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Washington Bankers Association Executive Development Program Turning ALCO into a Profit Center Thomas Farin President Farin & Associates Inc. [email protected] www.farin.com © 2012 FARIN & Associates Inc. 1 Agenda • Setting up a Dynamic A/L Process – Interest Rate Risk • Dynamic Income at Risk • Dynamic Value at Risk – Liquidity Risk • Liquidity Coverage Ratio • Dynamic Sources and Uses • Contingency Funding Plans • Non-Maturity Deposits – Analysis – Strategies • Loan Pricing – A Focus on Mortgages • Assessing Capacity to hold FRMs • Structural Tools for Supporting FRMs – Non-Maturity Deposits – FHLB Advances • Using ALCO to Evaluate Risk/Return Tradeoffs between Alternative Strategies • Effect of Core Studies © 2012 FARIN & Associates Inc. 2 Why is a Capital Plan Important • We will have new capital requirements • Defines the long-range targets we are going to shoot for in the annual budget and extended planning process • Develops annual goals that mark progress along the way to setting strategic goals • Your capital plan feeds: – Core funding growth goals – Non-Regulatory core funding goals – Goals for overall level of investments – Goals for overall level of loans – Goals for business plan or strategy we will be evaluating and stress testing © 2012 FARIN & Associates Inc. 3 Effective Capital Plan • Horizon • Step 2 – Set Annual Goals – 5 Year Horizon – note: regulators appear to be requiring 9 quarters … • Step 1 – Long-Range Financial Goals – Reconcile earnings, capitalization, growth, and dividend policy – Equalize LT growth - core, loans, & assets – Balance sheet mix – Lead to achieving financial goals – Provide framework for drilling down in greater detail • Step 3 – Build the Business Plan – Using your A/L & Planning model – Attempt to hit annual goals set in Step 2 • Loans, investments, NE assets • Core, non-Core, other, capital – Included in ABA Liquidity Toolbox - Tool 1 © 2012 FARIN & Associates Inc. 4 XYZ Bank • Case study institution that runs all the way through the ABA Liquidity Toolbox. • Dealing with asset quality problem, short-term earnings issues, liquidity issues and potential capital issues • ABA Toolbox 1. Capital plan 2. Core Funding Plan 3. Asset-Based Liquidity Buffer 4. Non-Core Funding 5. Policy Statement, Policy Limits and Measurement System © 2012 FARIN & Associates Inc. 5 © 2011 Farin Capital Plan - History Ending balance sheet numbers for As of: date Net income for year ending on As of: date Three years of historical ratios. Not crucial to operation of model, But helpful in reviewing trends. © 2012 FARIN & Associates Inc. 6 © 2011 Farin Capital Plan – Step 1 - SFG Set and Reconcile Long Range Goals Strategic Financial Goals are long-range financial goals you hope to achieve within five years. Mutuals not used to setting ROE goals Could compute ROE goal as follows •ROE Target •Core Capital/Asset Target •Suggested ROA target calculated from ROE target and capital/asset target •Goal for ROA •Dividend payout percentage •Organic capital growth calculated from ROE and dividends •Sets suggested Loan Growth rate •Sets suggested regulatory core growth rate •Enter goal for Loan Growth •Goal for Investments/Assets •Goal for Non-Earning Assets/Assets •Goal for Regulatory Core Growth •Goal for Non-Regulatory Funding/Assets •Goal for Other Liabilities/Assets ROEgoal = ROAgoal / Capital/Assetsgoal © 2012 FARIN & Associates Inc. 7 Capital Plan – Step 1 - SFG The organic capital growth rate is calculated as follows: OCGR = ROE * (1 – Div/Inc) Set and Reconcile Long Range Goals •ROE Target •Core Capital/Asset Target •Suggested ROA target calculated from ROE target and capital/asset target •Goal for ROA •Dividend payout percentage •Organic capital growth calculated from ROE and dividends •Sets suggested Loan Growth rate •Sets suggested regulatory core growth rate •Enter goal for Loan Growth •Goal for Investments/Assets •Goal for Non-Earning Assets/Assets •Goal for Regulatory Core Growth •Goal for Non-Regulatory Funding/Assets •Goal for Other Liabilities/Assets Unless capital actions are taken, over the long haul, goals for capital growth, asset growth, loan growth, and core funding growth need to be the same for the balance sheet to remain in the relative state set by the goals. © 2012 FARIN & Associates Inc. 8 Capital Plan – Step 1 - SFG Goals for loan growth and core funding Set and Reconcile Long Range Goals •ROE Target growth will normally match those in •Core Capital/Asset Target balanced column. Exceptions would be •Suggested ROA target calculated from ROE target and capital/asset target if the institution plans to inject new •Goal for ROA capital or repurchase existing capital. •Dividend payout percentage •Organic capital growth calculated from ROE and dividends •Sets suggested Loan Growth rate •Sets suggested regulatory core growth rate •Enter goal for Loan Growth •Goal for Investments/Assets •Goal for Non-Earning Assets/Assets •Goal for Regulatory Core Growth •Goal for Non-Regulatory Funding/Assets •Goal for Other Liabilities/Assets © 2012 FARIN & Associates Inc. 9 Capital Plan – Step 2 – Annual Goals Strategic Financial Goal Most recent historical result Annual goals (blue) Forecast Calculated results (black) History Strategic Financial Goal Set in Step 1 Annual goals section layout – You are setting annual goals that step you from your current/recent results in the direction of achieving your Strategic Financial Goals. © 2012 FARIN & Associates Inc. 10 Capital Plan – Step 2 – Annual Goals Investments Note: the goals for investments/assets, non-earning assets/assets and annual loan growth collectively drive growth in total assets. None of the ending numbers are valid until all three sets of goals have been entered. The strategic financial goal for investments should consider the tradeoffs between liquidity risk and return. XYZ management feels recent levels of investments are too low to meet asset-based liquidity needs. Therefore they set a higher SFG. This SFG may need to be revisited when work on Tool 4 is complete. Annual goals for investments should consider how fast the institution can reasonably be expected to move in the direction of the goal. XYZ management feels that the SFG can be achieved within three years. © 2012 FARIN & Associates Inc. 11 Capital Plan – Step 2 – Annual Goals Non-Earning Assets / Assets Note: the goals for investments/assets, non-earning assets/assets and annual loan growth collectively drive growth in total assets. None of the ending numbers are valid until all three sets of goals have been entered. The strategic financial goal for non-earning assets should be for normal times. XYZ management feels recent