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What is this Project’s Objective?
This project is designed to improve your ability to analyze a
particular bank's performance. The
emphasis should be to explore your bank from a regulator’s
point of view. In that respect you
should address the six CAMELS components and try to identify
any "red flags" that could indicate
potential problems in your bank. The Excel file under the name
of “Bank Financial Analysis”
should be used to capture the financial data for your bank and to
show the associated financial
ratios. You should be able to find all your data in your bank’s
Uniform Bank Performance Report
(UBPR) which is available at www.ffiec.gov. Your written
report should be no less than 5 pages
long (typed, double-spaced) not including the Excel worksheet.
The six CAMELS components
are: Capital adequacy; Asset quality; Management quality;
Earnings record; Liquidity position;
and Sensitivity to market risk. Following is a more detailed
listing of the items that you need to
address:
A. Liquidity
Consider your bank’s Uniform Bank Performance Report
(UBPR) and provide an overview of your
bank’s liquidity by reviewing the following areas:
1. Liquidity and Funding Ratios especially the Net Non-Core
Funding Dependence
and Loan to Assets Ratios – The first ratio measures the degree
to which the bank is
funding longer-term assets (loans, securities that mature in more
than one year, etc.) with
non-core funding. Non-core funding includes funding that can
be very sensitive to
changes in interest rates such as brokered deposits, CDs greater
than $100,000, and
borrowed money. Higher ratios reflect a reliance on funding
sources that may not be
available in times of financial stress or adverse changes in
market conditions. What are
the trends in these ratios? How do they compare to the peer?
2. The availability of liquid assets readily convertible to cash
without undue loss-
Consider Federal funds sold, available for sale securities, loans
for sale, etc.
3. Core deposit/asset growth - Are core deposits capable of
funding anticipated asset
growth?
4. Diversification of funding sources - A bank with strong
liquidity has a strong core
deposit base, established borrowings lines, and procedures in
place for acquiring
internet-based or other forms of emergency borrowing.
5. External Forces - Economic conditions, competition,
marketing efforts, etc. have a
material impact on the need for liquidity going forward.
You should also take a look at your textbook’s continuing case
assignment for chapter 11 which
discusses various bank liquidity indicators.
B. Sensitivity to Market Risk
Sensitivity to Market Risk - refers to the risk that changes in
market conditions could adversely
impact earnings and/or capital. Market Risk encompasses
exposures associated with changes in
interest rates, foreign exchange rates, commodity prices, equity
prices, etc. While all of these
items are important, the primary risk in most banks is interest
rate risk (IRR). In the most
simplistic terms, interest rate risk is a balancing act. Banks are
trying to balance the quantity of
http://www.ffiec.gov/�
repricing assets with the quantity of repricing liabilities. For
example, when a bank has more
liabilities repricing in a rising rate environment than assets
repricing, the net interest margin (NIM)
shrinks. Conversely, if your bank is asset sensitive in a rising
interest rate environment, your NIM
will improve because you have more assets repricing at higher
rates.
Use your textbook’s continuing case assignment for chapter 7
and discuss sensitivity to market
risk for your institution.
In this section look for red flags such as a substantial change in
the NIM - Look for substantial
decreases or increases in the NIM. Changes in both directions
could indicate that the bank is
taking on more IRR than expected. Keep in mind, however, that
significant changes in the NIM
are not necessarily related to IRR. Changes in the balance sheet
such as changing the
percentage of earning assets, changing the risk profile, or
changing the quantity of non-interest
bearing funds can all affect the NIM.
It should be noted that there are many ways to monitor exposure
to IRR. Measurement systems
vary in complexity from very simple methods such as a gap
model, to very sophisticated models
such as a simulation or duration analysis. A simple gap model is
presented below to show the
exposure that we are trying to measure.
Repricing Time Frame
Account Balance 0-12
months
1-5 years >5 years
Cash 13,000
Investments 26,000 10,000 12,000 4,000
Loans 170,000 94,000 68,000 8,000
Federal funds 1,200 1,200 0 0
Premises 2,000 0 0 0
Other Assets 5,000 0 0 0
Totals 217,200 105,200 80,000 12,000
Deposits 160,000 132,000 28,000 0
Borrowings 35,000 20,000 15,000 0
Other Liabilities 4,000 0 0 0
Totals 199,000 152,000 43,000 0
Gap (RSA-RSL) (46,800) 37,000 12,000
Cumulative Gap (46,800) (9,800) 2,200
Gap Ratio (Gap/Earning
Assets)
-23.7%
The chart above shows a gap ratio of negative 23.7%, indicating
a significant amount of liability
sensitivity over the next 12 months. During this time,
management will have to reprice
approximately $152 million in liabilities but will have only
$105 million in assets reprice. This chart
suggests that a rising interest rate environment would have a
negative impact on interest
margins. Specifically, with an additional $46.8 million in
liabilities repricing, the model predicts that
a 100 basis point rise in rates would cost the bank an estimated
$468,000 in income.
