The latest tactics for bank treasury go beyond stress tests and sensitivity to Fed rate changes to focus on banking business challenges like modelling depositor behavior.
Members of the Bank Treasurers’ Peer Group met in May in New York to discuss bank regulatory reform, share their experiences with the latest rounds of stress testing and consider how reg reform will affect them. They also mulled the rate outlook and how to adjust asset sensitivity and, most importantly, how to model deposits—looking beyond betas, or the sensitivity to Fed rate moves, to myriad other factors. This relates to shifting what one member calls “Big A” analytical resources from focusing solely on stress testing (expected to become less onerous with new legislation and Trump regulatory appointments) to looking at banking business challenges like deposit acquisition and runoff mitigation. These themes framed the major questions of discussion:
1) Regulatory Reform—Can Treasury Get Time Back for Banking Business? To what extent will bank regulation reform restore the balance between bank treasurers’ focus on compliance and supporting their banking business?
2) What’s the New Normal Driving Depositor Behavior? External bank equity analysts are seeking to model net interest margin sensitivity by looking at asset as well as deposit betas. Big A analysts (think quantitative skills) in treasury, meanwhile, are looking beyond betas to capture depositors’ non-interest sensitivities.
3) What to Do About Stress Testing? Stress testing, according to consensus, will not disappear immediately, either for capital or liquidity. So how should banks be thinking about stress testing as regulators decide how to reform requirements on how tests must be performed?
Regulatory Reform—Can Treasury Get Time Back for Banking Business?
To what extent will the reform of bank regulations restore the balance between bank treasurers’ focus on compliance and supporting their banking business? Variations on this question were a recurring theme of the meeting. The following takeaways shed light on the degree to which regulatory reform may help promote equilibrium.
KEY TAKEAWAYS
1) Don’t plan on shelving CCAR or DFAST next year. Some members with less than $50 billion or $100 billion in assets would love to shelve full stress testing submissions as soon as next year. While it’s possible, it’s probably wishful thinking to expect the Comprehensive Capital Analysis and Review (CCAR) or the Dodd-Frank Act Stress Test (DFAST) to fall off so fast. Stress testing will continue in the absence of regulatory fiat—this remains the consensus—but members want to scale back documentation, model validation requirements and governance overkill.
2) Crapo bill passed as expected before Memorial Day. The Crapo bill, among other things, will move the line for systemically important financial institutions (SIFIs) from $50 billion in total assets to $250 billion, with an 18-month phaseout for banks between $100 billion and $250 billion. According to our opening dinner speaker, the legislation could have gone further but moving the line is significant, a view that was corroborated in our session the next day.
3) CRA tweaks will also help M&A. Moving the SIFI line will help strategic mergers in banking, as will tweaks to Community Reinvestment Act (CRA) rules. Community groups and their constituents will no longer be able to hold up a banking license or merger change up to the very last minute with accusations of community harm. Less-than-satisfactory opinions will no longer be fatal.
4) Fed has most deep state staffers. The Office of the Comptroller of the Currency is the prudential regulator that is most open to reform, followed by the FDIC, which is expected to have new board appointments soon. The Fed is more difficult given the enhanced power that Fed staff has enjoyed in regulating banks since the financial crisis. Fed regulators are much more reliant on their staffs than other regulators, and there has been much more centralization of regulatory decision-making there. How much this gets rolled back is something members should watch.
5) Given the Fed is the lagging reformer, play the BHC card. From discussions of banks looking to simplify their structures emerged the suggestion that banks tell the Fed they might give up their bank holding company to streamline regulation. The cons may outweigh the pros, but it is a potential negotiating ploy.
Make the Case for Bank Value and Growth
- ALM and balance sheet sensitivity to rates vs. growth. As banks seek to tell Wall Street a story of future growth, they are going to test their commitment to asset-liability and balance sheet management. Unfortunately, equity analysts don’t have a great understanding of these subjects or the trade-offs necessary for a growth story, which favors asset sensitivity, especially as rates rise. All treasury can do is raise awareness internally of the trade-offs and ensure senior management and the board are making decisions based on economic and risk-adjusted facts.