levels of non-earning assets are higher than normal as a result of asset-quality problems. Therefore they set a lower SFG. Annual goals for non-earning assets/assets should consider how fast the institution can reasonably be expected to move in the direction of the goal. XYZ management feels that the level will increase in the first year because of asset quality issues, then return to normal by the end of year four. © 2012 FARIN & Associates Inc. 12 Capital Plan – Step 2 – Annual Goals Loan Growth Rate Note: the goals for investments/assets, non-earning assets/assets and annual loan growth collectively drive growth in total assets. None of the ending numbers are valid until all three sets of goals have been entered. The strategic financial goal for loan growth will normally equal the goal for internal capital growth unless you wish to raise or retire capital. XYZ management does not intend to take capital actions so they set the SFG equal to internal capital growth. Annual goals for loan growth should consider loan demand and the institution’s financial condition. XYZ management needs to shrink loans and assets in the first two years in order to maintain capital/assets while losing money. Once earnings come back on stream, they can begin growing loans, reaching the SFG by year five. © 2012 FARIN & Associates Inc. 13 Capital Plan – Step 2 – Annual Goals Core Growth Rate Note: Goals for core growth rate are independent of any other goals in the model. On the other hand, the goal for Non-Reg Core/Assets is dependent on this setting. The strategic financial goal for Core Growth will normally equal the goal for internal capital growth unless you wish to raise or retire capital. XYZ management does not intend to take capital actions so they set the SFG equal to internal capital growth. Annual goals for core growth should consider asset growth and what management wishes to do to the Non-Regulatory Core/asset ratio. XYZ management has set annual core growth goals above the asset growth rate in years 1-4 as they wish to reduce their reliance on non-core funding. They reach the SFG in year 5. If the core growth rate is too high, Non-Regulatory Core/Assets could go negative. © 2012 FARIN & Associates Inc. 14 Capital Plan – Step 2 – Annual Goals Other Liabilities/Assets Note: Goals for Other Liabilities/Assets is independent of any other goals in the model. On the other hand, the goal for Non-Reg Core/Assets is dependent on this setting. The strategic financial goal for Other Liabilities/Assets will normally be based on current/recent results. The effect of this goal is trivial but it is necessary to balance the balance sheet. XYZ management set the SFG equal to the recent/history result. Annual goals for Other Liabilities/Assets will normally be set equal to the SFG. XYZ management has set Other Liabilities/Assets goals equal to the SFG for all 5 years. © 2012 FARIN & Associates Inc. 15 Capital Plan – Step 2 – Annual Goals ROA Goals Note: Goals for ROA are independent of any other goals in the model. This screen plus the following screen covering capital actions drive growth in capital, Note that ROA Is an input to this model. Use your bank’s planning model to develop the plan to meet these goals. The model recommends an ROA SFG based on the ROE and capital/asset goals. You will normally accept this recommendation. XYZ’s ROA goal is that calculated by the model based on their ROE and capital/asset goal. Annual goals for ROA should consider evolution of your bank’s financial condition over time. XYZ management set negative ROAs in years 1 and 2 to reflect the evolution of their asset quality problem. By year 5 they hope to reach the SFG for ROA. © 2012 FARIN & Associates Inc. 16 Capital Plan – Step 2 – Annual Goals Capital Actions Note: Goals for Dividends/Income combined with ROA goals and new capital drive growth in capital in this model. The SFG for dividends/income should represent the percentage of net income to be paid to stockholders. Mutuals should leave this set to 0%. XYZ management, a C corporate set the SFG to 33%, the expectations of their stockholders. Annual goals for dividends/income should be mindful of the SFG but also the institution’s ability to maintain adequate capital. XYZ management set dividends/income to 0% in years 1 and 2 to preserve capital. It is set at 33% for the three remaining years. Institutions planning to inject new capital (positive number) or buy back capital (negative number should enter the amount in thousands in column H. © 2012 FARIN & Associates Inc. 17 Capital Plan – Step 2 – Annual Goals Capital/Assets Note: Numbers appearing on this screen are calculated based on other inputs. There Is no need for input in this area. However should results be unsatisfactory, additional tuning of other inputs may be necessary. The SFG for Capital/Assets will be the core capital ratio needed to meet regulatory capital minimums plus a buffer needed to absorb risk that management feels appropriate based on stress testing and other factors. XYZ management set the SFG at 9.0% Annual results for capital/assets will be a byproduct of total assets and total capital projections earlier in the model. XYZ management finds the set of assumptions entered into this model (if achieved) will allow it to reach its SFG for capital/assets by year 4 of the plan. © 2012 FARIN & Associates Inc. 18 Capital Plan – Step 2 – Annual Goals ROE Note: Numbers appearing on this screen are calculated based on other inputs. There Is no need for input in this area. However should results be unsatisfactory, additional tuning of other inputs may be necessary. The SFG for ROE will be the ROE needed to meet investor expectations. For mutuals, it will be their desired internal capital growth rate. XYZ management set the ROE SFG at 12% to achieve investor expectations. Annual results for ROE are calculated by multiplying the ROA goals set earlier by the calculated equity multiplier. XYZ management finds the set of assumptions entered into this model (if achieved) will allow it to reach its SFG for ROE in year 5 of the plan. © 2012 FARIN & Associates Inc. 19 Capital Plan – Step 2 – Annual Goals Non-Regulatory Core/Assets Note: Numbers appearing on this screen are calculated based on other inputs. This is the model’s balancing account. If the annual numbers go negative, you will need to reduce the core funding growth rate or take actions to grow assets. The SFG for Non-Regulatory Core/Assets will be a level consistent with a bank’s policy limit while providing adequate borrowing capacity to deal with liquidity stress events. XYZ set their SFG at 20%, ½ of the policy limit in their liquidity policy. Annual results for ROE are calculated by