C. Earnings
In this section, you need to evaluate earnings by assessing:
• The level, trend, and stability of earnings - Look for earnings
fluctuations and try to
determine the cause of those fluctuations.
• The quality and sources of earnings - Are the primary sources
of income from normal
banking activities that you can rely on in the future? Try to
assess the amount that is
attributable to non-recurring sources - like extraordinary gains
or investment trading
activities.
• The ability to augment capital through retained earnings - This
factor is very
important, especially in times of rapid growth or increasing
risk.
• The exposure to market risks - For most banks, this exposure
is centered in interest
rate risk. Maintaining higher levels of interest rates risk can
create dramatic swings in
income and could have negative implications for future
earnings.
• The provisions for loan losses - If the allowance for loan
losses is not adequate for the
risk identified in the loan portfolio, additional provisions will
be necessary, which will lower
net income.
Look at your bank’s Uniform Bank Performance Report and
focus on some key earnings ratios
that will help you monitor earnings performance. One fairly
standard approach to this analysis is
to follow what regulators typicaly refer to as the "Earnings
Analysis Trail". It focuses on the
following five items found on the Summary Ratios page of the
UBPR under Earnings and
Profitability.
Net Income
Logically, the first item to look at is the bottom line to
determine how well the bank is doing
overall. The line item listed as Net Income in the Earnings and
Profitability section is also known
as Return on Assets (ROA). The ratio is calculated by dividing
net income (after all expenses and
taxes) by average assets.
Net Interest Income
The second step on this earnings analysis trail is the line item
Net Interest Income (NII). This ratio
is calculated by subtracting total interest expense from total
interest income and dividing the
result by average assets.
Non-Interest Income
The line item for Non-Interest Income mainly consists of
service charges and miscellaneous
account fees and is usually the second major type of bank
income. Like the other ratios we have
seen, this ratio is measured as a percentage of average assets.
Overhead Expenses
Overhead is accounted for as Non-Interest Expense on the
UBPR. This item includes all
operating expenses except for interest expense and provisions
for loan losses. This line item
includes expenses such as salaries, depreciation, consulting
fees, and supplies. This ratio is
more fully detailed on page 4 of the UBPR.
Provision for Loan Losses
Another item that you need to discuss in the Earnings and
Profitability section is the Provision for
Loan Losses. Your main concern here is whether the provisions
are adequate to maintain the
Allowance for Loan Losses at an appropriate level. If the
allowance is too low relative to risk in
the loan portfolio, additional provisions will be necessary,
which must be taken out of earnings.
As you are discussing earnings and profitability, you should
specifically address any items with
significant changes. In that respect, you could answer questions
such as:
- What has caused the change in net income? What is the reason
for the increase or
decrease in overhead expenses?
- Review the following ratios:
• Yield on Total Loans
• Personnel Expenses as a Percent of Average Assets
- Has the yield on total loans and leases increased or decreased
during this period? At
the same time what happened to the interest income as a percent
of average assets
(Summary Page)?
- What are the reasons for the rise or drop in Non-Interest
Expense?
Finally, use your textbook’s continuing case assignment for
chapter 6 and discuss some of the
remaining profitability ratios shown there such as ROE; and the
breakdowns of ROA; ROE; and
net profit margin for your institution.
D. Asset Quality
The assessment of asset quality involves much more than simply
calculating past due and
adverse classification ratios. In addition to assessing trends in
classified assets, delinquent loans,
and credit concentrations, the asset quality component takes
into account management's ability
to underwrite and administer credits in a prudent and sound
manner. In that respect, the
regulators will examine a bank’s loan policies, loan portfolios
and the adequacy of the allowance
for loan and lease losses
The UBPR is a good starting point to begin extracting asset
quality information. It is a very useful
tool for identifying trends or outlying performance issues
relative to a group of similar banks.
