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updateFinancial ManagersA publication of <strong>the</strong> Financial Managers SocietySeptember 16, 20082Community institutions3Fair value confusion7Competitive strategyLiquidity risk managementHeightened scrutiny by examiners continuesLiquidity risk management isgetting heightened scrutiny fromexaminers, due to concerns over <strong>the</strong>impact of market volatility and afragile economy. The FDIC recentlyissued guidance warning financialinstitutions that <strong>the</strong>y must effectivelymeasure liquidity risks and havecontingency funding plans in placefor <strong>the</strong> current volatile environment.Examiners are evaluating <strong>the</strong>ability of institutions to maintainaccess to funds and to liquidateassets in a “reasonable and costefficientmanner.”The FDIC cautioned that manyinstitutions have underestimated <strong>the</strong>difficulty of obtaining or retainingfunding sources. O<strong>the</strong>r regulators,including <strong>the</strong> OCC, OTS, andNCUA, are also closely monitoringliquidity concerns.Brokered depositsIn its guidance, <strong>the</strong> FDICinstructed institutions to beparticularly wary of risks relatedto brokered deposits and high-ratedeposits. The guidance restricts<strong>the</strong> use of brokered deposits forFannie, Freddie rescueU.S. government seizes control to bolster GSEssome insured institutions, no doubtreacting to <strong>the</strong> high concentrationof brokered funds in recentbank failures.Mike Guglielmo, managingdirector, <strong>Darling</strong> <strong>Consulting</strong> <strong>Group</strong>,Newburyport, Mass., said that<strong>the</strong> portion of <strong>the</strong> FDIC’s policythat addresses brokered deposits,much of which has already beenin effect, is probably intended as astrong reminder to institutions thatare bordering on “less than wellcapitalized” levels.continued on page 5In a dramatic rescue move, <strong>the</strong> U.S.government at press time seizedcontrol of Fannie Mae and FreddieMac, <strong>the</strong> nation’s two giant mortgagefundingcompanies, in an effortto stabilize <strong>the</strong> deteriorating U.S.housing market.The two companies, whichtoge<strong>the</strong>r hold $5.4 trillion ofguaranteed mortgage-backedsecurities and debt outstanding,provide mortgage funding foraround three-quarters of new homemortgages in <strong>the</strong> nation.Treasury secretary HenryPaulson, Jr., who engineered <strong>the</strong>plan, announced that <strong>the</strong> twocompanies were being placed undera government conservatorship,giving control of managementto <strong>the</strong> Federal Housing FinanceAgency (FHFA), <strong>the</strong> regulator of<strong>the</strong> two GSEs.Such conservatorship is a statutoryprocess designed to stabilize <strong>the</strong>troubled entities with <strong>the</strong> objective ofreturning <strong>the</strong>m to normal businessoperations, officials explained.The rescue package representsa massive federal intervention andcould become one of <strong>the</strong> most costlyfinancial bailouts in U.S. history.A previous estimate by <strong>the</strong>Congressional Budget Officesuggested that a federal rescuecould cost taxpayers as much as$25 billion, while o<strong>the</strong>r observerssuggested that in a worse-casescenario, it could total $100 billion.“In <strong>the</strong> end, <strong>the</strong> ultimate costto <strong>the</strong> taxpayer will depend on <strong>the</strong>business results of <strong>the</strong> GSEs goingforward,” Paulson said. He notedthat prior to launching <strong>the</strong> plan,<strong>the</strong> Treasury consulted with Fedchairman Bernanke, in addition too<strong>the</strong>r key government players.continued on page 4


One man’s ruminationsCommunity institutions: <strong>the</strong> next generationSteve Williams, of CornerstoneAdvisors in Scottsdale, Arizona, isone of my favorite commentators onfinancial institutions…especiallycommunity institutions.He and o<strong>the</strong>rs at Cornerstonepublish a weekly e-mail newslettercalled “Gonzo Banker,” a “collectionof observations, ruminations,predictions and random thoughts.”If you’ve never seen it, I recommendyou go to <strong>the</strong>ir website and subscribe.It’s free, and <strong>the</strong> <strong>article</strong>s are alwaysinformative, slightly irreverent,usually provocative, and frequentlyhumorous.I found Steve’s August 29 <strong>article</strong>,“Community Banks: The NextGeneration,” especially interesting andwondered how our members mightreact. So, I’m hoping many of youwill take a look at it and share yourreactions with me. The <strong>article</strong> is in <strong>the</strong>Industry News Archive of our web siteunder September 2 (www.fmsinc.org).I’m at dyingst@fmsinc.org.Steve’s <strong>article</strong> is a follow-up to onehe published in June entitled “Surviving<strong>the</strong> Dark Ages of Banking”…also in ourArchive, under July 2. In that piece,he