subtracting total liabilities and capital from total assets on the previous screens. The difference is the amount of non-regulatory core funding needed to balance the balance sheet. The fact XYZ’s goals for core funding growth exceed its goals for asset growth is the primary reason its ratio is dropping over time. The SFG is reached in year 3. © 2012 FARIN & Associates Inc. 20 Capital Plan – Step 3 Develop Your Plan • The result of this exercise is a high level set of goals • The final step is to use your planning model to develop a detailed plan to reach these goals. – This plan is, of course, your business plan that will be used in to assess liquidity in the context of the business plan. – It will also be the business plan to which you will apply stress tests in stressing your institution’s liquidity under liquidity stress events and interest rate risk using the stress tests we will discuss. © 2012 FARIN & Associates Inc. 21 Wouldn’t It Be Nice If: • We built our budget or business plan for 2012 • We extended it for two additional years to see the long-term effect • We modeled the plan through multiple rate environments to test income at risk • We ran value at risk analysis (EVE) at the beginning and end of the plan • We evaluated liquidity risk in the plan using sources/uses • We ran liquidity stress tests on the plan • We were not satisfied with the results (risk/risk or risk/return), we modified strategies and ran the same tests • We chose the version of the plan with the best risk/risk and risk/return tradeoffs • On a quarterly basis we rolled the plan forward a quarter and repeated the same process, tweaking the plan as necessary © 2012 FARIN & Associates Inc. 22 Questions Answered • Would it make sense to portfolio fixed-rate mortgages? • Would it make sense to ladder out my investment portfolio? • Do I really need to extend my CDs to manage my interest rate risk? … or … • Would an effective strategy for pricing my nonmaturity deposits turn out to effectively hedge my interest rate risk? Would you like to turn your ALCO process into a profit center rather than just a regulatory compliance cost? © 2012 FARIN & Associates Inc. 23 Developing the Plan • In order to move on to budgeting and planning to meet the goals we’ve established (annual and strategic) we need to get some tools on the table – – – – Liquidity risk analysis tools Interest rate risk analysis tools Core funding analysis tools and strategy Loan pricing used to identify well priced loans © 2012 FARIN & Associates Inc. 24 Stress Tests - What Are They Talking About? Stress tests • Interest rate risk • Credit Risk • Liquidity Risk IRR Credit Liquidity Food for thought question: We know that a rising rate environment could affect our case institution’s bottom line because of interest rate risk. But how might the bottom line also be affected by credit risk and liquidity risk? What if the institution is already weakened by asset quality problems? © 2012 FARIN & Associates Inc. 25 Stress Test Objective • Test whether an institution has sufficient capital to remain Well Capitalized after a severe stress Says to us: – New capital regulations will set minimums – Stress tests will define cushions • Recently verbalized regulatory approach – Simple enough to be done in a spreadsheet – Note that the OCC released Community Bank Stress Test Guidelines in October 2012. © 2012 FARIN & Associates Inc. 26 Dynamic Interest Rate Risk • Interest Rate Risk – Income at risk (IAR) is dynamic if it is evaluated by stressing a plan or strategy • Income at risk testing involving holding the balance sheet constant is static measurement of income at risk – EVE (VAR) is a static measure of IRR – EVE becomes dynamic if tests are performed on a balance sheet resulting from a plan or strategy Note: Any static measure can be converted it to a dynamic measure by performing the analysis on forecast balance sheets. © 2012 FARIN & Associates Inc. 27 Dynamic IAR Comparison of Alternative Strategies Income at Risk - ROA Expected and alternative rate environments. Rate Env Pol Limit Stgy 1 Stgy 2 Stgy 3 Stgy 4 +300 bp -25% 0.8% 0.72% 0.96% 0.92% Expected Maximum 1.20% 0.72% 1.14% 1.18% -200 bp 1 Yr Extend 2 Yr Budget Strategic -25% 1.56% 0.72% 1.32% 1.38% Income at risk policy limits. Same metric used to measure return is used to measure risk (ROA) Question for stakeholders: If ROA is the primary metric we use to measure return, how much of ROA are we willing to have at risk under alternative rate environments? © 2012 FARIN & Associates Inc. 28 Dynamic IAR Comparison of Alternative Strategies Income at Risk - ROA Expected and alternative rate environments. Rate Env Unacceptable: Lousy return! Pol Limit Stgy 1 Stgy 2 Stgy 3 Stgy 4 +300 bp -25% 0.8% 0.72% 0.96% 0.92% Expected Maximum 1.20% 0.72% 1.14% 1.18% -200 bp 1.56% 0.72% 1.32% 1.38% -25% IAR modeling can eliminate poor strategies based on their risk and return, limiting choices to strategies with acceptable risk/return tradeoffs. Unacceptable: Too much risk! But what’s missing in this analysis? © 2012 FARIN & Associates Inc. Acceptable risk/return tradeoffs! 29 Static Value at Risk Today Horizon Remaining life of all instruments Immediate & Permanent Rate Shocks Current Balance Sheet In static value at risk analysis, all cash flows over their remaining lives are generated for every financial instrument on the balance sheet for each rate environment. Discount rates are then used to mark the cash flows to market. © 2012 FARIN & Associates Inc. 30 Dynamic Value at Risk Today Horizon Typically 2-3 Years A dynamic value at risk analysis uses the same approach as a static value at risk analysis except it is performed on the balance sheet that exists at the end rather than the beginning of the planning horizon. Rate shocks Expected rate environment Current balance sheet and forecast balance sheet are different reflecting the effect of the plan or strategy. © 2012 FARIN & Associates Inc. 31 Value at Risk Limits (Results Could Be from Static or Dynamic Testing) OTS TB-13a Rating Post-Shock NPV Ratio 100 - 200 bp Minimal (1) 200 - 400 bp Minimal (1) Over 400 bp Moderate (2) 6.0% to 10% 0 - 100 bp Minimal (1) 13.21% 71.6bp Minimal (1) Minimal (1) Moderate (2) Significant (3) 4.0% to 6.0% Minimal (1) Moderate (2) Significant (3) High (4) Under 4.0% Moderate (2) Significant (3) High (4) High (4) Over 10% March-09 Ratios Post Shock NPV Post Shock Sensitivity (bp Chg from Flat) Chg from Book (Shock - Book) % Chg from Book Interest Sensitivity Measure I & P -300 12.91% (101.2) 12.14% I & P -200 13.32% (60.9) I & P -100 13.64% (28.9) Flat rates 13.92% - I & P 100 13.67% (25.1) I & P 200 13.21% (71.6) I & P 300 12.46% (146.3) 0.77% 6.38% 1.18% 9.71% 