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Articles Tagged with: Operational Risk

Prepayment Spikes in Ida’s Wake – What to Expect

It is, of course, impossible to view the human suffering wrought by Hurricane Ida without being reminded of Hurricane Katrina’s impact 16 years ago. Fortunately, the levees are holding and Ida’s toll appears likely to be less severe. It is nevertheless worth taking a look at what happened to mortgages in the wake of New Orleans’s last major catastrophic weather event as it is reasonable to assume that prepayments could follow a similar pattern (though likely in a more muted way).

Following Katrina, prepayment speeds for pools of mortgages located entirely in Louisiana spiked between November 2005 and June 2006. As the following graph shows, prepayment speeds on Louisiana properties (the black curve) remained elevated relative to properties nationally (the blue curve) until the end of 2006. 

Comparing S-curves of Louisiana loans (the black curve in the chart below) versus all loans (the green curve) during the spike period (Nov. 2005 to Jun. 2006) reveals speeds ranging from 10 to 20 CPR faster across all refinance incentives. The figure below depicts an S-curve for non-spec 100% Louisiana pools and all non-spec pools with a weighted average loan age of 7 to 60 months during the period indicated.

The impact of Katrina on Louisiana prepayments becomes even more apparent when we consider speeds prior to the storm. As the S-curves below show, non-specified 100% Louisiana pools (the black curve) actually paid slightly slower than all non-spec pools between November 2003 and October 2005.

As we pointed out in June, a significant majority of prepayments caused by natural disaster events are likely to be voluntary, as opposed to the result of default as one might expect. This is because mortgages on homes that are fully indemnified against these perils are likely to be prepaid using insurance proceeds. This dynamic is reflected in the charts below, which show elevated voluntary prepayment rates running considerably higher than the delinquency spike in the wake of Katrina. We are able to isolate voluntary prepayment activity by looking at the GSE Loan Level Historical Performance datasets that include detailed credit information. This enables us to confirm that the prepay spike is largely driven by voluntary prepayments. Consequently, recent covid-era policy changes that may reduce the incidence of delinquent loan buyouts from MBS are unlikely to affect the dynamics underlying the prepayment behavior described above.

RiskSpan’s Edge Platform enables users to identify Louisiana-based loans and pools by drilling down into cohort details. The example below returns over $1 billion in Louisiana-only pools and $70 billion in Louisiana loans as of the August 2021 factor month.


Edge also allows users to structure more specified queries to identify the exposure of any portfolio or portfolio subset. Edge, in fact, can be used to examine any loan characteristic to generate S-curves, aging curves, and time series.  Contact us to learn more.



Is the housing market overheated? It depends where you are.

Mortgage credit risk modeling has evolved slowly in the last few decades. While enhancements leveraging conventional and alternative data have improved underwriter insights into borrower income and assets, advances in data supporting underlying property valuations have been slow. With loan-to-value ratios being such a key driver of loan performance, the stability of a subject property’s value is arguably as important as the stability of a borrower’s income.

Most investors rely on current transaction prices to value comparable properties, largely ignoring the risks to the sustainability of those prices. Lacking the data necessary to identify crucial factors related to a property value’s long-term sustainability, investors generally have little choice but to rely on current snapshots. To address this problem, credit modelers at RiskSpan are embarking on an analytics journey to evaluate the long-term sustainability of a property’s value.

To this end, we are working to pull together a deep dataset of factors related to long-term home price resiliency. We plan to distill these factors into a framework that will enable homebuyers, underwriters, and investors to quickly assess the risk inherent to the property’s physical location. The data we are collecting falls into three broad categories:

  • Regional Economic Trends
  • Climate and Natural Hazard Risk
  • Community Factors

Although regional home price outlook sometimes factors into mortgage underwriting, the long-term sustainability of an individual home price is seldom, if ever, taken into account. The future value of a secured property is arguably of greater importance to mortgage investors than its value at origination. Shouldn’t they be taking an interest in regional economic condition, exposure to climate risk, and other contributors to a property valuation’s stability?