lamented <strong>the</strong> current state of <strong>the</strong>industry, and castigated us a bit forbeing asleep at <strong>the</strong> wheel. He does,however, offer some “rules to live by”to get through <strong>the</strong> trough, which arecertainly worth a look.Stale assumptionsIn this latest <strong>article</strong>, he claims thattraditional community banks, andto a certain extent credit unions, arefaced with an emerging identity crisis.He argues that our age-old strategicplaybook has gone stale…very stale.Steve views <strong>the</strong> traditionalcommunity bank business modeland strategic identity, built on datedassumptions, as crumbling and causing“tons of grief.” Those assumptions:•“We are at <strong>the</strong> center of ourtown’s business community”•“Our conservative local lendingknowledge allows us to maintainsuperior credit quality”•“We differentiate through ourpersonal service that <strong>the</strong> big guyscan’t match”•“We don’t compete on price sowe generate strong loan yields and lowfunding costs from our core deposits”•“We attract experienced talentwho don’t like <strong>the</strong> headaches at largebanks”•“We’re not efficient like <strong>the</strong> bigguys, but we watch expenses closely”•“We will build this baby upand <strong>the</strong>n flip it for a nice ‘three timesbook’ liquidity event”Steve debunks each of <strong>the</strong>seassumptions, and addresses why hebelieves each has to be discarded.His perspectives deserve your reviewand thought.New imperativesUnlike many pundits, however,who predict community institutionswill go extinct, he does not. Hebelieves that community bankingwill adapt, but not with same stalestrategic playbook.He posits that <strong>the</strong> next generationof community banks must be drivenby a new model, and offers severalimperatives that he views as majorcomponents of that model:•Deep industry knowledgeand niches—getting excitedabout supporting real businessesand finding niches and perhapsspecializing in certain industries•Loans and business services—<strong>the</strong> next generation players will haveto have a more balanced focus onloans, deposits and fee based services•Technology and process ‘in<strong>the</strong> cloud”—becoming more adept atvirtual banking...tapping into Webbasedsystems and processes providedby third parties that can match <strong>the</strong>capabilities of <strong>the</strong> big players•Industry collaboration to driveefficiency—collaborating more on howto deliver services and share resourceswith o<strong>the</strong>r community institutions…staying independent, but sharingcommon I.T. operations, delivery andrisk management resources•Training on steroids—with alikely shortage of experienced talent,significant credit, wealth management,payments, operations, and technologytraining will be a must•Strategic liquidity events—whenbuilding up and selling <strong>the</strong> nextwave of community banks, <strong>the</strong> bigmultiples are likely to go to <strong>the</strong> morecreative niche playersWilliams obviously believesgoing forward that <strong>the</strong> game will bemarkedly different, and only thosethat draft a new strategic identity andvision will prosper.Please, take a look at his twopieces and let me know yourreactions…are his ruminations oldnews? Are his criticisms unfair?Are his “imperatives” unrealistic?Unnecessary? Sophomoric? Let meknow and we’ll summarize yourreactions in a future <strong>article</strong>. FMUDick YingstPresident/CEOFinancial ManagersupdateFinancial Managers Update ispublished biweekly by Financial ManagersSociety, Inc. • 100 West Monroe, Suite 810,Chicago, IL 60603 • 312-578-1300 • info@fmsinc.orgEditor: Tom Lanningtoml@fmsinc.org, 312-630-3421The opinions and statements set forthherein are those of <strong>the</strong> individual sourcesand do not necessarily reflect <strong>the</strong>viewpoint of <strong>the</strong> Financial ManagersSociety or its individual members, andnei<strong>the</strong>r <strong>the</strong> Society nor its editors and staffassume responsibility for suchexpressions of opinion or statements.Copyright © 2008, Financial ManagersSociety, Inc. All rights reserved.2 • Financial Managers Update • September 16, 2008


Fair value confusionAuditor cites current FAS 157 implementation challengesThe application of fair value accountingprinciples under FAS 157 is currentlycausing some perplexing challenges andconfusion for community institutions,an auditing specialist warns.One development complicating <strong>the</strong>situation is that while recent accountingregulations have emphasized<strong>the</strong> importance of consistency inreporting, some audit firms seem to beinterpreting <strong>the</strong> rules more aggressivelythan o<strong>the</strong>rs.Dan Trigg, national financialinstitutions practice leader atMcGladrey & Pullen, LLP, Schaumburg,Ill., says that two key issues, affectingdifferent institutions in varyingdegrees, involve <strong>the</strong> interpretationand application of impairment oninvestment securities, and also <strong>the</strong>application of FAS 157 to collateralizeddebt obligations (CDOs).Impairment issuesThe larger issue, affecting a widernumber of institutions, involves <strong>the</strong>application of fair value accountingto o<strong>the</strong>r-than-temporary impairment(OTTI) on investment securities. Asignificant amount of confusion hasarisen over how such impairmentshould be calculated, Trigg said.