1.50% 12.34% 1.79% 14.71% 1.54% 12.65% 1.07% 8.82% 0.32% 2.67% Book Equity How would you feel of your plan moved you from here to here? © 2012 FARIN & Associates Inc. 32 Liquidity Risk • Definition: The risk that an institution is unable to produce enough sources of funds to meet anticipated or unanticipated uses of funds. – Sources: Loan and Investment Payments, Saleable Assets, Borrowings, Deposit growth – Uses: Loan originations, investment purchases, deposit and borrowing outflows © 2012 FARIN & Associates Inc. 33 Sound Liquidity Practices • • • • • Governance – BOD and management Appropriate strategies, policies, procedures Cash flow oriented measurement systems Intraday collateral and liquidity management Diverse mix of present and potential funding sources • • • Adequate levels of highly liquid marketable securities Comprehensive contingency funding plans addressing adverse events Internal controls and audit requirements © 2012 FARIN & Associates Inc. 34 Evolving Framework • Movement away from – Static measures – Balance sheet liquidity measures • Movement toward – Dynamic measures • Loans/shares or loans/assets • Non-core funding dependency • Liquid Investments/assets • Current balance sheet • Business strategy or plan • Unexpected triggering events – Fail well capitalized status – Securitization markets freeze up – Corporate CU placed into receivership • Requires contingency funding plans © 2012 FARIN & Associates Inc. 35 Measurement Framework Liquidity Measurement Goals: • Assess impact of plan on liquidity position • Ensure adequate sources to meet unanticipated (stressed) needs – Highly liquid securities – External Borrowings • Integrate Contingency Funding Plan into Liquidity Assessment – Define and assess stress events that impact plan cash flows © 2012 FARIN & Associates Inc. 36 Measurement Framework Primary Measurement • Liquidity Coverage Ratio – – – – Measures adequacy of asset-based liquidity buffer Is a stress test Proposed by Basel Not yet implemented by US regulatory agencies • Forecast Sources and Uses of Fund (Liquidity Gap) – Assess risk in plan – Relies on institution goals for key performance ratios as guides to plan – Measures size and trend in combined asset and liability based liquidity buffers (unused borrowing capacity) – Can be stress tested © 2012 FARIN & Associates Inc. 37 How Much Asset-Based Liquidity is Enough? – Numerator • Options – Peer group data – inconsistent with guidance – Some standardized measure – Basel LCR • Basel LCR • Cash & Due From • Highly Liquid Unencumbered Marketable Securities – Denominator • Deposit Runoff • Cut off from Non-Core Funding • Line Draw Downs • Less Cash Inflows – Limited – Test - Do you have sufficient cash to survive a 30 day stress? – Guideline • Maintain LCR >= 100% © 2012 FARIN & Associates Inc. 38 Using LCR to Set Limits Actual XYZ Exposure – Tool 4 XYZ Policy Limits – Currently operating in red light zone. Note that the LCR could be calculated on forecast balance sheets in business plan showing time frames for moving into compliance. Static measure – how do we convert to dynamic? © 2012 FARIN & Associates Inc. 39 Liquidity Gap Report • Liquidity Gap Report – Summary of Cash Flow sources and uses impact on liquidity – Dynamic by its nature • Use a forecast (Plan) for growth assumptions • Use starting cash flows to project inflows and outflows – Apply Contingency Funding Plan Stress Tests & assess liquidity needs • Impact of missing deposit growth by 10% • What if loan repayments accelerate or slow? • What happens to total ratio if access to key funding sources is gone? – Brokered CDs – FHLB 40 © 2012 FARIN & Associates Inc. 40 MB&T Liquidity Gap Liquidity Report Mar-2010 (Q) Jun-2010 (Q) Sep-2010 (Q) Dec-2010 (Q) (Dollars i Total Inflows Cumulative Inflows Total Outflows Cumulative Outflows Cash Flow Surplus (Deficit) Cum Cash Flow Surplus (Deficit) 60,017,242 60,017,242 55,254,540 55,254,540 4,762,702 4,762,702 86,191,620 146,208,862 92,655,515 147,910,055 (6,463,894) (1,701,193) Total Inflows Cash & Overnight Investments Less: Overnight Borrowings Available HLUM Securities Unused Borrowing Capacity Total Available for Liquidity Total Outflows Total Liquidity Gap Total Liquidity Sources/Uses Total Liquidity Gap/Assets 60,017,242 86,191,620 10,005,990 3,542,100 5,866,988 7,782,965 13,717,820 20,143,612 89,608,040 117,660,297 55,254,540 92,655,515 34,353,500 25,004,783 162.17% 126.99% 11.54% 8.71% 56,850,228 203,059,090 52,084,214 199,994,268 4,766,014 3,064,822 56,850,228 8,308,110 9,585,959 22,342,316 97,086,613 52,084,214 45,002,399 186.40% 15.87% 54,627,817 257,686,908 52,433,319 252,427,587 2,194,498 5,259,320 54,627,817 10,502,610 9,467,251 25,815,670 100,413,348 52,433,319 47,980,029 191.51% 17.28% Periodic Liquidity Gap © 2012 FARIN & Associates Inc. 41 MB&T Liquidity Gap Cumulative Inflows Cash & Overnight Investments Less: Overnight Borrowings Available HLUM Securities Unused Borrowing Capacity Cumulative Available for Liquidity Cumulative Outflows Cumulative Liquidity Gap Cum Liquidity Sources/Uses Cumulative Liquidity Gap/Assets 60,017,242 146,208,862 203,059,090 10,005,990 3,542,100 8,308,110 5,866,988 7,782,965 9,585,959 13,717,820 20,143,612 22,342,316 89,608,040 177,677,539 243,295,475 55,254,540 147,910,055 199,994,268 34,353,500 29,767,484 43,301,207 162.17% 120.13% 121.65% 11.54% 10.36% 15.27% 257,686,908 10,502,610 9,467,251 25,815,670 303,472,439 252,427,587 51,044,851 120.22% 18.38% Policy set around Cumulative Liquidity Gap/Asset Cumulative Liquidity Gap © 2012 FARIN & Associates Inc. 42 Liquidity Policy Limits • Limits should indicate base plan levels of risk • As stress tests are added, a second level of limits are required to: – Reflect levels of sources required to survive liquidity stress events – Outline likely actions • In addition to limits, trigger ratio ranges set to act as early warning signals to plan goals © 2012 FARIN & Associates Inc. 43 Liquidity Gap/Asset Policy Limits 12 Month Liquidity Gap/Asset Ratio Threat Level => 15% Green Light >= 10% and <15% Yellow Light < 10% Red Light © 2012 FARIN & Associates Inc. Actions No actions required, continue normal monitoring and reporting Develop options for asset or liability changes in plan to return to Green within 6 months. Immediate plan changes to be implemented and impact of Contingency Funding Plan assessed for realistic stress events. Monitoring monthly until return to Yellow 44 Stress Events • Regulators want to know how long you can last if things turn from good to bad and bad to worse… • Purpose is to determine how you will survive severe liquidity stresses • Capital Scenario Outline: – MB&T projects a drop below “Well Capitalized” level • Highly