Credit & Risk

By: Kari Michel Lenders want to find new customer through more informed credit risk decisions and use new types of data relationships to cross-sell.   The strategic goals of any company are to get more customers and revenue while reducing costs on the operating side and the credit loss side.  Some of the ways to meet these goals are to improve operating efficiency in creating and managing credit attributes, which represent the building blocks of how lenders make customer decisions. Lenders face many challenges in leveraging data from multiple credit and non-credit sources (e.g. credit bureaus) and maintaining data attributes across multiple systems. Furthermore, a lack of access to raw data makes it difficult to create effective, predictive attributes. Simply managing the discrepancies between specifications and code can become a very time consuming effort.  Maintaining a common set of attributes used in many types of scorecards and decision types often becomes difficult.  As a result, there is a heavy reliance on external people and technical resources to find the right tools to try and pull the data sources and attributes together. In an ideal situation, a lender should be able to easily access raw data elements across multiple sources and aggregate the data into meaningful attributes. Experian can offer these capabilities through its Attribute Toolbox product, allowing one or more systems to access a common set of standard analytics.  A set of highly predictive attributes, Premier Attributes, are available and offers a much more effective solution  for managing standard attributes across an enterprise.  With the use of these tools, lenders can decrease maintenance costs by quickly integrating data and analytics into existing business architecture to make profitable decisions.  

By:Wendy Greenawalt In my last few blogs, I have discussed how optimizing decisions can be leveraged across an organization while considering the impact those decisions have to organizational profits, costs or other business metrics. In this entry, I would like to discuss how this strategy can be used in optimizing decisions at the point of acquisition, while minimizing costs. Determining the right account terms at inception is increasingly important due to recent regulatory legislation such as the Credit Card Act. These regulations have established guidelines specific to consumer age, verification of income, teaser rates and interest rate increases. Complying with these regulations will require changes to existing processes and creation of new toolsets to ensure organizations adhere to the guidelines. These new regulations will not only increase the costs associated with obtaining new customers, but also the long term revenue and value as changes in account terms will have to be carefully considered. The cost of on-boarding and servicing individual accounts continues to escalate, and internal resources remain flat. Due to this, organizations of all sizes are looking for ways to improve efficiency and decisions while minimizing costs. Optimization is an ideal solution to this problem. Optimized strategy trees can be easily implemented into current processes and ensure lending decisions adhere to organizational revenue, growth or cost objectives as well as regulatory requirements.  Optimized strategy trees enable organizations to create executable strategies that provide on-going decisions based upon optimization conducted at a consumer level. Optimized strategy trees outperform manually created trees as they are created utilizing sophisticated mathematical analysis and ensure organizational objectives are adhered to. In addition, an organization can quantify the expected ROI of a given strategy and provide validation in strategies – before implementation. This type of data is not available without the use of a sophisticated optimization software application.  By implementing optimized strategy trees, organizations can minimize the volume of accounts that must be manually reviewed, which results in lower resource costs. In addition, account terms are determined based on organizational priorities leading to increased revenue, retention and profitability.

By: Kari Michel What is Basel II?  Basel II is the international convergence of Capital Measurement and Capital Standards. It is a revised framework and is the second iteration of an international standard of laws. The purpose of Basel II is to create an international standard that banking regulators can use when creating regulations about how much capital banks need to put aside to guard against the types of financial and operations risk banks face.  Basel II ultimately implements standards to assist in maintaining a healthy financial system. The business challenge The framework for Basel II compels the supervisors to ensure that banks implement credit rating techniques that represent their particular risk profile.  Besides the risk inputs (Probability of Default (PD), Loss Given Default (LGD) and Exposure at Default (EAD)) calculation, the final Basel accord includes the “use test” requirement which is the requirement for a firm to use an advanced approach more widely in its business and met merely for calculation of regulatory capital. Therefore many financial institutions are required to make considerable changes in their approach to risk management (i.e. infrastructure, systems, processes, data requirements).  Experian is a leading provider of risk management solutions -- products and services for the new Basel Capital Accord (Basel II).  Experian’s approach includes consultancy, software, and analytics tailored to meet the lender’s Basel II requirements.  