Examiners use the UBPR to plan for examinations by
identifying areas with potential credit
exposure. Nonetheless, the UPBR will only take you so far in
painting a picture of asset quality.
Several financial ratios relating to asset quality are available in
the UBPR. These ratios provide
detail on balance sheet composition, off-balance sheet
commitments, delinquencies, charge-offs,
and portfolio mix. Four ratios to focus on when assessing asset
quality include:
1. Asset Growth Rate - This ratio details the change in total
assets over the past 12
months.
2. Non-current Loans and Leases to Gross Loans and Leases -
This ratio reflects the
percentage of loans that are 90 days or more past due, or are no
longer accruing interest.
3. Net Losses to Average Total Loans and Leases - This ratio
presents the level of net
losses, on an annualized basis, as a percentage of the total
portfolio. It takes into
consideration any recoveries on prior period losses.
4. Loan and Lease Allowance to Total Loans - This ratio
measures the allowance
available to absorb loan losses relative to total loans
outstanding.
In relation to these ratios, answer the following questions:
- Asset Growth Rate - What is the rate of asset growth and how
would you characterize
this growth?
- What category dominated asset growth?
- Non-current Loans to Gross Loans - How would you
characterize the level of
delinquencies?
- Net Losses to Average Total Loans - What has the trend
been?
- Loan and Lease Allowance to Total Loans and Leases - What
conclusions can you draw
about the adequacy of the allowance?
Of course, UBPR analysis is a starting point. You should also
review your textbook which
discusses the various bank assets in more detail.
E. Capital
After reviewing the previous four components, you should have
developed a good idea as to what
this bank's risk profile looks like. You will know whether they
have weak or strong earnings
record, any asset quality or liquidity problems and what the
exposures are. The level of capital
that would be considered satisfactory will vary according to the
level of risk in a bank. Of course,
the higher the risk, the greater the level of support required.
Keep this in mind when you look at
your bank's Uniform Bank Performance Report (UBPR). Even
though a given bank's capital ratios
are higher than peer, it does not mean that the bank has
satisfactory capital. Peer ratio
comparisons don't consider your bank's risk profile and don't
provide a conscious assessment of
a bank's capital position. It is not unusual that a bank with
greater than peer capital levels might
receive a lower capital rating.
Basically, capital adequacy is examined relative to a given
bank's risk profile and when you
assess capital you need to consider any factor that impacts the
bank. A short list of things that
may impact the need for more or less capital include:
1. The quality, type, and diversification of assets - If your bank
has high levels of
classifications, sub-prime loans, high or unmonitored
concentrations, aggressive
underwriting, etc., you'll need higher levels of capital.
2. The quality of management - If the institution operates with
bare minimum staffing
levels or lower quality management, the risk profile is higher,
requiring higher levels of
capital.
3. The quantity and quality of earnings available for capital
augmentation - When we
talk about the quality of earnings, we consider whether earnings
are from core banking
operations or from anomalies such as gains on the sale of assets.
The quantity of
earnings is important because we are concerned with the bank's
ability to augment
capital via retained earnings.
4. Exposure to changing interest rates - Higher/lower interest
rate risk impacts the risk
profile and thus the need for more or less capital.
5. Anticipated growth (strategic plan/budget) - Regulators are
concerned with what the
capital needs will be going forward. This is assessed relative to
earnings available for
augmentation, as well as existing levels of capital.
6. Local economic conditions - If the bank's market is limited to
one economic area or
one industry, the risk profile is greater. The greater the
diversification, the lower the risk.
7. Dividend requirements to shareholders or a holding company
- Again, regulators are
interested in what's available for capital augmentation to
support growth and the risk
profile.
The above items are all qualitative factors. You should also use
quantitative factors to assess
capital. Some key ratios are provided in your UBPR, and
include the following:
1. Tier 1 Leverage Capital Ratio (Tier 1 Capital/Average
Assets)
2. Tier 1 Risk-Based Capital Ratio (Tier 1 Capital/Risk
Weighted Assets)
3. Total Risk-Based Capital Ratio (Total Capital/Risk Weighted
Assets)
Your textbook provides definitions of the various capital
categories in chapter 15.
As you are reviewing your bank’s capital ratios, you should pay
particular attention to the
following:
- The level of the capital ratios
- How do they compare to peer?
- What are the trends?
- Which of these ratios showed the most significant change?
- Why would one capital ratio show a greater change than
another?
Additionally, look to the growth rate section.
