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.