By: Wendy Greenawalt Marketing is typically one of the largest expenses for an organization while also being a priority to reach short and long-term growth objectives. With the current economic environment, continuing to be unpredictable many organizations have reduced budgets and focused on more risk and recovery activities. However, in the coming year we expect to see improvements and organizations renew their focus to portfolio growth. We expect that campaign budgets will continue to be much lower than what was allocated before the mortgage meltdown but organizations are still looking for gains in efficiency and response to meet business objectives. Creation of optimized marketing strategies is quick and easy when leveraging optimization technology enabling your internal resources to focus on more strategic issues. Whether your objective is to increase organizational or customer level profit, growth in specific product lines or maximizing internal resources optimization can easily identify the right solution while adhering to key business objectives. The advanced software now available enables an organization to compare multiple campaign options simultaneously while analyzing the impact of modifications to revenue, response or other business metrics. Specifically, very detailed product offer information, contact channels, timing, and letter costs from multiple vendors and consumer preferences can all be incorporated into an optimization solution. Once defined the complex mathematical algorithm factors every combination of all variables, which could range in the thousands, are considered at the consumer level to determine the optimal treatment to maximize organizational goals and constraints. In addition, by incorporating optimized decisions into marketing strategies marketers can execute campaigns in a much shorter timeframe allowing an organization to capitalize on changing market conditions and consumer behaviors. To illustrate the benefit of optimization an Experian bankcard client was able to reduced analytical time to launch programs from 7 days to 90 minutes while improving net present value. In my next blog, we will discuss how organizations can cut costs when acquiring new accounts.  

By: Wendy Greenawalt The economy has changed drastically in the last few years and most organizations have had to reduce costs across their businesses to retain profits. Determining the appropriate cost-cutting measures requires careful consideration of trade-offs while quantifying the short- and long-term organizational priorities.  Too often, cost reduction decisions are driven by dynamic market conditions, which mandate quick decision-making. Due to this, decisions are made without a sound understanding of the true impact to organizational objectives. Optimization (optimizing decisions) can be used for virtually any business problem and provides decisions based on complex mathematics. Therefore, whether you are making decisions related to outsourcing versus staffing, internal versus external project development or specific business unit cost savings opportunities, optimization can be applied. While some analytical requirements exist to obtain the highest business metric improvements, most organizations have the data available that is required to take full advantage of optimization technology.  If you are using predictive models, credit attributes and have multiple actions that can be taken on an individual consumer, then, most likely, your organization can benefit from strategies in optimizing decisions. In my next few blogs, I will discuss how optimization / optimizing decisions can be used to create better strategies across an organization whether your focus is marketing, risk, customer management or collections.  