We plan to introduce analytics across all three of these dimensions in the coming months. We are particularly excited about the approach we’re developing to analyze climate and natural hazard risk. We will kick things off, however, with basic economic factors. We are tracking the long-term sustainability of house prices through time by tracking economic fundamentals at the regional level, starting with the ratio of home prices to median household income.

Economic Factors

Housing is hot. Home prices jumped 12.7% nationally in 2020, according to FHFA’s house price index[1]. Few economists are worried about a new housing bubble, and most attribute this rise to supply and demand dynamics. Housing supply is low and rising housing demand is a function of demography –millennials are hitting 40 and want a home of their own.

But even if the current dynamic is largely driven by low supply, there comes a certain point at which house prices deviate too much from area median household income to be sustainable. Those who bear the most significant exposure to mortgage credit risk, such as GSEs and mortgage insurers, track regional house price dynamics to monitor regions that might be pulling away from fundamentals.

Regional home-price-to-income ratio is a tried-and-true metric for judging whether a regional market is overheating or under-valued. We have scored each MSA by comparing its current home-price-to-income ratio to its long-term average. As the chart below illustrating this ratio’s trend shows, certain MSAs, such as New York, consistently have higher ratios than other, more affordable MSAs, such as Chicago.

Because comparing one MSA to another in this context is not particularly revealing, we instead compare each MSA’s current ratio to the long-term ratio for itself. MSAs where that ratio exceeds its long-term average are potentially over-heated, while MSAs under that ratio potentially have more room to grow. In the table below highlighting the top 25 MSAs based on population, we look at how the home-price-to-household-income ratio deviates from its MSA long-term average. The metric currently suggests that Dallas, Denver, Phoenix, and Portland are experiencing potential market dislocation.

Loans originated during periods of over-heating have a higher probability of default, as illustrated in the scatterplot below. This plot shows the correlation between the extent of the house-price-to-income ratio’s deviation from its long-term average and mortgage default rates. Each dot represents all loan originations in a given MSA for a given year[1]. Only regions with large deviations in house price to income ratio saw explosive default rates during the housing crisis. This metric can be a valuable tool for loan and SFR investors to flag metros to be wary of (or conversely, which metros might be a good buy).

Although admittedly a simple view of regional economic dynamics driving house prices (fundamentals such as employment, housing starts per capita, and population trends also play important roles) median income is an appropriate place to start. Median income has historically proven itself a valuable tool for spotting regional price dislocations and we expect it will continue to be. Watch this space as we continue to add these and other elements to further refine how we measure property value stability and its likely impact on mortgage credit.


[1] FHFA Purchase Only USA NSA % Change over last 4 quarters

Contact us to learn more.



Is Your Enterprise Risk Management Keeping Up with Recent Regulatory Changes?​

For enterprise risk managers, ensuring that all the firm’s various risk management structures and frameworks are keeping up with ever-changing regulatory guidance can be a daunting task. Regulatory updates take on particular importance for model risk managers. MRM is required not only to understand and comply with the regulatory guidance specific to model risk management itself, but also to understand the regulatory ramifications of the risk models they validate.

This post focuses on recent updates to eight ERM areas that can sometimes seem like a moving target when it comes to risk compliance.

The timeline below illustrates the extensive variability that can exist from regulator to regulator when it comes to which ERM components are of most concern and the nature and speed of adoption. To take one example, model risk management guidance was issued in 2011 and all Fed- and OCC-regulated institutions were in general compliance with it by 2014. The FDIC, however, did not issue the same guidance until 2017 and enforcement varies considerably. Although every FDIC-regulated institution is technically required to be in compliance with the MRM guidance, several have yet to undergo even their first MRM exam. Things get even cloudier for credit unions as the NCUA has not issued any guidance or regulation pertaining to MRM. The NCUA requires MRM practices to be observed during Capital Planning and Stress Testing (per its 2019 capital planning guide). But this narrow definition allows most credit unions to skirt regulator-required MRM entirely.