“OTTI is <strong>the</strong> big deal right now,”Trigg said. “It seems that several of<strong>the</strong> accounting firms are taking ahard stand (regarding OTTI) on <strong>the</strong>perpetual preferred (stock) issued by<strong>the</strong> GSEs—Fannie and Freddie.”The values of <strong>the</strong> GSE preferredstock have been down for some time,he said. “The question on perpetualpreferred stock is: to determine OTTI,when will that stock value come back towhat <strong>the</strong> original cost was?”Significantly, many institutionsare wrestling with <strong>the</strong> issue, whichis addressed in FASB Staff PositionNo. 115-1, he said. “Here’s my point:OTTI is a fact-and-circumstancedrivenjudgment area—<strong>the</strong>reare no bright lines out <strong>the</strong>re fordetermining yes or no.”Thus, an institution must makea judgment, and auditors ought tounderstand what that process is, he said.“Objective documentationis absolutely critical,” he added.“Institutions need to have a process inplace and document <strong>the</strong>ir position as towhy OTTI should be recognized or not.”However, frequently institutionsaren’t looking to take losses as OTTIcharges, because <strong>the</strong>y firmly believe<strong>the</strong> market will come back, he said.“What <strong>the</strong>y’re not thinking about is<strong>the</strong> duration period, and whe<strong>the</strong>rsome of <strong>the</strong>ir actual principal valuehas been impaired.”The larger issue,affecting a widernumber of institutions,involves <strong>the</strong>application of fairvalue accounting too<strong>the</strong>r-than-temporaryimpairment oninvestment securities.Dan Trigg, National FinancialInstitutions Practice LeaderMcGladrey & Pullen, LLPSchaumburg, Ill.But audit firms may see thingsdifferently.“I know of at least one Big Fourfirm that basically drew a bright linein <strong>the</strong> sand and said, if your value hasdropped 35% and has been outstandingin a loss position more than six months,you have OTTI,” he said. “Well, thatdoesn’t seem to fit <strong>the</strong> spirit of GAAPaccounting, in my mind.”A second major accountingchallenge involves figuring <strong>the</strong> fairvalue of CDOs whose underlying assetsare trust-preferred securities issued bymid-tier banks that are still performing,Trigg said. “That is very inconsistentacross <strong>the</strong> accounting firms, veryinconsistent across <strong>the</strong> banking arena.”Significantly, a number ofcommunity institutions with weakloan demand have gotten involvedwith CDOs in pursuit of increasedyields, and more communityinstitutions are involved with CDOsthan generally believed, Trigg said.“That surprised me.”He said he knows of at least fivecommunity institutions with assets of$600 million to $1.1 billion that havesuch CDOs in <strong>the</strong>ir portfolios.“They made an investmentdecision that <strong>the</strong>se CDOs had anincreased yield that could improve <strong>the</strong>investment portfolio,” he explained.“And when <strong>the</strong>y looked at <strong>the</strong>underlying assets and saw that <strong>the</strong>ywere trust-preferred securities by wellrun,mid-market banks, <strong>the</strong>y decidedto take that risk.”Cash flowsIn <strong>the</strong>se particular instances, both<strong>the</strong> CDO cash flows and interest ratesare performing well, he said. “Thecash flows of those CDOs indicatethat <strong>the</strong>re are no impairment issues.”But here’s <strong>the</strong> problem. Themarket value, if you apply FAS 157,gives a different answer than if youapply EITF 99-20. Thus, bankers arebasically saying: “auditors are makingme take write-downs, but I think Ihave a basis to say that I don’t have awrite-down,” Trigg said.Unfortunately, although <strong>the</strong>CDOs in question appear to be inreasonably decent shape and areperforming well, <strong>the</strong> institutionsholding <strong>the</strong>m must face <strong>the</strong> reality of <strong>the</strong>current marketplace—<strong>the</strong>y are gettingsignificantly less on <strong>the</strong> dollar than onemight think, and less than desired.Trigg explained that FAS 157basically says you must use a principalmarket convention, and this hasunfortunate consequences for <strong>the</strong>current market.“Everybody has a self-fulfillingprophecy that says—hey, if <strong>the</strong>principal market and market valuesays you have 60 cents on <strong>the</strong> dollar,<strong>the</strong>n that’s what you write down to,”he said. FMUFinancial Managers Update • September 16, 2008 • 3