- Banks, especially regional banks, remain a safe harbor for credit. With M&A and other outcomes of tax reform creating credit concerns in other sectors, banks remain a safe harbor, says Morgan Stanley. A pullback in cash-rich corporate issuance gives more room for others to issue. Roadshows and investor relations are increasingly important and Morgan Stanley encouraged members to stay active in marketing their bonds.
- Focus and create a niche. Morgan Stanley’s mid-cap bank analysts suggested that regional banks focus and define a valuable niche to differentiate themselves and mitigate the competitive impact of larger national and global banks seeking to encroach on their deposit domains. Bigger banks are trading brand for price, so regional banks need to think more about their brand and what it stands for in each of their markets.
OUTLOOK
One reason reducing regulatory demands on banks is so important, and potentially exciting, is that there are so many nonregulatory challenges facing the banking business today. There is an opportunity to apply analytical resources honed by stress testing to these challenges, starting with new deposit and other banking playbooks that will be written using Big A analytical capabilities typically found in treasury. Deposit modelling is just one element of this. What factors are driving deposit retention and acquisition apart from rate sensitivity, such as marketing spend and customer personas? Also, what might banks offer depositors to reduce runoff as rates rise? This is all a part of a deployment of predictive analytics to drive better decisions.
What’s the New Normal Driving Depositor Behavior?
Bank equity analysts want to model net interest margin sensitivity by looking at asset and deposit betas (see sidebar). Big A analysts in treasury, meanwhile, are looking beyond betas to capture depositors’ non-interest sensitivities.
KEY TAKEAWAYS
1) What’s the new playbook for deposits? The question asked most frequently by members this year is what is the new playbook for deposits? Banks are not experiencing their modelled or expected betas and there is a sense that more than interest rates and deposit pricing are needed for the deposits retention and acquisition strategy. While larger banks may be further along in developing a more granular analysis of deposits and applying it to acquisition and retention strategies, no one seems to believe they have unlocked the new playbook for success.
2) Making deposit models more dynamic. The other issue with deposit modelling is how to make it more dynamic and predictive rather than static, linear and backward-looking. When polled, members were split almost evenly on the use of dynamic models vs. static, while suggesting that more are using both types. Since most banks are expecting deposit behavior to catch up to their modelled betas as rates continue to rise, it’s surprising that only a third of those polled at the meeting said they are modelling the catch-up.
3) More granular deposit modelling for the business. Applying CCAR and DFAST models to business applications will require banks to increase granularity. With deposits, for example, regulatory stress testing allows an aggregation approach. But modelling deposit behavior for the business requires breaking down the analysis—by depositor, by product and by geography. “It’s more akin to looking at the mortgage book,” one member said. You also need the flows and not just the average balances, and that becomes a bigger data challenge. “How do you even get those numbers?” one member asked.
4) Bring together treasury and the business. As deposit modelling moves beyond interest rate sensitivity to broader macroeconomic variables and market conditions, both treasury and the business need to be engaged. “A good process is to have people from treasury with content knowledge of how deposits react to interest rate changes and people from the business with practical hands-on experience with deposit customers,” said an expert from Novantas. This gets treasury involved in business, tracking the effectiveness of marketing campaigns in terms of deposit pricing and retention. But it also brings the business to treasury, opening the door for more discussion on funds transfer pricing (FTP) and liquidity impacts on deposit pricing. It’s important for both sides to elevate their understanding of how deposits are acquired and retained.
Relying on a Contingency Committee When Crises Hit Is Ridiculous
Members shared their various approaches to a contingency funding committee and related plan. “We have the 30-40 reports needed to make funding decisions for the bank automatically pulled to a shared drive that can be pulled into a committee meeting at any point,” one member said. The reality, though, the discussion revealed, is that in a crisis the funding decisions are not going to wait for a committee to come together to execute, so it’s something of a check the box or preparation exercise. The same holds true for the equivalent liquidity crisis team. Regulators want a quantitative trigger or early warning indicators (EWIs) that force the team and its plan into action. Here, again, the reality is that by the time these triggers are tripped, it may be too late for the team to respond. That must happen before the data comes in to trip something. Bureaucrats are averse to leaving anything to judgment. On the other hand, the committees do help in some instances. Periodically, “we get a call from the FDIC noting that our liquidity had breached a limit,” another member noted, since they are monitoring the call reports. Having the committee to go through the cause and temporary nature of the limit breach can be a source of reassurance. To build a story that hangs together, sometimes you need more than one person to come up with it.