likely given credit concerns and capital levels – Events are sequenced over time reflecting likely changes to business plan – Timeline of events… © 2012 FARIN & Associates Inc. 45 MB&T Stress Test © 2012 FARIN & Associates Inc. 46 Stressed Liquidity Gap/Assets Stressed Limits © 2012 FARIN & Associates Inc. 47 CFP for Capital Failure Numbers 3, 5, and 6 are already in base business plan Number 4 and further implementation of 5 are in stress scenario © 2012 FARIN & Associates Inc. 48 CFP for Cascading Events These items are all implemented as capital failure scenario continues to unwind. © 2012 FARIN & Associates Inc. 49 CORE DEPOSIT ANALYSIS © 2012 FARIN & Associates Inc. 50 Two Most Crucial A/L Assumptions • Pricing Betas – the extent to which a change in market rates is passed along to deposit customers – Income at risk analysis – EVE analysis • Decay rates – the speed at which non-maturity deposits decay off books over time – EVE analysis – Liquidity analysis • What is the greatest commonly expressed fear about NMD funding? © 2012 FARIN & Associates Inc. 51 Non-Maturity Deposits • Segmentation Strategies • Actual Behaviors – Rates on some of these accounts respond moderately and slowly in response to changes in market rates – Balances are retained for long periods of time in spite of rate behavior – Acts like: Stable supply, semi-fixed rate, long-term – Actual Counterpart – laddered portfolio of fixedrate long-term CDs – Rates respond very slowly to changes in market rates on non-rate sensitive portion – Rates respond more quickly to changes in market rates on rate sensitive portion – Weighted average cost moves relatively slowly in response to changes in market rates – Lots of barrier to entry options • • • • Product design Tiers Transactional Channel Is the ‘term’ of non-maturity deposits important as we head into a rising rate environment? © 2011 Farin & Associates, Inc © 2012 FARIN & Associates Inc. 52 Non-Maturity Deposit Life • Key Concept – Non-maturity deposits don’t all ‘mature’ at the same time – Instead, balances in accounts decay off the books over time – Decay rates can be statistically measured – Once measured, decay rates can be used to forecast cash flows coming off pools of non-maturity deposits For all these reasons, your decay rates could be dramatically different than national averages. • Cash Flow Decay rates affected by: – Life events – death, divorce, population turnover – Satisfaction with the institution – Movements in market rates and your pricing strategy. – Economic events – local (plant closings), and national (911, stock market health, economic outlook, etc.) – Technology – Interaction between CSRs and customers – Flight to quality – Relationship between CD and NMD rates 53 © 2011 Farin & Associates, Inc © 2012 FARIN & Associates Inc. 53 Pricing Betas • The Goal • The Science – Predict the effect of movements in market rates on how you will price a core deposit account • The Art – Use a statistically valid set of historical data – Understand that this is a modeling tool and does not represent how the institution actually prices • Application – A/L Modeling – Pick/plot a representative set of market rates for dates studied – Plot your actual pricing on account you are evaluating for study dates – Regress lines against each other to find best fit varying • Lags • Betas – From best fit take off • • • • • Income at risk • Value at risk © 2012 FARIN & Associates Inc. Index (market rate) Lag Beta Spread 54 Pricing Betas • For example, if market rates increase 200 bp and your beta for MMDAs is 0.5 (50%) then the beta would predict you will raise MMDA rates by 100 bp 200 bp X 0.5 = 100 bp • Betas can be: – SWAG’d – Derived statistically from historic data – Examiners prefer the latter • Betas can also be modified by use of segmentation strategies. © 2011 Farin & Associates, Inc © 2012 FARIN & Associates Inc. 55 Pricing Betas a = 0.4% b = .75 Y = a + bx = Rate Paid 56 © 2012 FARIN & Associates Inc. 56 Pricing Betas Questions: 1. Which of these cost of funds profiles would you prefer to have with rising rates? 2. What would that information allow you to do with asset and funding allocation? 57 © 2012 FARIN & Associates Inc. 57 How Betas Play Out in Industry 1.0 0.2 0.9 Premium MMDA & CDs Regular Savings 58 © 2012 FARIN & Associates Inc. 58 Example Pricing Beta Study Passbook Savings • • • • • • Benchmark/beta/lag testing Equation to actual comparison Rates paid for I&P and gradual rate moves Tuning Premium MMDA example Strategy example © 2012 FARIN & Associates Inc. 59 Ranked by Correlation Treasuries, Agencies, FHLB Advances – 3, 6, 12, 24, 36, 60 months lagged 0-12 months = 234 combinations © 2012 FARIN & Associates Inc. 60 Rate Paid vs. Equation Passbook Savings © 2012 FARIN & Associates Inc. 61 Forecast Rates – I&P Shocks © 2012 FARIN & Associates Inc. 62 Cash Flow Decay Rates • • The Goal – Predict the cash flows coming off a pool of nonmaturity deposits • The Art – Use a statistically valid set of historical data – Pick a time frame covering at least ½ of a rate cycle • Application – A/L Modeling • Value at risk • Liquidity The Science – Pick a grouping of non-maturity deposit accounts at an appropriate level of aggregation – Plot runoffs that occurred to a set of accounts over the study period. – Separate normal from ‘abnormal runoff or growth’ – Calculate decay rate for normal runoff – Calculate decay rate for abnormal balances – Use decay rates to generate potential cash flows. – From best fit take off • • • • © 2012 FARIN & Associates Inc. Index (market rate) Lag Beta Spread 63 Decay Rate Methods • Account No Method • Origination Date Method – Begin with a set of accounts and balances – Track what happens to balances of these accounts over time – No new money considered – Weaknesses • Lots of data and account numbers needed • Over long horizons characteristics of accounts at beginning of study may be inconsistent with the accounts you have now 1. Total Balances BOM 2. Total Balances EOM 3. New Account EOM Balances 4. Old Account EOM Balances (#2-#3) 5. Chg in Old Balances (#1-#4) 6. Decay Rate (#5/#1 * 12) 12,000 12,200 400 11,800 200 20.00% – Weaknesses • Not recognized as industry standard – Strengths – Strengths – Recognized as industry standard technique. • Account numbers not needed • Over long horizons sample moves with changes in customer characteristics. Note: in most cases both methods will yield roughly the same results. © 2012 FARIN & Associates Inc. 64 But before we calculate decay rates, we need to deal with surges All US banks on UBPRCD Stock Surge – Fast Decay Core – Slow Decay Non-Maturity Deposits as a Percent of Assets Relative pricing of non-maturity deposits vs. CDs 