Banking

With a historic tax reform in place and an economy that continues to show signs of strength, we have a positive outlook for 2018.  As we reflect on 2017, a truth has become abundantly clear – 2017 will go on record as a time of preparation and 2018 will be the opportunity to act.

For some years now, financial institutions (FIs) of all sizes have been tasked to leverage new technology. In many cases, integrating new solutions has come as part of larger regulatory demands—and often, obligatory ‘updates’ are the most difficult to accept. Nonetheless, those requirements are opportunities to justify spending on technology resources that offer benefits far greater than the assurance of compliance.

As banks navigate through their CECL implementation, many are experiencing challenges and uncertainties along the way. Since last summer when the new standard was announced, we’ve advised banks to get started on their implementation timeline sooner than later. In part, it’s to give time to mitigate the unexpected. In part, the advice comes from our experience with how complex and challenging it can be to implement new models, standards, regulations, and technologies. And finally, it’s because more robust data analysis means more confident decisions and ultimately more profitable loans over the long term.

As the adage says, one of the surest ways to combat fear is to confront it head on. Financial anxiety is one of those fears. For 85% of adults, concerns around unplanned emergencies, medical expenses, insufficient funds for retirement, and school loans rank as the top stressors in their life.[1] For young, Millennial-aged adults, these concerns are even more pressing.

After attending the Public Company Accounting Oversight Board’s (PCAOB) Forum on Auditing in the Small Business Environment, our HORNE Financial Institutions team was reminded of future certainties that require immediate preparations. Regulations are becoming more complex. Regulators are requiring more diligence from publicly traded companies and banks—as well as from their auditors. 

Banks already engaged in the CECL implementation process know that it poses significant compliance and operational challenges to the allowance for loan losses calculation – the largest and most critical estimate for banks. But there’s another side to this coin. CECL also is a unique and compelling opportunity for banks to build the capacity to gather and use data to scale, create new revenue streams, and compete more successfully in a multi-channel marketplace.

On Monday, May 1^st, President Trump spoke to representatives from the Independent Community Bankers of America (ICBA), committing to cut the ‘red tape’ imposed by the 2010 Dodd-Frank financial regulatory law. His repeal promises were met with a great deal of excitement from the community bankers present, in part because of the reminder that the number of federally insured small banks dropped from 7,357 in 2011 to 5,980 in 2016—at least in part because of the regulation.[1] ICBA representatives including CEO Cam Fine reiterated the general tone, saying that community banks face a “pressing need for regulatory relief.”[2]

While the on-paper goal for banks working toward their implementation deadline for the new Current Expected Credit Loss (CECL) impairment standard is compliance, the long game opportunity is much greater. Every decision in the process hinges on data.

“As an agency designed to serve the American people, it is imperative to constantly look back on the SEC’s rules and engage the public on ways to improve. Today, we are asking for public comment on whether Industry Guide 3 continues to elicit the information that investors need for informed investment and voting decisions.”

- SEC Acting Chairman Michael Piwowar

On March 1, 2017, the SEC voted to publish a request for public comment on disclosures mandated by Industry Guide 3—Statistical Disclosure by Bank Holding Companies. The agency is seeking input from investors, registrants and others on ways to improve disclosures for bank holding companies, inquiring whether Guide 3 remains capable of gathering the information needed for investors to make informed funding and voting decisions. Additionally, the SEC is examining what new types of disclosures about bank holding company activities might be necessary.

Recently, a HORNE Banking client, a community bank based in rural Mississippi, shared with us that they are moving into Fintech. This institution does business in their immediate area as well as in some metro locations. Their announcement was noteworthy for a few reasons. First, despite all the talk about this channel over the past few years, we’ve yet to see it in action within community banks. Second, the institution is using Fintech as a technology-based lending platform for its small business clients, rather than as a consumer lending offering.

As 2017 gets underway, and we understand more about what’s on the horizon for the new administration’s regulatory and tax reform, there’s a sense that the coming years will bring unprecedented changes for financial institutions. In this last post in our series about CECL adoption, we will revisit the timeline and steps. More than ever, it is critical that you are preparing now for ensuring a successful adoption in the midst of an ever-changing landscape.

The previous post about preparing for CECL compliance looked at how to assess data, human, credit management, and technology resource capabilities and needs. It’s a critical step that documents how your institution collects, stores, measures, and manages loan portfolio data, and includes a review of future requirements, warehousing and automation capabilities, and probable risks in your loan portfolio.

In the previous post about preparing for your CECL compliance deadline, we established that there is no one-size-fits-all solution under the new standard. We provided some of the key considerations for determining how sophisticated your model should be, as well as unique benefits and weaknesses of the options available to manage the loan pools in your portfolio.

Once you have evaluated the various model options and identified which you’ll use to perform calculations, it’s time to assess your resource capabilities and needs. This is a big consideration with cross-functional implications. It will help to identify the software models and provider that will be the best fit for your institution. In this step, you'll look at four main categories—data, human, credit data management, and technology. Data should be your starting point, as it will influence every subsequent decision at this juncture.