Because it can be difficult to stay on top of which regulator is requiring what and when, here is a quick summary of recent updates, organized by risk area.

Bank Secrecy Act (BSA/ Anti Money Laundering (AML) 

The past year has seen five guidance updates pertaining to BSA/AML. Most of these seek to increase the effectiveness, predictability, and transparency of BSA/AML regulatory exams. Other updates clarify specific aspects of BSA/AML risk.

  1. Updated Sections of the FFIEC BSA/AML Examination Manual (OCC 2021-10/SR 21-9 & OCC 2021-28). The updated sections:
    • Reinforce the risk-focused approach to BSA/AML examinations, and
    • Clarify regulatory requirements and include updated information for examiners regarding transaction testing, including examples.
  1. Interagency Statement on Model Risk Management for Bank Systems Supporting BSA/AML Compliance and Request for Information (OCC 2021-19/SR 21-8) as of April 12, 2021. This guidance:
    • Outlines the importance of MRM governance to AML exams,
    • Is designed to be flexible when applying MRM principals to BSA/AML models,
    • Updates MRM principles and validation to be more responsive,
    • Seeks not to apply a single industry-wide approach, and
    • Directs validators to consider third-party documentation when reviewing AML models.
  1. Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other AML Considerations (OCC 2021-4) as of January 21, 2021. These include instructions around:
    • Requests by law enforcement for financial institutions to maintain accounts,
    • Receipt of grand jury subpoenas/law enforcement inquiries and suspicious activity report (SAR) filing,
    • Maintaining a customer relationship following the filing of a SAR or multiple SARs,
    • SAR filing on negative news identified in media searches,
    • SAR monitoring on multiple negative media alerts,
    • Information in data fields and narrative, and
    • SAR character limits.
  1. Joint Statement on Bank Secrecy Act Due Diligence Requirements for Customers Who May Be Considered Politically Exposed Persons (OCC 2020-77/SR 20-19) as of August 21, 2020. This statement:
    • Explains that the BSA/AML regulations do not define what constitutes a politically exposed person (PEP),
    • Clarifies that the customer due diligence rule does not create a regulatory requirement and that there is no supervisory expectation for banks to have unique, additional due diligence steps for PEPs,
    • Clarifies how banks can apply a risk-based approach to customer due diligence in developing risk profiles for their customers, and
    • Discusses potential risk factors, levels and types of due diligence.
  1. OCC-Proposed Rule Regarding Exemptions to Suspicious Activity Report Requirements as of December 17, 2020:
    • The proposed rule would amend the agency’s SAR regulations to allow the OCC to issue exemptions from the requirements of those regulations on when and how to file suspicious activity reports (SARs).
Allowance for Loan and Lease Losses (ALLL)/ Current Expected Credit Losses (CECL) 

Current Expected Credit Losses: Final Rule (OCC 2020-85/SR 19-8/FIL-7-2021) as of October 1, 2020. The rule:

    • Applies to all community banks that adopted CECL in 2020 per GAAP requirements,
    • Exempts all other institutions until 2023,
    • Adopts all of the 2020 CECL IFR, and
    • Clarifies that a banking organization is not required to use the transition during fiscal quarters in which it would not generate a regulatory capital benefit.
Asset Liability Management (ALM) and Liquidity Risk Management 

Four important updates to ALM and liquidity risk guidance were issued in the past year.