Fannie, Freddie rescue from page 1As part of <strong>the</strong> wide-ranging rescueplan:•The two GSEs have been placedinto conservatorship.•New CEOs, supported by nonexecutivechairmen, have taken overmanagement of <strong>the</strong> entities.•Treasury and <strong>the</strong> FHFA haveestablished contractual preferred stockpurchase agreements between <strong>the</strong>Treasury and <strong>the</strong> conserved GSEs.•Treasury is establishing a newsecured lending credit facility that willbe available to Fannie, Freddie and <strong>the</strong>Federal Home Loan Banks, serving asan “ultimate liquidity backstop.”•Treasury is initiating atemporary program to purchase GSEmortgage-backed securities to fur<strong>the</strong>rsupport <strong>the</strong> current availability ofmortgage financing.Systemic riskPaulson said that <strong>the</strong> programbeing undertaken is <strong>the</strong> best meansof protecting financial markets andtaxpayers from systemic risk posed by<strong>the</strong> current financial condition of <strong>the</strong>GSEs. He emphasized that <strong>the</strong> bailoutis absolutely necessary.“Fannie Mae and Freddie Mac areso large and so interwoven in ourfinancial system that a failure of ei<strong>the</strong>rof <strong>the</strong>m would cause great turmoil inour financial markets here at homeand around <strong>the</strong> globe,” he said.He explained that <strong>the</strong> continuinghousing crisis also poses <strong>the</strong> biggestcurrent risk to <strong>the</strong> U.S. economy. “Oureconomy and our markets will notrecover until <strong>the</strong> bulk of this housingcorrection is behind us,” he said.Now that <strong>the</strong> bailout is underway,<strong>the</strong> primary mission of Fannie andFreddie will be to proactively work toincrease <strong>the</strong> availability of mortgagefinance, which includes examining<strong>the</strong> guaranty fee structure with aneye toward mortgage affordability,he said. “Because <strong>the</strong> GSEs arein conservatorship, <strong>the</strong>y will nolonger be managed with a strategyto maximize common shareholderreturns, a strategy which historicallyencouraged risk-taking.”Significantly, however, Paulson notedthat <strong>the</strong> conservatorship status doesnot eliminate <strong>the</strong> outstanding preferredstock held by financial institutions—it places preferred shareholders insecond position, after <strong>the</strong> common stockshareholders, in absorbing losses.In responding to <strong>the</strong> bailout, <strong>the</strong> Fed,FDIC, OCC and OTS said jointly that<strong>the</strong>y have been assessing <strong>the</strong> commonand preferred stock exposures ofbanks and thrifts to Fannie and Freddie.“The agencies believe that, while manyinstitutions hold common or preferredshares of <strong>the</strong>se two GSEs, only a limitednumber of smaller institutions haveholdings that are significant comparedto <strong>the</strong>ir capital,” <strong>the</strong>y said.“Our economyand our markets willnot recover until<strong>the</strong> bulk of thishousing correctionis behind us.”Henry Paulson, Jr., Treasury SecretaryTreasury DepartmentWashington, D.C.Depository institutions areencouraged to contact <strong>the</strong>ir primaryfederal regulator, if <strong>the</strong>y believe losseson holdings of Fannie or Freddiecommon or preferred shares—whe<strong>the</strong>rrealized or unrealized—are likely toreduce <strong>the</strong>ir regulatory capital below <strong>the</strong>“well-capitalized” level, Paulson said.The banking regulatory agenciessaid <strong>the</strong>y are prepared to work with<strong>the</strong>se institutions to develop capitalrestorationplans pursuant to regulationsconcerning capital and promptcorrective action. “All institutions arereminded that investments in preferredstock and common stock with readilydeterminable fair value should bereported as available-for-sale equitysecurity holdings, and that any netunrealized losses on <strong>the</strong>se securities arededucted from regulatory capital,” <strong>the</strong>regulators said.Significantly, <strong>the</strong> impact of <strong>the</strong>GSEs’ bailout could affect communityinstitutions around <strong>the</strong> U.S. in bothdirect and indirect ways. Just days before<strong>the</strong> Treasury launched its rescue steps,a prominent industry strategist offeredperspective on various possible impacts.“Fannie and Freddie are absolutelymission-critical to mortgage homeownership in America,” said RoyHingston, portfolio strategist, ShayFinancial, Miami, Fla. “They cannot beallowed to fail—that is not a question.”Hingston said (prior to <strong>the</strong>bailout) that many Americans and alot of international people have beenconcerned about <strong>the</strong> strength of <strong>the</strong> U.S.banking industry in general, includingsome of <strong>the</strong> largest and most wellknown institutions—not just Fannieand Freddie. He cited Citibank, BearStearns, and Merrill Lynch as examples.Common stockHe also pointed out that communityinstitutions which invested heavily incommon stock of <strong>the</strong> GSEs must face<strong>the</strong> dilemma that <strong>the</strong> stock has fallen toabout $3 or $4 from about $50 to $60.