By: Tom Hannagan While waiting on the compilation of fourth quarter banking industry results, I thought it might be interesting to relate the commercial real estate (CRE) risk management position facing commercial banks from the third quarter. CRE risk is an important consideration in enterprise risk management and for loan pricing and profitability. The slowdown in the global economy has affected CRE credit risk because of increased vacancy rates, halted development projects, and the loss of value affecting commercial properties. As CRE loans come up for renewal, many will find that there have equity deficits and that they are facing tightened credit standards. If a commercial property loan started life at 80 percent loan to value, and the property value has dropped 25 percent, the renewed loan balance will be down at least 25 percent, requiring a substantial net payoff from the borrower. This net cash payoff requirement would be tough to accomplish in good times and all-but-impossible for many borrowers in this economy. After all, the main reason for the decline in property value to begin with is its reduced cash flow performance. Following the third quarter numbers, total U.S. commercial real estate is generally estimated at $3.4 to $3.5 trillion. Commercial banks owned just over half of that debt, or about $1.8 trillion according to Federal Reserve and FDIC sources. The (possibly only) good news with that total is that commercial banks owned a relatively small share of the commercial-mortgage-backed securities (CMBS) slice of CRE exposure. CMBS assets were 21 percent of total CRE credit or $714 billion, but banks owned a total of $54 billion, which represented only 3 percent of total bank CRE assets. Unfortunately, the opposite is true for construction lending. U.S. banks, in total, had $486 to $534 billion (depending on the source) in construction and land loans, representing 27 percent to 30 percent of banks’ total CRE holdings. The true credit risk management picture is much more revealing if we cut the numbers by bank size. According to Deutsche Bank research, the largest 97 banks (those with over $10 billion in total assets) had $14.8 trillion in total assets and $1.0 trillion of the banking industry’s CRE credits.  This amounts to about 7 percent of the total assets for this group of larger banks. The 7,500 community banks, with aggregate assets of $2 trillion, had about $786 billion in CRE lending. This amounts to about 28 percent of total assets. That is roughly four times the level of exposure found in the larger banks. The 7 percent level of credit risk average exposure at the large bank group is less than their average level of equity or risk-based capital. For the banks under the $10 billion level, the 28 percent level of CRE exposure is almost three times their average equity position. The riskiest portion of CRE lending is clearly the construction and land development loans. The subtotals in this area confirm where the cumulative risk lies. Again, according to Deutsche Bank research, the largest 97 banks had $299 billion of the banking industry’s $534 billion in construction loans. Although this is 56 percent of total bank construction lending, it amounts to only 2 percent of this group’s total assets.  The 7,500 community banks had aggregate construction loans of $235 billion. This amounts to about 8.5 percent of total assets. That is a bit over four times the level of exposure found in the larger banks. The 2 percent level of construction credit risk exposure at the large bank group is one-fourth of their average level of common equity. At banks under the $10 billion level, the 8.5 percent level of CRE exposure, compared to total assets, is about the same as their average equity position. According to Moody’s, bank have already taken about $90 billion in net loan losses in CRE assets through the third quarter of 2009. That means the industry has perhaps another $150 billion in write-offs coming. This would total $240 billion in CRE credit losses for the banking industry due to this economic downturn. That would equate to 13.3 percent of the banking industry’s share of total CRE credit. With the decline in commercial property values ranging from 10 percent to 40 percent, a 13 percent loss is certainly not a worst case scenario. Banks have ramped up their loss reserves, and although the numbers aren’t out yet, we know many banks have used the fourth quarter 2009 to further bolster their allowances for loan and lease losses (ALLL). The larger the ALLL, the safer the risk-based equity account. Risk managers are aware of all of this and banks are very actively developing their strategies to handle the refunding requirements and, at the same time, be in a position to explain to regulators and external auditor how they are protecting shareholders. But the numbers are very daunting and not every bank will have enough net cash flow and risk equity to cover the inevitable losses.  

By: Amanda Roth Last week, we discussed how pricing with competition is important to ensure sound decision practices are being implemented in the domains of loan pricing and profitability.  The extreme of pricing too high for the market can obviously be detrimental to your organization.  The other extreme can be just as dangerous. Pricing for your profitability, regardless of what the competition is charging in your area, has a few potential issues associated with it regarding management of risk.  For example, the statistics state you can charge 5 percent in your “A” tier and still be profitable, but the competition is charging 7.5 percent for the same tier.  You may be thinking that by offering 5 percent you will attract the “best of the best” to your organization.  However, what your statistics may not be showing you is the risk outside of your applicant base.  If you significantly change the customers you are bringing in, does your risk increase as well, ultimately increasing the cost associated with each loan?   Increased costs will reduce or even eliminate the profitability you had expected. A second potential issue is setting the expectation within the marketplace.  It is often understood with the consumers that when changes occur to the interest rate at the federal level, there will be changes at their local financial institution.  These changes are often very small.  By undercutting your competition by such an extreme amount, your customers may question any attempts to raise rates more than 50bp, if you do experience increased costs as a result of the earlier situation or any other factors.  A safer strategy would be to charge between 6.5 percent and 7 percent, which allows you to obtain some of the best customers, ensure stability within the market, and take advantage of additional profitability while it is available.  This is definitely a winning strategy for all -- and an important consideration as you develop your portfolio risk management objectives.    