65 © 2012 FARIN & Associates Inc. 65 Rolling Decays as Surge Indicators Decay rate on outstanding study balances Decay rate on outstanding study accounts Marginal (12 month rolling) decay rate © 2012 FARIN & Associates Inc. 66 After Surge Adjustment After surge adjustment (20% surge) the marginal decay rate tracks along the cumulative average decay rate. © 2012 FARIN & Associates Inc. 67 Average Balances Before and After Surge © 2012 FARIN & Associates Inc. 68 Non-Surge Decays © 2012 FARIN & Associates Inc. 69 Decay Rates Surge Balance Burnout Truncation Assumption: 20% of balances are surge balances © 2012 FARIN & Associates Inc. 70 Savings / Money Market Case • Savings – – – – • Money Markets Single tiered product No current tier differentials $34 million in balances Projected growth of 2% per year as long as rates remain low • Primarily funds flowing out of CDs – Generally priced in 33rd percentile – Some surge balances – – – – Single tiered product Limited tier differentials $90 million in balances Projected growth of 2% per year as long as rates remain low • Primarily funds flowing out of CDs – Generally priced in 25th-33rd percentile – Some surge balances © 2012 FARIN & Associates Inc. 71 Savings/MM Sector Audit Rate board Rates Download rates No significant evidence of exception pricing in this example. Note that on NMDs what happens with weighted rates over time is a better input into pricing beta calculations than offer rates, because many institutions utilize exception pricing. © 2012 FARIN & Associates Inc. 72 New Product - Defensive New product with $50K barrier to entry priced defensively – cut existing rates • Saves $13 thousand per year • Increases core deposit intangible by $28 thousand • Is it worth it? – most would answer “No” and keep their new product powder dry 73 © 2012 FARIN & Associates Inc. 73 New Product – Defensive (+200) 0.38 0.31 0.25 0.35 0.50 0.35 0.50 0.75 0.09 0.14 0.19 0.17 0.25 0.37 0.75 © 2012 FARIN & Associates Inc. 74 New Product – Defensive (+200) Wtd cost was 0.135% - Strategy 1 Beta is 0.37, Strategy 2 Beta is 0.305 Saves 13 bp, $65 thousand. Increases core intangible by $312 thousand © 2012 FARIN & Associates Inc. 75 New Product – Offensive (+200) Betas same as previous slides Intangible increases $456 thousand Beta – 1.0 Marginal cost of new funds, 2.096%, 200 bp below benchmark 76 © 2012 FARIN & Associates Inc. 76 New Product – Offensive (+200) Institution Decay Rates OTS Institution specific decays: Money Markets – 15% (OTS was 19.89%) Savings – 10% (OTS77was 15.44%) © 2011 Farin & Associates, Inc © 2012 FARIN & Associates Inc. 77 Impact – One Customer Higher EVEs under all rate environments and increased asset sensitivity due to: • Increased duration of NMDs (lower decay rates) • Higher spreads to benchmarks (higher average benchmark cost) This leads to an opportunity … © 2012 FARIN & Associates Inc. 78 Opportunities • Reduce reliance on LT CDs – High cost, will they be there? • Lengthen investment portfolio • Lengthen loan portfolio – Keep mortgages you’ve been selling – Offer commercial and agriculture customers a fixedrate option © 2012 FARIN & Associates Inc. 79 EFFECTIVE LOAN PRICING © 2012 FARIN & Associates Inc. 80 Pricing Cash Flows • When we price a loan – We are pricing a bundle of cash flows – A good loan pricing model puts an A/L wrapper around a loan or a bundle of loans being priced. Approach and results should be consistent with: • A/L model results • Profitability system results • Market results – Assuming loan is sold © 2012 FARIN & Associates Inc. 81 Loan Pricing – Interest Rate Risk • • Interest Rate Risk – When you are pricing loans you are pricing cash flows not maturities. – With fixed-rate loans, pieces reprice as cash flows come in. Few reprice at maturity. – Principal cash flows are often uncertain • Prepayment options – Variable rate loans reprice To manage interest rate risk, institutions need to match funding to the repricing of the loans of loans. Two approaches: – Simplistic – match based on duration complex – Match fund x– More individual repricing flows. – While in the real world you may not x match, in making pricing decision, we should assume matching. • When cash flow pieces come in • When contractual repricing occurs, but … • Variable rate loans may not respond immediately or completely at reset points • Reset frequency • Restrictions on adjustments (caps) X – Approach taken in this series © 2012 FARIN & Associates Inc. 82 Market Curve Usage CurveNo 1 5 6 9 10 14 16 20 21 29 37 40 66 84 87 90 91 95 98 99 100 119 126 127 128 134 137 138 CurveName US Treasury Prime Fed Funds Balloon MBS Libor FHLMC FR MBS UST Strip FNMA FR MBS GNMA FR MBS Interest Rate Swap Indexed AAA Corporate Bond AAA Auto Index 11th District COFI Average FHLB ADV Cost of Savings Index Indexed AAA MUNI Bond Indexed Agency Bond National COFI REPO (Overnight) Retail CD Avg US CMT (H.15) AAA Commercial Equipment Indexed A Corporate Bond Indexed B Corporate Bond Indexed A- MUNI Bond FR MBS Balloon MBS Synthetic GNMA II ARMS • Curves Used for – Risk Free Curves – Investment Benchmarks – Wholesale Funding Curves • Requirements – Broad range of benchmarks. – Updated very frequently © 2012 FARIN & Associates Inc. 83 Cash Flow Matching Example Fully Ammortizing 20 Year Comm. R/E Funding © 2012 FARIN & Associates Inc. Investments 84 Cash Flow Matching Example 5/20 Comm. R/E Balloon Funding © 2012 FARIN & Associates Inc. Investments 85 Comparison – Investment Benchmark Fully Amortizing 20 Yr FRM 5/20 Yr Balloon + 0.957 © 2012 FARIN & Associates Inc. 86 Credit Risk - Which History to Use? • Was history from 2005-2007 a legitimate predictor of recent credit losses? • Are 2008-2010 losses a legitimate predictor of losses of newly originated loans in 2011? • Do we even have legitimate loss history for loans originated today? – Changes in collateral coverage – Changes in underwriting standards – Changes in kinds of loans originated © 2012 FARIN & Associates Inc. 87 Comparison – Investment Benchmark Fully Amortizing 20 Yr FRM 5/20 Yr Balloon © 2012 FARIN & Associates Inc. 88 Loan Pricing – Servicing Arguments Servicing Cost – Marginal Origination Cost • Cost of originating the next loan – Marginal Servicing Cost • Cost of servicing the next loan – Direct Overhead Allocation • Fixed costs directly related to loan production – General Overhead Allocation • President’s salary, human resources, etc. – Economist – Continue to produce widgets until marginal revenue equals marginal cost – Accountant – Without overhead allocation, you end up with profitable loans and an unprofitable institution OTS Cost Assumptions – – – – – – – – 0.20% - FR Mortgages 0.38% - ARMs 0.20% - Multi & Non-Res 