- Can you explain any significant changes in the capital ratios?
- What asset category dominated the growth or drop in total
assets in recent times?
- If it’s loan growth or decline does this loan change affect your
bank's risk profile?
You should also take a look at your textbook’s continuing case
assignment for chapter 15 which
covers bank capital.
F. Management
This section is a review of your bank’s management including
its directors. In general, the bank
directors are responsible for formulating sound policies, setting
strategic direction, and effectively
supervising its management team; whereas the management
team is responsible for
implementing those policies in managing day-to-day operations.
It is important to clearly differentiate between the board's and
the management team's
responsibilities. The primary responsibilities of the board
members are to:
• Establish clear direction, policies, and risk limitations for the
bank - Directors
should not be involved in the day-to-day operations of the bank,
but need to establish
policies that give clear guidance with regard to acceptable
activities, procedures, and risk
limitations.
• Hire qualified senior officers - Senior officers should have a
proven ability to operate
departments or institutions of similar complexity and share the
same attributes as
directors (personal integrity, knowledge of trade area, capacity
for sound business
judgment, etc.).
• Ensure that management operates the bank within the
established policies and
risk limitations: Since directors are not typically involved in
day-to-day activities, this is
accomplished by:
o Implementing an effective internal audit and review program
o Establishing an effective management reporting system (board
packages,
committee minutes, UBPR analysis, etc.)
o Reviewing regulatory examination reports
o Staying involved by visiting the bank, attending meetings
(especially with
regulators and auditors), and by asking questions
Examiners evaluate and rate management on a variety of factors
and criteria, many of which are
listed below. Basically they consider how well the board and
senior management:
• Plan for and oversee operations - This includes funding
strategies, portfolio
management, compliance, information technology, new business
activities, etc. The best
managed banks have an active and fully informed board that is
encouraged to ask
questions during board meetings and requires management to
fully assess operations
when doing their strategic planning.
• Identify, measure, monitor, and control risks - Examiners will
consider management
practices when rating all of the CAMELS components; however,
the management
component rating encompasses the assessment of risk
management practices
throughout all operational areas.
• Establish and implement adequate policies, procedures, and
controls - Policies can
be effective tools for the board, senior officers, and employees,
but only if they truly
reflect the needs of the bank.
• Provide for an effective audit program - An effective audit
program is one that is
comprehensive, independent, objective, and overseen by an
audit committee comprised
of outside directors. These audits provide an opportunity to
validate management's
procedures and to ensure that the information supplied by
management is accurate.
Here, it is important to make sure that the audit committee is
the primary contact with
auditors and that management does not have an overwhelming
influence on those
auditors.
• Avoid dominant influence or concentration of authority -
Allowing an officer or
director to have a dominant influence can overwhelm even the
best control systems. This
can be a leading cause of poor bank performance and one that
has contributed to several
bank failures.
• Provide for management depth and succession - The loss of
key officers will disrupt
any bank's operations, so it is important to determine whether
the bank is prepared for
this loss by identifying and grooming key individuals.
• Avoid self-dealing - All of the regulatory agencies have
regulations that govern
transactions between financial institutions and their insiders and
affiliates. Essentially,
these laws require that the bank interests are first and that
appropriate disclosures are
been made.
Essentially rating of this component reflects the board's and
management's ability to identify,
measure, monitor, and control the risks associated with an
institution's activities and to ensure
safe, sound, and efficient operations in compliance with
applicable laws and regulations. While
directors may not need to be actively involved in day-to-day
operations, they must provide clear
guidance regarding acceptable risk exposure levels and ensure
that appropriate policies,
procedures, and practices have been established. Senior
management is responsible for
developing and implementing policies, procedures, and
practices that translate the board's goals,
objectives, and risk limits into prudent operating standards.
While some of the required information for an appropriate
evaluation of management is not
available to the general public, you should still try to assess the
management component by
reviewing any evidence that you are able to locate about the
following factors:
• The level and quality of oversight of all institution activities
by the board of directors and
management
• The ability of the board of directors and management, in their
respective roles, to plan for,
and respond to, risks that may arise from changing business
conditions or the initiation of
new activities or products
• The adequacy of, and conformance with, appropriate internal
policies and controls
• The accuracy, timeliness, and effectiveness of management
information systems
• The adequacy of audits and internal controls
• Compliance with laws and regulations
• Responsiveness to recommendations from auditors and
supervisory authorities
• Management depth and succession
• The extent that the board of directors and management is
affected by, or susceptible to,
dominant influence or concentration of authority
• Reasonableness of compensation policies and avoidance of
self-dealing
• Demonstrated willingness to serve the legitimate banking
needs of the community
• The overall performance of the institution and its risk profile
SUMMARY AND RECOMMENDATIONS
In this section, you should summarize your findings in the form
of strengths and weaknesses and
provide any Recommendations that you might have for your
institution.

