatively) based on the mismatch in its balance sheet structure. The bank can offset market risk by purchasing interest rate swaps or other interest rate derivatives. The impact of insufficient attention to interest rate risk can damage earnings and may, again, negatively affect the bank’s capital position. So, ultimately, the bank’s risk-based capital acts as the last line of defense against the negative impact from, you guessed it, unpredictable variability – or “risk.” That is why equity is considered risk-based capital. Good management, predicting and pricing for all risks leads to safer earnings performance and equity position.

I’m working with many of our clients in reviewing their existing or evolving Red Flags Identity Theft Prevention Programs. While the majority of them appear to be buttoned up from the perspective of identifying covered accounts and applicable Red Flag conditions, as well as establishing detection methodologies, I often still see too much subjectivity in their response and reconciliation procedures. Here are a few reasons why the “response” portion of a strong Red Flags Identity Theft Prevention program needs to employ consistent and objective process, decisioning, and actions: 1. Inconsistent or subjectively varied responses and actions greatly reduce the ability to measure process effectiveness over time. It becomes increasingly difficult for retro-analysis to identify which processes and specific steps in those processes were successful in either positively or negatively reconciling potential fraudulent activity. Subsequently, it clouds any ability to make effective or necessary changes to specific activities that may not be working well. 2. Examiners may focus heavily on the response portion of your program. During operational side by sides, or even written program reviews, the less ambiguity and inconsistency identified or perceived, the better. A quick rule of thumb for any examination: preempt any questions with exhaustive information and clarity. Examiners that don’t need to ask many, or any, questions are happy examiners. 3. Objective and consistent process allows for more manageable staff training. It is much easier to educate your staff around a justified and effective uniform process than around intuitive and haphazard procedures and consumer interactions. It is tough to set expectations with your staff if there are gaping holes in the activities they are expected to execute. 4. Customer experience will certainly be more positive, and less of a worry for managers, as inequity of treatment is removed from the equation. It is better to have each customer progress through similar steps toward authentication than varied ones from the perspective of time, perception, effectiveness, and convenience. Now, certainly, a risk-based approach allows for varied treatment based on that risk. The point here is more toward the need to apply those varied techniques consistently. 5. Social engineering. Fraudsters are pretty good at figuring out if an operational process is open to interpretation and manipulation. They’ll continue to engage in a process with the goal of landing with the right associate who may be following a more easily penetrable fraud detection method. Bottom line: keep the walls around your business the same height throughout. Until next time, best of luck as you continue to develop and improve your Red Flags programs.