0.20% - Const & Land 0.20% - Second Mtg. 0.20% - Commercial 0.20% - Consumer 1.00% - Credit Card • Is there a better source for generic servicing costs © 2012 FARIN & Associates Inc. 89 Comparison – Investment Benchmark Fully Amortizing 20 Yr FRM 5/20 Yr Balloon - 0.034 © 2012 FARIN & Associates Inc. 90 Loan Pricing – The Basics Option Risk – Dealing with uncertain cash flows • We imbed options in loan contracts that allow customers to modify cash flow characteristics of loans when they consider it to their advantage to do so – Prepayments • Basic prepayment levels – death, divorce, transfer, upgrades, etc. • Incentive driven prepayments – Customer prepays to refinance at a lower rate – Customer can’t afford to move or upgrade because of interest rate jump – Up to the customer to execute the option – In some cases, subject to penalty – primarily commercial contracts – Adjustable rate mortgage caps • Annual caps, lifetime caps • Automatically executed by the institution • Loan floors • Ideally the institution is compensated with rate for making the option available. © 2012 FARIN & Associates Inc. 91 Option Risk – What Is It • 15 year FRM example showing remaining principal under different rate environments – Falling – 25% CPR – 2.75 year duration – Flat – 8% CPR – 4.64 Year duration – Rising – 5% CPR – 5.21 Year Duration 15 Year FRM Remaining Principal 120,000.00 100,000.00 80,000.00 5% CPR 8% CPR 60,000.00 25% CPR 40,000.00 20,000.00 1 14 27 40 53 66 79 92 105 118 131 144 157 170 Month © 2012 FARIN & Associates Inc. 92 Comparison – Investment Benchmark Fully Amortizing 20 Yr FRM 5/20 Yr Balloon + 0.925 © 2012 FARIN & Associates Inc. 93 Internal Profitability Measures (ROE) • How institutions make money – Loan Yield 6.0% – Funding Cost 2.0% – Spread 4.0% • Who owns the spread? – Loan Officer? – Funding Provider? – Treasury Function? © 2012 FARIN & Associates Inc. 94 Funds Transfer Pricing • • Internal profitability benchmark • Evaluates whether a loan is profitable within context of balance sheet • Most relevant when – – • You are trying to decide whether you can make money originating a loan Anytime you are trying to asses the profitability of a relationship, product or profit center – – – – – – – – – • Dollar contribution to profit (ROA) Return on required capital (RAROC) • Cash flow characteristics Cost Curve Pricing – Rates and fees Operating expenses Credit risk adjustment Additional option risk adjustments Capital Requirement (RAROC) Capital Goal (RAROC) Institution Tax Rate Calculated adjustments – – – – – Can focus on: – – Required inputs Pretax Spread ($ or %) After tax spread ($ or %) RAROC Spread to RAROC Goal Test – Is spread positive (good) or negative (bad)? Not considered – – – Risk free curve Investment benchmark curve Capital requirement © 2012 FARIN & Associates Inc. 95 Selecting a FTP Curve •Not Recommended - Your Cost of Funds Curve –Penalizes loan function for inefficient funds gathering, rewards for efficient funds gathering. Could force you to price out of the market. –Fails to reward and provide an incentive for funds providers to gather funds efficiently. –History based curve is used to price newly originated instruments. •Recommended - Your true wholesale funding alternative • • • • FHLB Advance Jumbo/Brokered/I-net CD AAA corporate Swap Curve –Use the one that comes closest to your true wholesale funding cost. –Credits deposit gathering functions for sub-wholesale deposits. Levels the playing field for lending functions. © 2012 FARIN & Associates Inc. 96 Transfer Pricing Components •Return on Equity (RAROC) for the transaction is calculated by: –Summing net interest income contribution from loan and investment –Adding fees and subtracting allocated operating expenses. –Net income is divided by capital required to calculate Return on Capital (ROE) •So FTP income can be measured with –Net Income (ROA) –RAROC 6% - Loan Spread – Loan 5% - FTP Curve Spread – Option Risk 4% - Spread – Rate Risk 3% Spread - Deposit 2% - Deposit 1 Yr 7 Yr Balance Rate FTP Rate Spread Net Int Inc Loan 100,000 6.00% 5.00% 1.00% 1,000 Deposit 80,000 2.00% 3.00% 1.00% 800 Total 1,800 Fees 500 Expenses 1,000 Net 1,300 Capital Requirement (8%) 8,000 ROE 16.25% © 2012 FARIN & Associates Inc. 97 Capital Allocation •Why assign a capital requirement to a loan? –Relates profitability of an entity (loan) to a primary earnings measurement ratio. –Allows for adjustments in return based on differential capital needs for different loans and investments. •What capital allocation model should I use? –Leverage Requirement •Core capital requirement •Internal capital goals –Risk Based Requirement •Should you bother with a capital allocation model? •Basel I •Basel II •Internal Model –Will adding this level of complexity have a material effect on analysis or decisions? –Is capital a constraint • • Regulatory requirements Self-imposed requirements © 2012 FARIN & Associates Inc. 98 RAROC (ROE) Calculation Fully Amortizing 20 Yr FRM 5/20 Yr Balloon Swap cost of funds Core hedges portion of option risk ROE is after tax Assigned capital requirement © 2012 FARIN & Associates Inc. 99 Price to Same ROE + 0.637% 1. Will the customer pay an additional 0.637% to lock his Comm. R/E loan rate for 20 years? 2. Will the availability of the product allow you to attract customers you might not otherwise get? © 2012 FARIN & Associates Inc. 100 Acme Commercial R/E Loan © 2012 FARIN & Associates Inc. 101 Acme Commercial R/E Loan Rate needed to hit ROE Goal Problem: No sale Options: • Rate • Points • Point buy down • Relationship © 2012 FARIN & Associates Inc. 102 Relationship – Add LOC Up from 10.5% © 2012 FARIN & Associates Inc. 103 Relationship – Add Bus Checking Up from 10.95% © 2012 FARIN & Associates Inc. 104 Relationship – Add Bus Checking Fees Up from 11.79% © 2012 FARIN & Associates Inc. 105 Origination Fee on Comm R/E Up from 12.04% © 2012 FARIN & Associates Inc. 106 Funding Fixed-Rate Mortgages • FHLB Advances • Deposits – Long-Term CDs • Recently Expensive • Will lag the market in rising rate environments • Uncovered Options – Relatively cheap now – Will lead deposit rates in rising rate environment – Can be purchased • With no imbedded options • With options granted to the FHLB (cheaper) • With imbedded options granted to the member (more expensive) – Non-Maturity Deposits • Cheap source of long-term funding especially when rates are up. • But do you bet the whole shop on the results of a core study? – Can raise exactly what you need, at a known rate, when you need it – Requires collateral • SWAPs, CAPs and other off balance-sheet instruments © 2012 FARIN & Associates Inc. 107 Option Risk – What Is It • 15 year FRM example showing remaining