“It’s been devastating,” he said. “It’snot enough of an investment that itwould bring down <strong>the</strong> institution ifFannie or Freddie stock failed—nobodyis over-invested in Fannie or Freddie.”But <strong>the</strong>re have been some people whohad big common stock investments inFannie and Freddie that have watched<strong>the</strong>m erode, he said.However, <strong>the</strong> challenges involvingcommunity institutions with GSEpreferred stock are different. Hingstonestimated that more than half hisclients have exposure to ei<strong>the</strong>r Fannieor Freddie preferred. “And those(stocks) have fallen precipitously(before <strong>the</strong> bailout), because while <strong>the</strong>yare preferred stock, <strong>the</strong>y are not thatmuch above common in <strong>the</strong> liquidationsituation,” he said.He pointed out, for example, thatsince Fannie’s preferred stock came out at$25 per share, it dropped as low as $10,before recovering slightly. “The problem,”he said, “is that’s like a 50% decline—which leads to <strong>the</strong> question that <strong>the</strong>accountants want to ask: is it impaired?”And <strong>the</strong> price for <strong>the</strong> preferred stock(prior to <strong>the</strong> bailout), trading at about 50cents on <strong>the</strong> dollar, was saying that <strong>the</strong>market was ambivalent as to whe<strong>the</strong>r <strong>the</strong>stock may or may not be safe, he said.“They know it will ei<strong>the</strong>r go to zero, orcontinued on page 74 • Financial Managers Update • September 16, 2008


Liquidity risk management from page 1“It’s not <strong>the</strong> brokered depositsthat put <strong>the</strong> banks under—it’s what<strong>the</strong>y’re supporting with <strong>the</strong> brokereddeposits,” Guglielmo explained.He noted that in some respects <strong>the</strong>FDIC’s regulatory enforcement hasrecently toughened, however. Over <strong>the</strong>past year, <strong>the</strong> FDIC appears to havetightened its stance based upon <strong>the</strong>significant amount of denied requestsfor waivers.Guglielmo said that in previousyears, if an institution dropped below<strong>the</strong> “well-capitalized” threshold andrequested a waiver, this would oftenbe granted provided <strong>the</strong> institutionhad a well defined plan and process inplace. However, on a percentage basis,<strong>the</strong> number of approved waivers thisyear is significantly less than in yearspast, indicating ei<strong>the</strong>r a tougheningstance on enforcement, or perhaps <strong>the</strong>failure of institutions to articulate aneffective funding plan.Liquidity pool“Look, <strong>the</strong> game’s different—<strong>the</strong>ability to access funds easily throughvarious alternatives has changed,” hesaid. “The whole liquidity pool hasshrunk, due to tightening standardsand supply-demand factors.”The overall liquidity situationhas become more serious over <strong>the</strong>past year, due to <strong>the</strong> credit crunchweighing down on institutions, headded. “Credit is clearly <strong>the</strong> numberonefocus of examiners—but a closesecond cousin is liquidity.”He explained that large industryplayers are now hoarding liquidity,thus putting pressure on pricesand also on <strong>the</strong> smaller institutionsin terms of <strong>the</strong> liquidity avenuesavailable to <strong>the</strong>m.“You’ve got a number of <strong>the</strong> bigplayers who are also concerned about<strong>the</strong> stability of <strong>the</strong>ir funding sourcesand <strong>the</strong> safety of <strong>the</strong>ir principal—rightnow, cash is king,” Guglielmo said.Many institutions also are beingchallenged by Federal Home LoanBanks, as some have been tighteningstandards, increasing haircuts, andwidening spreads. While much of <strong>the</strong>trend involving tightened liquidityis due to <strong>the</strong> big players’ issues, itgenerally is affecting everyone, he said.“They (FHLBs) want to ensure<strong>the</strong>y are managing in a safe and soundfashion as well, and are <strong>the</strong>refore beingcautious to make sure <strong>the</strong>y are lendingto stronger banks and that banks canafford <strong>the</strong> borrowings,” he said.Also, due to <strong>the</strong> current housingcrisis in <strong>the</strong> U.S., market valuesof some underlying securities thatbanks were using as collateral with<strong>the</strong> FHLBs have declined, causing insome cases margin calls and reducedborrowing limits, he explained.