  1. Net Stable Funding Ratio: Final Rule (OCC 2021-9) as of February 24, 2021. The rule:
    • Implements a minimum stable funding requirement designed to reduce the likelihood that disruptions to a covered company’s regular sources of funding will compromise its liquidity position,
    • Requires the maintenance a ratio of “available stable funding” to “required stable funding” of at least 1.0 on an ongoing basis,
    • Defines “available stable funding” as the stability of a banking organization’s funding sources,
    • Defines “required stable funding” as the liquidity characteristics of a banking organization’s assets, derivatives, and off-balance-sheet exposures,
    • Requires notification of a shortfall, realized or potential within 10 business days, and
    • Provides public disclosure rules for a consolidated NSFR.
  1. Volcker Rule Covered Funds: Final Rule (OCC 2020-71) as of July 41, 2020. The rule:
    • Permits the activities of qualifying foreign excluded funds,
    • Revises the exclusions from the definition of “covered fund,”
    • Creates new exclusions from the definition of covered fund for credit funds, qualifying venture capital funds, family wealth management vehicles, and customer facilitation vehicles, and
    • Modifies the definition of “ownership interest.”
  1. Interest Rate Risk: Revised Comptroller’s Handbook Booklet (OCC 2020-26) as of March 26, 2020. The updated Handbook:
    • Expands discussions on MRM expectations for reviewing and testing model assumptions,
    • Addresses funds transfer pricing (FTP), and
    • Adds guidelines for advanced approaches to interest rate risk management consistent with the Pillar 2 supervisory approach.
  1. Capital and Liquidity Treatment for Money Market Liquidity Facility and Paycheck Protection Program: Final Rule (OCC 2020-96) as of November 3, 2020. This rule:
    • Permits a zero-percent risk weight for PPP loans,
    • Eliminates the regulatory capital impact and liquidity rule provisions for participating in the PPP and Money Market Liquidity Facility.
Artificial Intelligence (AL)/ Machine Learning (ML) 

The only recent regulatory update pertaining to AI/Machine Learning has been a request for comment related to usage, controls, governance, and risk. At present, there is no formal guidance specifically related to AI or ML models. The OCC’s semi-annual risk perspectives includes just a couple of sentences stating that users of ML models should be able to defend and explain their risks. The Fed’s feedback has been similarly broad. Movement seems afoot to issue more detailed guidance on how ML models should be governed and monitored. But this is likely to be limited to specific applications and not to the ML models themselves.

The Request for Information and Comment on Financial Institutions’ Use of Artificial Intelligence, Including Machine Learning (OCC 2021-17) as of March 31, 2021, seeks respondents’ views on appropriate governance, risk management, and controls over artificial intelligence, and any challenges in developing, adopting, and managing artificial intelligence approaches.

Capital Risk 

We focus on the two items of capital risk guidance issued in the past year. The rule applies to community banks with total assets of less than $10 billion as of December 31, 2019.

  1. Temporary Asset Thresholds: Interim Final Rule (OCC 2020-107) as of December 2, 2020:
    • The rule allows these institutions to use asset data as of December 31, 2019, to determine the applicability of various regulatory asset thresholds during calendar years 2020 and 2021.
  1. Regulatory Capital Rule: Eligible Retained Income: Final Rule (OCC 2020-87) as of October 8, 2020:

The final rule revises the definition of eligible retained income to the greater of:

    • Net income for the four preceding calendar quarters, net of any distributions and associated tax effects not already reflected in net income, and
    • The average of a Bank’s net income over the preceding four quarters.
Fair Lending 
  1. Community Reinvestment Act: Key Provisions of the June 2020 CRA Rule and Frequently Asked Questions (OCC 2020-99) as of November 9, 2020:

The rule establishes new criteria for designating bank assessment areas, including:

    • Facility-based assessment areas based on the location of a bank’s main office and branches and, at a bank’s discretion, on the location of the bank’s deposit-taking automated teller machines, and
    • Deposit-based assessment areas, which apply to a bank with 50 percent or more of its retail domestic deposits outside its facility-based assessment areas.
  1. Community Reinvestment Act: Implementation of the June 2020 Final Rule (OCC 2021-24) as of May 18, 2021. The OCC has determined that it will reconsider its June 2020 rule. While this reconsideration is ongoing, the OCC will not implement or rely on the evaluation criteria in the June 2020 rule pertaining to:
    • Quantification of qualifying activities
    • Assessment areas
    • General performance standards
    • Data collection
    • Recordkeeping
    • Reporting
Market Risk 
  1. Libor Transition: Self-Assessment Tool for Banks (OCC 2021-7) as of February 10, 2021. The self-assessment tool can be used to assess the following:
    • Five primary topics: Assets and contracts; LIBOR risk exposure; Fallback language; Consumer impact; Third-party service provider
    • The appropriateness of a bank’s Libor transition plan
    • Bank management’s execution of the bank’s transition plan
    • Related oversight and reporting
  1. Standardized Approach for Counterparty Credit Risk; Correction: Final Rule (OCC 2020-82) as of September 21, 2020. The issuance corrects errors in the standardized approach for counterparty credit risk (SA-CCR) rule:
    • Clarifying that a Bank that uses SA-CCR will be permitted to exclude the future exposure of all credit derivatives
    • Revising the number of outstanding margin disputes
    • Correcting the calculation of the hypothetical capital requirement of a qualifying central counterparty (QCCP)
  1. Agencies Finalize Amendments to Swap Margin Rule (News Release 2020-83) as of June 25, 2020:
    • Swap entities that are part of the same banking organization will no longer be required to hold a specific amount of initial margin for uncleared swaps with each other, known as inter-affiliate swaps.
    • Final rule allows swap entities to amend legacy swaps to replace the reference to LIBOR or other reference rates that are expected to end without triggering margin exchange requirements.
Operations Risk
  1. Corporate and Risk Governance. Revised and New Publications in the Director’s Toolkit (OCC 2020-97) as of November 5, 2020:
    • Defines permissible derivatives activities,
    • Allows engagement in certain tax equity finance transactions,
    • Expands the ability to choose corporate governance provisions under state law,
    • Includes OCC interpretations relating to capital stock issuances and repurchases, and
    • Applies rules relating to finder activities, indemnification, equity kickers, postal services, independent undertakings, and hours and closings to FSAs.
  1. Activities and Operations of National Banks and Federal Savings Associations: Final Rule (OCC 2020-111) as of December 23, 2020:
    • Focuses on key areas of planning, operations, and risk management,
    • Outlines directors’ responsibilities as well as management’s role,
    • Explains basic concepts and standards for safe and sound operation of banks, and
    • Delineates laws and regulations that apply to banks.
  1. Operational Risk: Sound Practices to Strengthen Operational Resilience (OCC 2020-94) as of October 10, 2020:
    • Outlines standards for operational resilience set forth in the agencies’ rules and guidance,
    • Promotes a principles-based approach for effective governance, robust scenario analysis, secure and resilient information systems, and thorough surveillance and reporting,
    • Introduces sound practices for managing cyber risk.
Contact us to learn more.


Managing Operational and Credit Risk in Mortgage Servicing Portfolios During the COVID-19 Crisis

Tomorrow (April 1st) is the due date of the first significant wave of mortgage payments since the Coronavirus began disrupting the economy. The operational impact of COVID-19 on mortgage bankers—and servicers in particular—has been swift and dramatic. It will not soon subside. Its financial impact remains on the horizon but is likely to be felt over a more extended period. 

Whereas borrower inquiries related to the Coronavirus accounted for zero percent of servicer call volume as recently as March 16th, within a week they have spiked to more than 25 percent of inquiries at one servicer. Another servicer reported receiving over 20,000 calls relating to forbearance relief during the same period. 

We are officially in a new world. The next several months appear to hold chaos, disruption, and potentially devastating losses for mortgage servicers. When delinquencies associated with April 1st payments start to hit, the financial impact—felt primarily through P&I, T&I, and corporate advances, additional collection and compliance costs, and the loss of servicing fee income simply because fewer payments are being made—has the potential to linger considerably longer than the liquidity and funding crisis currently rocking financial markets.    