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  • 1. What is this Project’s Objective? This project is designed to improve your ability to analyze a particular bank's performance. The emphasis should be to explore your bank from a regulator’s point of view. In that respect you should address the six CAMELS components and try to identify any "red flags" that could indicate potential problems in your bank. The Excel file under the name of “Bank Financial Analysis” should be used to capture the financial data for your bank and to show the associated financial ratios. You should be able to find all your data in your bank’s Uniform Bank Performance Report (UBPR) which is available at www.ffiec.gov. Your written report should be no less than 5 pages long (typed, double-spaced) not including the Excel worksheet. The six CAMELS components are: Capital adequacy; Asset quality; Management quality; Earnings record; Liquidity position; and Sensitivity to market risk. Following is a more detailed listing of the items that you need to address: A. Liquidity Consider your bank’s Uniform Bank Performance Report (UBPR) and provide an overview of your bank’s liquidity by reviewing the following areas: 1. Liquidity and Funding Ratios especially the Net Non-Core
  • 2. Funding Dependence and Loan to Assets Ratios – The first ratio measures the degree to which the bank is funding longer-term assets (loans, securities that mature in more than one year, etc.) with non-core funding. Non-core funding includes funding that can be very sensitive to changes in interest rates such as brokered deposits, CDs greater than $100,000, and borrowed money. Higher ratios reflect a reliance on funding sources that may not be available in times of financial stress or adverse changes in market conditions. What are the trends in these ratios? How do they compare to the peer? 2. The availability of liquid assets readily convertible to cash without undue loss- Consider Federal funds sold, available for sale securities, loans for sale, etc. 3. Core deposit/asset growth - Are core deposits capable of funding anticipated asset growth? 4. Diversification of funding sources - A bank with strong liquidity has a strong core deposit base, established borrowings lines, and procedures in place for acquiring internet-based or other forms of emergency borrowing. 5. External Forces - Economic conditions, competition, marketing efforts, etc. have a material impact on the need for liquidity going forward. You should also take a look at your textbook’s continuing case assignment for chapter 11 which
  • 3. discusses various bank liquidity indicators. B. Sensitivity to Market Risk Sensitivity to Market Risk - refers to the risk that changes in market conditions could adversely impact earnings and/or capital. Market Risk encompasses exposures associated with changes in interest rates, foreign exchange rates, commodity prices, equity prices, etc. While all of these items are important, the primary risk in most banks is interest rate risk (IRR). In the most simplistic terms, interest rate risk is a balancing act. Banks are trying to balance the quantity of http://www.ffiec.gov/� repricing assets with the quantity of repricing liabilities. For example, when a bank has more liabilities repricing in a rising rate environment than assets repricing, the net interest margin (NIM) shrinks. Conversely, if your bank is asset sensitive in a rising interest rate environment, your NIM will improve because you have more assets repricing at higher rates. Use your textbook’s continuing case assignment for chapter 7 and discuss sensitivity to market risk for your institution. In this section look for red flags such as a substantial change in the NIM - Look for substantial decreases or increases in the NIM. Changes in both directions could indicate that the bank is
  • 4. taking on more IRR than expected. Keep in mind, however, that significant changes in the NIM are not necessarily related to IRR. Changes in the balance sheet such as changing the percentage of earning assets, changing the risk profile, or changing the quantity of non-interest bearing funds can all affect the NIM. It should be noted that there are many ways to monitor exposure to IRR. Measurement systems vary in complexity from very simple methods such as a gap model, to very sophisticated models such as a simulation or duration analysis. A simple gap model is presented below to show the exposure that we are trying to measure. Repricing Time Frame Account Balance 0-12 months 1-5 years >5 years Cash 13,000 Investments 26,000 10,000 12,000 4,000 Loans 170,000 94,000 68,000 8,000 Federal funds 1,200 1,200 0 0 Premises 2,000 0 0 0 Other Assets 5,000 0 0 0 Totals 217,200 105,200 80,000 12,000 Deposits 160,000 132,000 28,000 0 Borrowings 35,000 20,000 15,000 0 Other Liabilities 4,000 0 0 0
  • 5. Totals 199,000 152,000 43,000 0 Gap (RSA-RSL) (46,800) 37,000 12,000 Cumulative Gap (46,800) (9,800) 2,200 Gap Ratio (Gap/Earning Assets) -23.7% The chart above shows a gap ratio of negative 23.7%, indicating a significant amount of liability sensitivity over the next 12 months. During this time, management will have to reprice approximately $152 million in liabilities but will have only $105 million in assets reprice. This chart suggests that a rising interest rate environment would have a negative impact on interest margins. Specifically, with an additional $46.8 million in liabilities repricing, the model predicts that a 100 basis point rise in rates would cost the bank an estimated $468,000 in income. C. Earnings In this section, you need to evaluate earnings by assessing: • The level, trend, and stability of earnings - Look for earnings fluctuations and try to determine the cause of those fluctuations. • The quality and sources of earnings - Are the primary sources