By: Amanda Roth Doesn’t that sound strange: Pricing WITH competition?  We are familiar with the sayings of pricing for competition and pricing to be competitive, but did you ever think you would need to price with competition?  When developing a risk-based pricing program, it is important to make sure you do not price against the competition in any extreme.  Some clients decide they want to price lower than the competition regardless of how it impacts their profitability.  However, others price only for profitability without any respect to their competition.  As we discussed last week, risk-based pricing is 80 percent statistics, but 20 percent art -- and competition is part of the artistic portion. Once you complete your profitability analysis (refer to 12/28/2009 posting), you will often need to massage the final interest rate to be applied to loan applications.  If the results of the analysis are that your interest rate needs to be 8.0 percent in your “A” tier to guarantee profitability, but your competition is only charging 6.0 percent, there could be a problem if you go to market with that pricing strategy.  You will probably experience most of your application volume coming to an end, especially those customers with low risk that can obtain the best rates of a lender.  Creativity is the approach you must take to become more competitive while still maintaining profitability.  It may be an approach of offering the 6.0 percent rate to the best 10 percent of your applicant base only, while charging slightly higher rates in your “D” and “E” tiers. Another option may be that you need to look internally at processing efficiencies to determine if there is a way to decrease the overall cost associated with the decision process.  Are there decision strategies in place that are creating a manual decision when more could be automated?  Pricing higher than the market rate can be detrimental to any organization, therefore it is imperative to apply an artistic approach while maintaining the integrity of the statistical analysis. Join us next week to continue this topic of pricing with competition which is, again, an important consideration when developing a risk-based pricing program.  

We've recently discussed management of risk, collections strategy, credit attributes, and the like for the bank card, telco, and real estate markets. This blog will provide insights into the trends of the automotive finance market as of third quarter 2009.  In terms of credit quality, the market has been relatively steady in year-over-year comparisons.  The subprime group saw the biggest change in risk distribution from 3Q08, with a -3.74 percent shift. Overall, balances have declined to just over $673 billion (- 4 percent).  In 3Q09, banks held the largest total of outstanding automotive balances of $241 billion (with captive auto next at $203 billion).  Credit unions had the largest increase from 3Q08 (with $5 billion) and the finance/other group had the largest decrease in balances (- $23 billion). How are automotive loans performing?  Total 30- and 60-day delinquencies are still on the rise, but the rate of increase of 30-day delinquencies appears to be slowing.   New originations are dominating in the Prime plus market (66 percent), up by 10 percent.  Lending criteria has tightened and, as a result, we see scores on both new and used vehicles continue to increase.  For new buyers, over 83 percent are Prime plus.  For used buyers, over 53 percent are Prime plus.  The average credit score changed from 762 in 3Q08 to 775 in 3Q09 -- up 13 points for new vehicles.  For used vehicles in the same time period: 670 to 684, up 14 points. Lastly, let’s take a look at how financing has changed from 3Q08 to 3Q09.  The financed amounts and monthly payments have dropped year-over-year as well as the average term and average rate. Source:  State of the Automotive Finance Market, Third Quarter 2009 by Melinda Zabritski, director of Automotive Credit at Experian and Experian-Oliver Wyman Market Intelligence Reports    