OUTLOOK
As one member noted at the end of the session, nothing he heard about the new factors involved in deposit modeling has convinced him that any bank has found the answers to what is driving depositor behavior today and factored them into its model. That won’t stop him and others from trying. Eventually, members will find better answers to what’s driving deposits and figure out how to incorporate them into their models.
What to Do About Stress Testing?
Stress testing, the consensus held, will not disappear immediately, either for capital or liquidity. So how should banks be thinking about stress testing as regulators figure out how to reform the requirements on how tests must be performed? Here are some key takeaways from related discussions.
KEY TAKEAWAYS
1) LCR vs. LST. In a breakout discussion, members said that regulators still appreciated the effort to undertake a modified liquidity coverage ratio (LCR) and that it is worth considering from a management standpoint as well. The most efficient approach is to develop it in the same framework and definition of liquidity stress (monthly). This means standard, systemic scenarios (e.g., a grid with limits). Some members said they do a daily liquidity horizontal review using the 2252a templates and submit it monthly. On the larger bank side, a similar conversation took place about using the LCR framework for liquidity stress testing (LST).
2) LST challenges. The challenge with LST is to integrate across market, idiosyncratic and combined scenario sets. Treasurers noted doing 14-, 30-, 45- and 90-day liquidity requirement tests under stress and even 90+ days, with tailored, well-supported assumptions for individual scenarios. Reg YY and other regulations suggest going out 12 months, which gets kind of ridiculous. Most will do a survival of the bank scenario beyond 90 days, however. One member who has both a bank and a broker-dealer noted that running one-day liquidity stress tests is not that painful but it’s different on the bank side. Most banks do a daily monitoring of liquidity stress, with a month-end submission. But many feel that the day when they will be running a quantitative risk management (QRM) liquidity stress test every day is coming.
3) More from the second line. The Fed has started to challenge a second line of defense that merely entails a separate meeting to review the same data and reports. They want to see the second line use a separate instance of QRM and a clean load-up of the balance sheet. The second line needs to have its own data and to rely on its own capabilities.
4) CCAR scenarios invite gaming with lack of realism. The CCAR breakout discussion touched on the Fed discouraging the use of CCAR models for running the bank given the increasing unrealism of its severely adverse scenarios. If the link between regulatory CCAR and reality goes away, it will create a temptation to game the process. And scenarios with more remote potential of occurrence increase the perception that stress testing is a waste of resources.
Libor Alternative Pushback
Members pointed out concerns about SOFR, the Libor alternative. One big issue is the lack of credit considerations, given it’s a secured rate. This will generate difficulties in applying it to unsecured lending. There is also no term structure, e.g., no way to get an actual rate quote for three months out. More broadly, there is concern that dominant broker-dealer banks may be able to manipulate the rate and opportunities might emerge to arb between secured and unsecured rate-linked products. Members said they would have preferred something like the FHLB advance rate as a reference. It’s more relevant to their business.
Watch out for “zombie Libor.” Whatever replaces Libor, don’t assume Libor will actually go away. Because so many financial contracts reference it, a document review on citations of the reference rate is critical. Until the decision to phase out Libor was reached, most market participants contemplated an alternative rate in scenarios where Libor was not being quoted. The reverse is now more the concern: What if contracts uphold a Libor rate if it’s still being quoted? This opens up the risk of a “zombie Libor” where two or even more banks continue to quote it to keep it alive. As it ceases to be a reference rate, banks do not want to see any contracts at risk of being tied to it.
OUTLOOK
We hope regulators see the opportunity to make stress testing a permanent and positive fixture of bank risk management and meet banks and their Big A analysts halfway. That is, they should seek to reform bank regulation to make it increasingly relevant to running a bank business, including ensuring adequate capital and liquidity with prudent risk mitigation, and look closely at requirements that take resources away from these aims. If this is the outcome of reform, then job satisfaction for treasurers may skyrocket. Next year, we hope more than 31% of you say your job satisfaction has improved significantly.
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