  • 6. of income from normal banking activities that you can rely on in the future? Try to assess the amount that is attributable to non-recurring sources - like extraordinary gains or investment trading activities. • The ability to augment capital through retained earnings - This factor is very important, especially in times of rapid growth or increasing risk. • The exposure to market risks - For most banks, this exposure is centered in interest rate risk. Maintaining higher levels of interest rates risk can create dramatic swings in income and could have negative implications for future earnings. • The provisions for loan losses - If the allowance for loan losses is not adequate for the risk identified in the loan portfolio, additional provisions will be necessary, which will lower net income. Look at your bank’s Uniform Bank Performance Report and focus on some key earnings ratios that will help you monitor earnings performance. One fairly standard approach to this analysis is to follow what regulators typicaly refer to as the "Earnings Analysis Trail". It focuses on the following five items found on the Summary Ratios page of the UBPR under Earnings and Profitability. Net Income Logically, the first item to look at is the bottom line to
  • 7. determine how well the bank is doing overall. The line item listed as Net Income in the Earnings and Profitability section is also known as Return on Assets (ROA). The ratio is calculated by dividing net income (after all expenses and taxes) by average assets. Net Interest Income The second step on this earnings analysis trail is the line item Net Interest Income (NII). This ratio is calculated by subtracting total interest expense from total interest income and dividing the result by average assets. Non-Interest Income The line item for Non-Interest Income mainly consists of service charges and miscellaneous account fees and is usually the second major type of bank income. Like the other ratios we have seen, this ratio is measured as a percentage of average assets. Overhead Expenses Overhead is accounted for as Non-Interest Expense on the UBPR. This item includes all operating expenses except for interest expense and provisions for loan losses. This line item includes expenses such as salaries, depreciation, consulting fees, and supplies. This ratio is more fully detailed on page 4 of the UBPR. Provision for Loan Losses Another item that you need to discuss in the Earnings and Profitability section is the Provision for Loan Losses. Your main concern here is whether the provisions are adequate to maintain the Allowance for Loan Losses at an appropriate level. If the allowance is too low relative to risk in
  • 8. the loan portfolio, additional provisions will be necessary, which must be taken out of earnings. As you are discussing earnings and profitability, you should specifically address any items with significant changes. In that respect, you could answer questions such as: - What has caused the change in net income? What is the reason for the increase or decrease in overhead expenses? - Review the following ratios: • Yield on Total Loans • Personnel Expenses as a Percent of Average Assets - Has the yield on total loans and leases increased or decreased during this period? At the same time what happened to the interest income as a percent of average assets (Summary Page)? - What are the reasons for the rise or drop in Non-Interest Expense? Finally, use your textbook’s continuing case assignment for chapter 6 and discuss some of the remaining profitability ratios shown there such as ROE; and the breakdowns of ROA; ROE; and net profit margin for your institution. D. Asset Quality
  • 9. The assessment of asset quality involves much more than simply calculating past due and adverse classification ratios. In addition to assessing trends in classified assets, delinquent loans, and credit concentrations, the asset quality component takes into account management's ability to underwrite and administer credits in a prudent and sound manner. In that respect, the regulators will examine a bank’s loan policies, loan portfolios and the adequacy of the allowance for loan and lease losses The UBPR is a good starting point to begin extracting asset quality information. It is a very useful tool for identifying trends or outlying performance issues relative to a group of similar banks. Examiners use the UBPR to plan for examinations by identifying areas with potential credit exposure. Nonetheless, the UPBR will only take you so far in painting a picture of asset quality. Several financial ratios relating to asset quality are available in the UBPR. These ratios provide detail on balance sheet composition, off-balance sheet commitments, delinquencies, charge-offs, and portfolio mix. Four ratios to focus on when assessing asset quality include: 1. Asset Growth Rate - This ratio details the change in total assets over the past 12 months. 2. Non-current Loans and Leases to Gross Loans and Leases - This ratio reflects the percentage of loans that are 90 days or more past due, or are no longer accruing interest.