By: Tom Hannagan Apparently my last post on the role of risk management in the pricing of deposit services hit some nerve ends. That’s good. The industry needs its “nerve ends” tweaked after the dearth of effective risk management that contributed to the financial malaise of the last couple of years. Banks, or any business, can prosper by simply following their competitors’ marketing strategies and meeting or slightly undercutting their prices. The actions of competitors are an important piece of intelligence to consider, but not necessarily optimal for your bank to copy. One question is regarding the “how-to” behind risk-based pricing (RBP) of deposits. The answer has four parts. Let’s see. First, because of the importance and size of the deposit business (yes, it’s a line of business) as a funding source, one needs to isolate the interest rate risk. This is done by transfer pricing, or in a sense, crediting the deposit balances for their marginal value as an offset to borrowing funds. This transfer price has nothing to do with the earnings credit rate used in account analysis – that is a merchandising issue used to generate fee income. Fees, resulting from account analysis, when not waived, affect the profitability of deposit services, but are not a risk element. Two things are critical to the transfer of funding credit: 1) the assumptions regarding the duration, or reliability of the deposit balances and 2) the rate curve used to match the duration. Different types of deposit behave differently based on changes in rates paid. Checking account deposit funds tend to be very loyal or “sticky” - they don’t move around a lot (or easily) because of rate paid, if any. At the other extreme, time deposits tend to be very rate-sensitive and can move (in or out) for small incremental gains. Savings, money market and NOW accounts are in-between. Since deposits are an offset (ultimately) to marginal borrowing, just as loans might (ultimately) require marginal borrowing, we recommend using the same rate curve for both asset and liability transfer pricing. The money is the same thing on both sides of the balance sheet and the rate curve used to fund a loan or credit a deposit should be the same. We believe this will help, greatly, to isolate IRR. It is also seems more fair when explaining the concept to line management. Secondly, although there is essentially no credit risk associated with deposits, there is operational risk. Deposit make up most of the liability side of the balance sheet and therefore the lion’s share of institutional funding. Deposits are also a major source of operational expense. The mitigated operational risks such as physical security, backup processing arrangements, various kinds of insurance and catastrophe plans, are normal expenses of doing business and included in a bank’s financial statements. The costs need to be broken down by deposit category to get a picture of the risk-adjusted operating expenses. The third major consideration for analyzing risk-adjusted deposit profitability is its revenue contribution. Deposit-related fee income can be a very significant number and needs to be allocated to particular deposit category that generates this income. This is an important aspect of the return, along with the risk-adjusted funding value of the balances. It will vary substantially for various deposit types. Time deposits have essentially zero fee income, whereas checking accounts can produce significant revenues. The fourth major consideration is capital. There are unexpected losses associated with deposits that must be covered by risk-based capital – or equity. The unexpected losses include: unmitigated operational risks, any error in transfer pricing the market risk, and business or strategic risk. Although the unexpected losses associated with deposit products are substantially less than found in the lending products, they needs to be taken into account to have a fully risk-adjusted view. It is also necessary to be able to compare the risk-adjusted profit and profitability of such diverse services as found within banking. Enterprise risk management needs to consider all of the lines of business, and all of the products of the organization, on a risk-adjusted performance basis. Otherwise it is impossible to decide on the allocation of resources, including precious capital. Without this risk management view of deposits (just as with loans) it is impossible to price the services in a completely knowledgeable fashion. Good entity governance, asset and liability posturing, and competent line of business management, all require more and better risk-based profit considerations to be an important part of the intelligence used to optimally price deposits.      