“The key issue isto make sure youunderstand yourliquidity needs,your liquidity sources,and how <strong>the</strong>y canbe affected byvarious factors.”Mike Guglielmo, Managing Director<strong>Darling</strong> <strong>Consulting</strong> <strong>Group</strong>Newburyport, Mass.To be sure, regulators havepointed out that <strong>the</strong> challenge ofmanaging liquidity risks has becomeincreasingly complex for communityinstitutions in recent years, due tosignificant changes in <strong>the</strong> capitalmarkets, consumer behaviors, andinternational market factors.Most banks, thrifts and creditunions regularly use wholesalefunding sources and off-balance sheetsources of liquidity, and nearly allhave had to adjust to a decline in coredeposit growth.Significantly, in its guidance, <strong>the</strong>FDIC also placed some restrictionson high-rate deposits. Institutionsthat are “less than well capitalized”are precluded from offering depositinterest rates that are significantlyhigher than <strong>the</strong> prevailing rates in aninstitution’s normal market area or <strong>the</strong>national rate.Institutions that use volatile, creditsensitive, or concentrated fundingsources are generally expected to holdcapital above regulatory minimumlevels to compensate for <strong>the</strong> elevatedlevels of liquidity risk present in <strong>the</strong>iroperations, <strong>the</strong> FDIC said.Individuals responsible for managingan institution’s liquidity should befamiliar with all aspects of suchrestrictions and limitations set forth inFDIC regulations, <strong>the</strong> agency said.Fur<strong>the</strong>r, <strong>the</strong> guidance said thatinstitutions must have contingencyfunding plans that outline practicaland realistic funding alternativeswhich can be implemented as accessto funding is reduced. The plans mustinclude provisions for diversification offunding and capital-raising initiatives,and incorporate events that couldrapidly affect an institution’s liquidity.It pointed out that funding decisionscan be influenced by unplanned events,such as: <strong>the</strong> inability to fund assetgrowth; difficulty renewing or replacingfunding as it matures; <strong>the</strong> exerciseof options by customers to withdrawdeposits or to draw down lines of credit;legal or operational risks; <strong>the</strong> demise ofa business line; and market disruptions.“The key issue is to make sureyou understand your liquidity needs,your liquidity sources, and how <strong>the</strong>ycan be affected by various factors,”Guglielmo said.Ensuring effectivenessHe said it’s prudent for institutionsto evaluate <strong>the</strong> effectiveness of <strong>the</strong>irliquidity risk management process.The ALCO should ensure that it hasadequately determined:•The amount of operational,reserve, and contingency liquidity thatis available•The accessibility of that liquidityand its relative cost•The change in <strong>the</strong> need forliquidity and cash availability, in<strong>the</strong> event that economic or marketconditions change•The type of crisis or events thatcould affect operational needs•Actions that would be takenduring a liquidity crisis, and whe<strong>the</strong>r<strong>the</strong>re is a sufficient early-warning system•The adequacy of currentcontrols and processes to ensurecontinued on page 7Financial Managers Update • September 16, 2008 • 5


✓ Regulatory and Accounting ChecklistThese proposals may be accessed through <strong>the</strong> FMS Web site at www.fmsinc.org. Go to <strong>the</strong> Members Only section and follow<strong>the</strong> Regulations/Proposals link for direct access to <strong>the</strong> following documents.Reducing Complexity in ReportingFinancial InstrumentsComments due: Sept. 19, 2008Prompt Corrective ActionComments due: Sept. 29, 2008IASB: The International Accounting Standards Board recently issued a discussionpaper on reducing complexity in reporting financial instruments. The paper isdesigned to ga<strong>the</strong>r information to assist accounting policy-makers in deciding howto proceed in developing new standards that are principle-based and less complexthan today’s requirements.NCUA: The NCUA has proposed a rule implementing a statutory amendment to<strong>the</strong> definition of “net worth” concerning how it applies solely to NCUA’s system ofregulatory capital standards, known as “prompt corrective action.”Basel II, Standardized ApproachComments due: Oct. 27, 2008FDIC/Fed/OCC/OTS: The banking agencies issued an interagency proposal for astandardized framework under Basel II that would be an option for <strong>the</strong> majorityof institutions. The proposal takes a risk-based approach and includes more riskbuckets, but it also requires a capital charge for operational risk.Earnings per ShareComments due: Dec. 5, 2008FASB: The FASB issued a revised exposure draft proposal, Earnings per Share,which would amend FAS 128. The proposed statement seeks to improve financialreporting by clarifying and simplifying <strong>the</strong> method of calculating earnings pershare, while promoting international convergence of accounting standards.Truth in LendingFinal rule. No comments