  • 10. 3. Net Losses to Average Total Loans and Leases - This ratio presents the level of net losses, on an annualized basis, as a percentage of the total portfolio. It takes into consideration any recoveries on prior period losses. 4. Loan and Lease Allowance to Total Loans - This ratio measures the allowance available to absorb loan losses relative to total loans outstanding. In relation to these ratios, answer the following questions: - Asset Growth Rate - What is the rate of asset growth and how would you characterize this growth? - What category dominated asset growth? - Non-current Loans to Gross Loans - How would you characterize the level of delinquencies? - Net Losses to Average Total Loans - What has the trend been? - Loan and Lease Allowance to Total Loans and Leases - What conclusions can you draw about the adequacy of the allowance? Of course, UBPR analysis is a starting point. You should also review your textbook which discusses the various bank assets in more detail.
  • 11. E. Capital After reviewing the previous four components, you should have developed a good idea as to what this bank's risk profile looks like. You will know whether they have weak or strong earnings record, any asset quality or liquidity problems and what the exposures are. The level of capital that would be considered satisfactory will vary according to the level of risk in a bank. Of course, the higher the risk, the greater the level of support required. Keep this in mind when you look at your bank's Uniform Bank Performance Report (UBPR). Even though a given bank's capital ratios are higher than peer, it does not mean that the bank has satisfactory capital. Peer ratio comparisons don't consider your bank's risk profile and don't provide a conscious assessment of a bank's capital position. It is not unusual that a bank with greater than peer capital levels might receive a lower capital rating. Basically, capital adequacy is examined relative to a given bank's risk profile and when you assess capital you need to consider any factor that impacts the bank. A short list of things that may impact the need for more or less capital include: 1. The quality, type, and diversification of assets - If your bank has high levels of classifications, sub-prime loans, high or unmonitored concentrations, aggressive underwriting, etc., you'll need higher levels of capital.
  • 12. 2. The quality of management - If the institution operates with bare minimum staffing levels or lower quality management, the risk profile is higher, requiring higher levels of capital. 3. The quantity and quality of earnings available for capital augmentation - When we talk about the quality of earnings, we consider whether earnings are from core banking operations or from anomalies such as gains on the sale of assets. The quantity of earnings is important because we are concerned with the bank's ability to augment capital via retained earnings. 4. Exposure to changing interest rates - Higher/lower interest rate risk impacts the risk profile and thus the need for more or less capital. 5. Anticipated growth (strategic plan/budget) - Regulators are concerned with what the capital needs will be going forward. This is assessed relative to earnings available for augmentation, as well as existing levels of capital. 6. Local economic conditions - If the bank's market is limited to one economic area or one industry, the risk profile is greater. The greater the diversification, the lower the risk. 7. Dividend requirements to shareholders or a holding company - Again, regulators are interested in what's available for capital augmentation to
  • 13. support growth and the risk profile. The above items are all qualitative factors. You should also use quantitative factors to assess capital. Some key ratios are provided in your UBPR, and include the following: 1. Tier 1 Leverage Capital Ratio (Tier 1 Capital/Average Assets) 2. Tier 1 Risk-Based Capital Ratio (Tier 1 Capital/Risk Weighted Assets) 3. Total Risk-Based Capital Ratio (Total Capital/Risk Weighted Assets) Your textbook provides definitions of the various capital categories in chapter 15. As you are reviewing your bank’s capital ratios, you should pay particular attention to the following: - The level of the capital ratios - How do they compare to peer? - What are the trends? - Which of these ratios showed the most significant change? - Why would one capital ratio show a greater change than another? Additionally, look to the growth rate section. - Can you explain any significant changes in the capital ratios? - What asset category dominated the growth or drop in total assets in recent times? - If it’s loan growth or decline does this loan change affect your bank's risk profile?