In a continuation of my previous entry, I’d like to take the concept of the first-mover and specifically discuss the relevance of this to the current bank card market. Here are some statistics to set the stage: • Q2 2009 bankcard origination levels are now at 54 percent of Q2 2008 levels • In Q2 2009, bankcard originations for subprime and deep-subprime were down 63 percent from Q2 2008 • New average limits for bank cards are down 19 percent in Q2 2009 from peak in Q3 2008 • Total unused limits continued to decline in Q3 2009, decreasing by  $100 billion in Q3 2009 Clearly, the bank card market is experiencing a decline in credit supply, along with deterioration of credit performance and problematic delinquency trends, and yet in order to grow, lenders are currently determining the timing and manner in which to increase their presence in this market. In the following points, I’ll review just a few of the opportunities and risks inherent in each area that could dictate how this occurs. Lender chooses to be a first-mover: • Mining for gold – lenders currently have an opportunity to identify long-term profitable segments within larger segments of underserved consumers. Credit score trends show a number of lower-risk consumers falling to lower score tiers, and within this segment, there will be consumers who represent highly profitable relationships. Early movers have the opportunity to access these consumers with unrealized creditworthiness at their most receptive moment, and thus have the ability to achieve extraordinary profits in underserved segments. • Low acquisition costs – The lack of new credit flowing into the market would indicate a lack of competitiveness in the bank card acquisitions space. As such, a first-mover would likely incur lower acquisitions costs as consumers have fewer options and alternatives to consider. • Adverse selection - Given the high utilization rates of many consumers, lenders could face an abnormally high adverse selection issue, where a large number of the most risky consumers are likely to accept offers to access much needed credit – creating risk management issues. • Consumer loyalty – Whether through switching costs or loyalty incentives, first-movers have an opportunity to achieve retention benefits from the development of new client relationships in a vacant competitive space. Lender chooses to be a secondary or late-mover: • Reduced risk by allowing first-mover to experience growing pains before entry. The implementation of new acquisitions and risk-based pricing management techniques with new bank card legislation will not be perfected immediately. Second-movers will be able to read and react to the responses to first movers’ strategies (measuring delinquency levels in new subprime segments) and refine their pricing and policy approaches. • One of the most common first-mover advantages is the presence of switching costs by the customer. With minimal switching costs in place in the bank card industry, the ability for second-movers to deal with an incumbent is not one where switching costs are significant issues – second-movers would be able to steal market share with relative ease. • Cherry-picked opportunities – as noted above, many previously attractive consumers will have been engaged by the first-mover, challenging the second-mover to find remaining attractive segments within the market. For instance, economic deterioration has resulted in short-term joblessness for some consumers who might be strong credit risks, given the return of capacity to repay. Once these consumers are mined by the first-mover, the second-mover will likely incur greater costs to acquire these clients. Whether lenders choose to be first to market, or follow as a second-mover, there are profitable opportunities and risk management challenges associated with each strategy.  Academics and bloggers continue to debate the merits of each, (1)  but it is the ultimately lenders of today that will provide the proof.   [1] http://www.fastcompany.com/magazine/38/cdu.html  

To calculate the expected business benefits of making an improvement to your decisioning strategies, you must first identify and prioritize the key metrics you are trying to positively impact.  For example, if one of your key business objectives is improved enterprise risk management, then some of the key metrics you seek to impact, in order to effectively address changes in credit score trends, could include reducing net credit losses through improved credit risk modeling and scorecard monitoring. Assessing credit risk is a key element of enterprise risk management and can addressed as part of your application risk management processes as well as other decisioning strategies that are applied at different points in the customer lifecycle. In working with our clients, Experian has identified 15 key metrics that can be positively impacted through optimizing decisions.  As you review the list of metrics below, you should identify those metrics that are most important to your organization. • Approval rates • Booking or activation rates • Revenue • Customer net present value • 30/60/90-day delinquencies • Average charge-off amount • Average recovery amount • Manual review rates • Annual application volume • Charge-offs (bad debt & fraud) • Avg. cost per dollar collected • Average amount collected • Annual recoveries • Regulatory compliance • Churn or attrition Based on Experian’s extensive experience working with clients around the world to achieve positive business results through optimizing decisions, you can expect between a 10 percent and 15 percent improvement in any of these metrics through the improved use of data, analytics and decision management software. The initial high-level business benefit calculation, therefore, is quite important and straightforward.  As an example, assume your current approval rate for vehicle loans is 65 percent, the average value of an approved application is $200 and your volume is 75,000 applications per year.  Keeping all else equal, a 10 percent improvement in your approval rates (from 65 percent to 72 percent) would generate $10.7 million in incremental business value each year ($200 x 75,000 x .65 x 1.1).  To prioritize your business improvement efforts, you’ll want to calculate expected business benefits across a number of key metrics and then focus on those that will deliver the greatest value to your organization.  