principal under different rate environments – Falling – 25% CPR – 2.75 year duration – Flat – 8% CPR – 4.64 Year duration – Rising – 5% CPR – 5.21 Year Duration 15 Year FRM Remaining Principal 120,000.00 100,000.00 80,000.00 5% CPR 8% CPR 60,000.00 25% CPR 40,000.00 20,000.00 1 14 27 40 53 66 79 92 105 118 131 144 157 170 Month © 2012 FARIN & Associates Inc. 108 Option Risk – Wholesale Institution • Funding 7.0% 6.0% Rate 5.0% – Raised in bond market 4.0% – If bullet funding is used to 3.0% 2.0% fund instruments with 1.0% significant option risk, 0.0% -4.0% -3.0% -2.0% -1.0% Flat 1.0% 2.0% 3.0% 4.0% institution can be damaged -1.0% Rate Environment Yield - Mortgages Cost - Bullet Funding however rates move Unhedged Spread Hedged Spread – Operate with relatively Unhedged - Zero or negative spreads in narrow spreads so option adverse rate environments risk has a material bottom Hedged – sacrifice spread to hedge option risk line effect Wholesale Institutions (Freddie, Fannie, FHLBs, etc.) must give up some of the spread in order to hedge this risk using tools like, Swaps, Caps, structured debt instruments (callable bonds), and the like. That means investment views of profitability must consider option risk. © 2012 FARIN & Associates Inc. 109 Option Risk – Retail Institution NMD Extension Risk Hedge - Segmentation – Mostly raised from consumers – Operate with wider spreads and are willing to live with moderate spread fluctuations – It can be argued that nonmaturity deposits inherently hedge some option risk. • But should I not make a loan when the option risk adjusted benchmark is above market rates if I elect to keep and have already hedged the option risk with non-maturity deposits? 7.0% 6.0% 5.0% Rate • Funding 4.0% 3.0% 2.0% 1.0% 0.0% -4.0% -3.0% -2.0% Yield - Mortgages -1.0% Flat 1.0% Rate Environment Cost - NMD 2.0% 3.0% 4.0% Spread Unhedged prepayment risk What this means is retail institutions with inherent NMD deposit option risk hedges may not need fully load option risk adjustments in profitability analysis. © 2012 FARIN & Associates Inc. 110 Blended Funding Using FHLB Advances • Concept – Use FHLB Advances to provide structural support under fixed-rate loans • Partially matched cash flows • Prepayment protection – Supplement FHLB Advances with non-maturity deposits to plug funding gap taking advantage of: • • • • Low cost Pricing betas affected by segmentation Decay rates Inherent extension risk hedge © 2012 FARIN & Associates Inc. 111 © 2012 FARIN & Associates Inc. 112 © 2012 FARIN & Associates Inc. 113 © 2012 FARIN & Associates Inc. 114 © 2012 FARIN & Associates Inc. 115 Mortgage Retention Case • Original interest rate risk analysis showed institution as fairly liability sensitive – Sell mortgages – Keep investments short – Reach out for long-term funding • Institution is interest rate risk neutral after funding strategy is in place • Also very liquid – (low yield investments) • Strategies – Base – No change in strategy – Mortgage 1 – Retain fixedrate mortgages – Mortgage 2 – hedge some of the risk in fixed rate mortgages with FHLB Advances • IAR Rate Environments – Global Insight © 2012 FARIN & Associates Inc. • Low • Base • High 109 Global Insight Base 65% probability Base GI rate environment used in reports and in income at risk calculations. Long term rates lift off gradually rising approximately 200 bp by end of 2014. Short-Term rates steady for two years then move up by 200 bp in year 3. © 2012 FARIN & Associates Inc. 110 Global Insight High Rates begin to move upward almost immediately, peaking 2 ½ years into forecast, before trending back down. Short-term rates and long-term rates up 500 bp. © 2012 FARIN & Associates Inc. 111 Global Insight Low 25% probability Low GI rate environment assumes a further rate drop then gradual lifting of long-term rates with a spike occurring near end of 3rd year. Short-Term rates flat for 2 ½ years. Then rising in last six months. © 2012 FARIN & Associates Inc. 112 Mortgage Strategy – IAR – 3 Yr - With Advances - W/O Advances (25%) (65%) (10%) Which strategy would you select? © 2012 FARIN & Associates Inc. 113 Mortgage Strategy - VAR With FHLB Advances W/O FHLB Advances Mortgage 1 Mortgage 2 © 2012 FARIN & Associates Inc. 114 ALCO Policy Limits Dynamic capital ratios projected from business plan or strategy Earnings Goals Dynamic income and economic value at risk limits from business plan or strategy Dynamic liquidity risk limits from business plan or strategy Dynamic credit limits from business plan or strategy © 2012 FARIN & Associates Inc. 115 ALCO Decision Tool Base – OTS Core Assumptions: • Capital is a bit below goals • Earnings are only 75% of goal • Income at risk and value at risk show significant liability sensitivity • Liquidity risk is minimal. • Credit risk is in in yellow range due to lingering asset quality problems Base 3 year business plan. OTS assumptions used for core funding. Most results are at the end of 3 years. Some average over 3 years. © 2012 FARIN & Associates Inc. 116 ALCO Decision Tool Base – Institution Specific Core Assumptions: • Capital still is a bit below goals • Earnings are 80% of goal • Income at risk and value at risk show moderate liability sensitivity • Liquidity risk is still minimal • Credit risk is still in in yellow range due to lingering asset quality problems Note: All we have done here is substitute institution specific core funding assumptions for OTS assumptions. © 2012 FARIN & Associates Inc. 117 ALCO Decision Tool Base – Institution Specific Core Assumptions, Deposit Segmentation • Capital is closer to goals • Earnings up to 90% of goal • Income at risk and value at risk is fairly neutral • Liquidity risk is still minimal • Credit risk is still in yellow range due to lingering asset quality problems Note: Major change from previous results is that we modeled the segmentation strategies we plan to implement as rates go up. © 2012 FARIN & Associates Inc. 118 ALCO Decision Tool Revised – Institution Specific Core Assumptions, Deposit Segmentation, Mortgage Strategy with FHLB Adv. • Capital is above goals • Earnings are at 100% of goal • Income at risk and value at risk show moderate liability sensitivity in business plan • Liquidity risk is up with one liquidity ratio going into yellow range and two others moving closer to yellow • Credit risk is still in in yellow range due to lingering asset quality problems Major change from previous example is that our interest rate risk position (moderate asset sensitivity) allows us to reach out the yield curve on asset side of balance sheet (loans and securities) to enhance yield, at a cost to liquidity. © 2012 FARIN & Associates Inc. 119 Questions? © 2012 FARIN & Associates Inc.