  • 14. You should also take a look at your textbook’s continuing case assignment for chapter 15 which covers bank capital. F. Management This section is a review of your bank’s management including its directors. In general, the bank directors are responsible for formulating sound policies, setting strategic direction, and effectively supervising its management team; whereas the management team is responsible for implementing those policies in managing day-to-day operations. It is important to clearly differentiate between the board's and the management team's responsibilities. The primary responsibilities of the board members are to: • Establish clear direction, policies, and risk limitations for the bank - Directors should not be involved in the day-to-day operations of the bank, but need to establish policies that give clear guidance with regard to acceptable activities, procedures, and risk limitations. • Hire qualified senior officers - Senior officers should have a proven ability to operate departments or institutions of similar complexity and share the same attributes as
  • 15. directors (personal integrity, knowledge of trade area, capacity for sound business judgment, etc.). • Ensure that management operates the bank within the established policies and risk limitations: Since directors are not typically involved in day-to-day activities, this is accomplished by: o Implementing an effective internal audit and review program o Establishing an effective management reporting system (board packages, committee minutes, UBPR analysis, etc.) o Reviewing regulatory examination reports o Staying involved by visiting the bank, attending meetings (especially with regulators and auditors), and by asking questions Examiners evaluate and rate management on a variety of factors and criteria, many of which are listed below. Basically they consider how well the board and senior management: • Plan for and oversee operations - This includes funding strategies, portfolio management, compliance, information technology, new business activities, etc. The best managed banks have an active and fully informed board that is encouraged to ask questions during board meetings and requires management to fully assess operations when doing their strategic planning.
  • 16. • Identify, measure, monitor, and control risks - Examiners will consider management practices when rating all of the CAMELS components; however, the management component rating encompasses the assessment of risk management practices throughout all operational areas. • Establish and implement adequate policies, procedures, and controls - Policies can be effective tools for the board, senior officers, and employees, but only if they truly reflect the needs of the bank. • Provide for an effective audit program - An effective audit program is one that is comprehensive, independent, objective, and overseen by an audit committee comprised of outside directors. These audits provide an opportunity to validate management's procedures and to ensure that the information supplied by management is accurate. Here, it is important to make sure that the audit committee is the primary contact with auditors and that management does not have an overwhelming influence on those auditors. • Avoid dominant influence or concentration of authority - Allowing an officer or director to have a dominant influence can overwhelm even the best control systems. This can be a leading cause of poor bank performance and one that has contributed to several bank failures.
  • 17. • Provide for management depth and succession - The loss of key officers will disrupt any bank's operations, so it is important to determine whether the bank is prepared for this loss by identifying and grooming key individuals. • Avoid self-dealing - All of the regulatory agencies have regulations that govern transactions between financial institutions and their insiders and affiliates. Essentially, these laws require that the bank interests are first and that appropriate disclosures are been made. Essentially rating of this component reflects the board's and management's ability to identify, measure, monitor, and control the risks associated with an institution's activities and to ensure safe, sound, and efficient operations in compliance with applicable laws and regulations. While directors may not need to be actively involved in day-to-day operations, they must provide clear guidance regarding acceptable risk exposure levels and ensure that appropriate policies, procedures, and practices have been established. Senior management is responsible for developing and implementing policies, procedures, and practices that translate the board's goals, objectives, and risk limits into prudent operating standards. While some of the required information for an appropriate evaluation of management is not
  • 18. available to the general public, you should still try to assess the management component by reviewing any evidence that you are able to locate about the following factors: • The level and quality of oversight of all institution activities by the board of directors and management • The ability of the board of directors and management, in their respective roles, to plan for, and respond to, risks that may arise from changing business conditions or the initiation of new activities or products • The adequacy of, and conformance with, appropriate internal policies and controls • The accuracy, timeliness, and effectiveness of management information systems • The adequacy of audits and internal controls • Compliance with laws and regulations • Responsiveness to recommendations from auditors and supervisory authorities • Management depth and succession • The extent that the board of directors and management is affected by, or susceptible to, dominant influence or concentration of authority • Reasonableness of compensation policies and avoidance of self-dealing • Demonstrated willingness to serve the legitimate banking needs of the community • The overall performance of the institution and its risk profile SUMMARY AND RECOMMENDATIONS
  • 19. In this section, you should summarize your findings in the form of strengths and weaknesses and provide any Recommendations that you might have for your institution.