I’ve recently been hearing a lot about how bankcard lenders are reacting to changes in legislation, and recent statistics clearly show that lenders have reduced bankcard acquisitions as they retune acquisition and account management strategies for their bankcard portfolios. At this point, there appears to be a wide-scale reset of how lenders approach the market, and one of the main questions that needs to be answered pertains to market-entry timing: Should a lender be the first to re-enter the market in a significant manner, or is it better to wait, and see how things develop before executing new credit strategies? I will dedicate my next two blogs to defining these approaches and discussing them with regard to the current bankcard market. Based on common academic frameworks, today’s lenders have the option of choosing one of the following two routes: becoming a first-mover, or choosing to take the role of a secondary or late mover. Each of these roles possess certain advantages and also corresponding risks that will dictate their strategic choices: The first-mover advantage is defined as “A sometimes insurmountable advantage gained by the first significant company to move into a new market.” (1)  Although often confused with being the first-to-market, first-mover advantage is more commonly considered for firms that first substantially enter the market. The belief is that the first mover stands to gain competitive advantages through technology, economies of scale and other avenues that result from this entry strategy. In the case of the bankcard market, current trends suggest that segments of subprime and deep-subprime consumers are currently underserved, and thus I would consider the first lender to target these customers with significant resources to have ‘first-mover’ characteristics. The second-mover to a market can also have certain advantages: the second-mover can review and assess the decisions of the first-mover and develops a strategy to take advantage of opportunities not seized by the first-mover. As well, it can learn from the mistakes of the first-mover and respond, without having to incur the cost of experiential learning and possessing superior market intelligence. So, being a first-mover and second-mover can each have its advantages and pitfalls. In my next contribution, I’ll address these issues as they pertain to lenders considering their loan origination strategies for the bankcard market. (1) http://www.marketingterms.com/dictionary/first_mover_advtanage  

By: Tom Hannagan This blog has often discussed many aspects of risk-adjusted pricing for loans. Loans, with their inherent credit risk, certainly deserve a lot of attention when it comes to risk management in banking. But, that doesn’t mean you should ignore the risk management implications found in the other product lines. Enterprise risk management needs to consider all of the lines of business, and all of the products of the organization. This would include the deposit services arena. Deposits make up roughly 65 percent to 75 percent of the liability side of the balance sheet for most financial institutions, representing the lion’s share of their funding source. This is a major source of operational expense and also represents most of the bank’s interest expense. The deposit activity has operational risk, and this large funding source plays a huge role in market risk – including both interest rate risk and liquidity risk. It stands to reason that such risks are considered when pricing deposit services. Unfortunately it is not always the case. Okay, to be honest, it’s too rarely the case. This raises serious entity governance questions. How can such a large operational undertaking, not withstanding the criticality of the funding implications, not be subjected to risk-based pricing considerations? We have seen warnings already that the current low interest rate environment will not last forever. When the economy improves and rates head upwards, banks need to understand the bottom line profit implications. Deposit rate sensitivity across the various deposit types is a huge portion of the impact on net interest income. Risk-based pricing of these services should be considered before committing to provide them. Even without the credit risk implications found on the loan side of the balance sheet, there is still plenty of operational and market risk impact that needs to be taken into account from the liability side. When risk management is not considered and mitigated as part of the day-to-day management of the deposit line of business, the bank is leaving these risks completely to chance. This unmitigated risk increases the portion of overall risk that is then considered to be “unexpected” in nature and thereby increases the equity capital required to support the bank.

By: Amanda Roth To refine your risk-based pricing another level, it is important to analyze where your tiers are set and determine if they are set appropriately.  (We find many of the regulators / examiners are looking for this next level of analysis.) This analysis begins with the results of the scoring model validation.  Not only will the distributions from that analysis determine if the score can predict between good and delinquent accounts, but it will also highlight which score ranges have similar delinquency rates, allowing you to group your tiers together appropriately.  After all, you do not want to have applicants with a 1 percent chance of delinquency priced the same as someone with an 8 percent chance of delinquency.  By reviewing the interval delinquency rates as well as the odds ratios, you should be able to determine where a significant enough difference occurs to warrant different pricing. You will increase the opportunity for portfolio profitability through this analysis, as you are reducing the likelihood that higher risk applicants are receiving lower pricing.  As expected, the overall risk management of the portfolio will increase when a proper risk-based pricing program is developed. In my next post we will look the final level of validation which does provide insight into pricing for profitability.