necessaryFed: The Fed issued a final rule amending Regulation Z, which implements <strong>the</strong> Truthin Lending Act and Home Ownership and Equity Protection Act. The changes aredesigned to protect consumers from unfair or deceptive lending, and to provide <strong>the</strong>mwith transaction-specific disclosures, among o<strong>the</strong>r things.Home Mortgage DisclosureComments closed: Aug. 29, 2008Fed: The Fed proposes to amend Regulation C, Home Mortgage Disclosure,in order to revise <strong>the</strong> rules for reporting price information on higher-priced loans.The definition for higher-priced loans would conform to <strong>the</strong> Truth in Lending rule.Member Business LoansComments closed: Aug. 25, 2008NCUA: The NCUA has issued an advance proposal of proposed rulemakingconcerning member business loans. It is considering revising provisions relatedto loan-to-value ratio requirements, collateral and security requirements,and o<strong>the</strong>r issues.Risk-based Pricing NoticesComments closed: Aug. 18, 2008Fed/FTC: The Federal Reserve and FTC proposed rules that would implement<strong>the</strong> risk-based pricing provisions in section 311 of <strong>the</strong> Fair and Accurate CreditTransactions Act of 2003. Under <strong>the</strong> proposal, a creditor would be required toprovide a risk-based pricing notice to a consumer who has been given materiallyless favorable credit terms, based on a credit report.Underserved AreasComments closed: Aug. 18, 2008NCUA: The NCUA issued a proposal to change <strong>the</strong> existing process of approvingmultiple group credit unions’ service to underserved areas under <strong>the</strong> Chartering andField of Membership Manual for federal credit unionsDisclosure of Loss ContingenciesComments closed: Aug. 8, 2008FASB: The FASB issued an exposure draft proposal concerning disclosure of certainloss contingencies, which amends FAS 5, Accounting for Contingencies, and FAS141-R, Business Combinations. The disclosures required by <strong>the</strong> proposal would beeffective for annual financial statements for fiscal years ending after Dec. 15, 2008.6 • Financial Managers Update • September 16, 2008


Liquidity risk management from page 5that action plans are successfullyimplemented.Guglielmo said that manycommunity institutions are unpreparedfor closely adhering to <strong>the</strong> FDIC’sliquidity risk management guidelines.“A lot of banks don’t have <strong>the</strong>sufficient diversification of fundingsources,” he said. “Right now, I think<strong>the</strong>y’re kind of waking up with ahangover.”Such institutions may have reliedtraditionally on one or two alternativesfor obtaining liquidity. For example,some community institutions don’tutilize <strong>the</strong> repo market or Federal HomeLoan Bank advances for funding, heit will go back to $25—but <strong>the</strong>y don’tknow which.”“Banking is a business ofconfidence—people have to beconfident that <strong>the</strong>ir money is safe, or<strong>the</strong>y’ll move it,” he said.Paulson said that in comingmonths <strong>the</strong> two GSEs will modestlyincrease <strong>the</strong>ir MBS portfolios through<strong>the</strong> end of 2009 in order to promotestability in <strong>the</strong> secondary mortgagemarket and lower <strong>the</strong> cost of funding.said. “So as a result, <strong>the</strong>y are not aswell equipped as o<strong>the</strong>rs who have morediversified funding sources.”“There are a number of institutionsthat really don’t know how muchliquidity <strong>the</strong>y have available to<strong>the</strong>m—so a lot of <strong>the</strong>m don’t realize<strong>the</strong>y have a problem until late in <strong>the</strong>game,” he added.He suggested six steps thatinstitutions should take to streng<strong>the</strong>n<strong>the</strong> liquidity risk-management process:determine how much liquidityyou have; estimate how much youneed; establish an early warningsystem; stress-test funding needs andavailability; outline management’sFannie, Freddie rescue from page 4Then, in 2010, <strong>the</strong>ir portfolios willbegin to be reduced gradually at <strong>the</strong>rate of 10% per year, largely throughnatural run-off, as a way to address<strong>the</strong> problem of systemic risk.Looking to <strong>the</strong> future, he saidthat since <strong>the</strong> GSEs are chartered byCongress, only that body can addresscertain issues. “The new Congressand <strong>the</strong> next administration mustdecide what role governmentin general, and <strong>the</strong>se entities inCompetitive strategyShifting to organic growth from branch expansionresponse for liquidity events; anddocument your process and periodicallytest liquidity sources.“Surprisingly, a lot of communityinstitutions have not thought throughthis exercise,” he said.Also, institutions must recognizethat when <strong>the</strong>y need liquidity <strong>the</strong> mostis precisely <strong>the</strong> time when it’s mostdifficult to obtain. So it’s imperativeto develop an effective liquiditycontingency crisis plan.“A lot of banks are under-prepared,”Guglielmo said.Interested FMS members mayreview <strong>the</strong> guidance on liquidity riskmanagement in <strong>the</strong> FDIC section of <strong>the</strong>News Archive on <strong>the</strong> FMS Web site atwww.fmsinc.org. FMUparticular, should play in <strong>the</strong> housingmarket,” he said.There is a consensus today that<strong>the</strong> GSEs pose a systemic risk, and<strong>the</strong>y cannot continue in <strong>the</strong>ir currentform, he said. “Government supportneeds to be ei<strong>the</strong>r explicit or nonexistent,and structured to resolve<strong>the</strong> conflict between public andprivate purposes.”Interested FMS members mayreview details on <strong>the</strong> bailout packagein <strong>the</strong> banking industry trends/issuessection of <strong>the</strong> News Archive on <strong>the</strong>FMS Web site at www.fmsinc.org. FMUA recent FMS White Paperexplains how community banks,thrifts and credit unions cansuccessfully integrate and executean organic growth strategy, whichcan help shore up <strong>the</strong> institution’sposition, supporting long-termviability and sustained growth.The paper, “Strategy for today’scompetitive marketplace,” pointsout that merger and acquisitionactivity within <strong>the</strong> financial servicesindustry has slowed to a crawl in2008. Despite this trend, manybanking executives often make<strong>the</strong> mistake of seeing mergers,acquisitions or de novo branchingas <strong>the</strong> most probable means to grow<strong>the</strong>ir businesses.Fortunately, however, currentmarketplace realities also haveprompted o<strong>the</strong>r institutions to takea different approach by shifting<strong>the</strong>ir attention to organic growthopportunities. “As margins aresqueezed and spending is morecarefully regulated, organic growthhas become <strong>the</strong> most viable option forthose who simply cannot afford a costlyexpansionary strategy,” <strong>the</strong> paper says.The report, authored by BradyWalen, director of marketing, MarketInsights, Chicago, Ill., explains thatbefore an institution can hope todeepen relationships with currentcustomers and build loyalty, it mustfirst thoroughly understand itscurrent customer base.Collecting and using customerdata thus becomes a critical elementto understanding customers,deepening relationships andincreasing share of wallet. The goalis to identify trends among <strong>the</strong> mostattractive or profitable segments.“Effective organic growthstrategies require this level of deepunderstanding, as each customerdoes not present <strong>the</strong> same level ofopportunity,” <strong>the</strong> paper says.Interested FMS members mayreview <strong>the</strong> White Paper by accessing<strong>the</strong> Members Only section of <strong>the</strong>FMS Web site at www.fmsinc.org. Or, members may call AlethaGalloway at 312-578-1300 to requesta copy. FMUFinancial Managers Update • September 16, 2008 • 7


100 West Monroe Street, Suite 810Chicago, Illinois 60603Return Service RequestedFirst Class MailU.S. PostagePAIDElgin, ILPermit No. 9FMS CalendarWebinarsSept. 25Oct. 7Oct. 8Oct. 9Oct. 20Oct. 22WorkshopsSan Antonio, TXOct. 20-21Oct. 22-23Atlanta, GANov. 17-18Nov. 19-20Boston, MADec. 8-9Dec. 9-10Dec. 10-11Pricing Loans & Deposits for GrowthHow to Apply Investment Basicsin <strong>the</strong> Current Crisis MarketCommercial Real Estate (CRE) Stress TestingInternal Fraud and Embezzlement:Lessons from <strong>the</strong> TrenchesLoan ImpairmentCommercial Mortgage Backed Securities:An Emerging Asset Class forCommunity BanksBest Practices in SOX & FDICIAThe CFO ExchangeLeveraging Your ALM Modeling ProcessRisk/Return Management BasicsThe Building Blocks of ALM for Credit UnionsSEC Reporting & UpdateStrategies for Growing Core DepositsFor more information, visit www.fmsinc.org/education.WebinarCommercial MortgageBacked Securities:An Emerging AssetClass for Community BanksOctober 22, 20082:00 p.m. EDT, 1:00 p.m. CDT,12:00 p.m. MDT, 11:00 a.m. PDTDespite <strong>the</strong> recent turmoil in <strong>the</strong> credit markets,<strong>the</strong> outlook for commercial mortgage backedsecurities (CMBS) is still positive.As with any security, <strong>the</strong>re are risks and rewardsto weigh and community banks have only recentlybegun to consider AAA-rated CMBS classes due to<strong>the</strong> yield and convexity advantages this asset classoffers. This convenient webinar will help you:n Examine <strong>the</strong> history of <strong>the</strong> CMBS market from astructural and credit perspectiven Discuss both <strong>the</strong> risks and rewards of CMBSn Walk through evaluations of specific CMBSbonds to determine how CMBS can help manage<strong>the</strong> portfolio duration and convexityVisit www.fmsinc.org/webinars for moreinformation and to register.

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