Having a roadmap for navigating impending financial, credit, and operational dilemmas has never been more important.   

Market dislocations created by the speed and seriousness of COVID-19 are constraining (and will continue to constrain) servicers’ tools for responding to and resolving a forthcoming tsunami of delinquencies, foreclosures and REOs. The ability of servicers to manage through this will be further complicated by external factors that will dictate when and how servicers will be able to manage their businesses. These are likely to include various forms of government intervention, such as payment holidays, mandatory forbearance, foreclosure moratoriums, and modification programs. While protecting borrowers, these programs will also add layers of complexity into servicer compliance operations. 

In addition to introducing new sets of moral hazard issues for the servicing of mortgages, increases in delinquencies and illiquidity of trading markets will seize the trading markets for servicing portfolios, limiting mortgage bankers’ access to cash. Investors, guarantors, and insurers will increase their oversight into servicer operations to minimize their losses.  

One Solution 

RiskSpan has been working with its mortgage banking clients to construct a modeling framework for assessing, quantifying, and managing COVID-19 risk to servicing operations and income statements. The framework covers the full lifecycle of a servicing asset and is designed to forecast each of the following under several defined stress scenarios: 

  • Principal and interest advances
  • Escrow (T&I) advances 
  • Corporate advances to cover foreclosure, liquidations and REO expenditures 
  • Financing and capital implications of delinquent and defaulted loans 
  • Repurchases, denials, and rescissions  
  • Compensatory fees and curtailments 

In addition to projecting these financial costs, the modeling framework forecasts the incremental operational costs associated with servicing a portfolio with increasing shares of delinquencies, defaults, bankruptcies, liquidations, and REOs—including all the incremental personnel, compliance and other costs associated with servicing a portfolio that was prime at acquisition but is suddenly beginning to take on subprime characteristics.  

Contact us to talk about how RiskSpan’s operational risk assessment tool can be customized to your servicing portfolio. 


Webinar: Applying Model Validation Principles to Anti-Money Laundering Tools

webinar

Applying Model Validation Principles to Anti-Money Laundering Tools

This webinar will explore some of the more efficient ways we have encountered for applying model validation principles to AML tools, including:

  • Ensuring that the rationale supporting rules and thresholds is sufficiently documented 
  • Applying above-the-line and below-the-line testing to an effective benchmarking regime 
  • Assessing the relevance of rules that are seldom triggered or frequently overridden 


About The Hosts

Timothy Willis

Managing Director – RiskSpan

Timothy Willis is head of RiskSpan’s Governance and Controls Practice, with a particular focus on model risk management. He is an experienced engagement manager, financial model validator and mortgage industry analyst who regularly authors and oversees the delivery of technical reports tailored to executive management and regulatory audiences.

Tim has directed projects validating virtually every type of model used by banks. He has also developed business requirements and improved processes for commercial banks of all sizes, mortgage banks, mortgage servicers, Federal Home Loan Banks, rating agencies, Fannie Mae, Freddie Mac, and U.S. Government agencies.

Susan Devine, Cams, CPA

Senior Consultant – Third Pillar Consulting

Susan has more than twenty years of experience as an independent consultant providing business analysis, financial model validations, anti-money laundering reviews in compliance with the Bank Secrecy Act, and technical writing to government and commercial entities. Experience includes developing and documenting business processes, business requirements, security requirements, computer systems, networks, systems development lifecycle activities, and financial models. Experience related to business processes includes business process reviews, security plans in compliance with NIST and GISRA, Sarbanes Oxley compliance documents, Dodd-Frank Annual Stress Testing, functional and technical requirements for application development projects, policies, standards, and operating procedures for business and technology processes.

Chris Marsten

Financial and Data Analyst – RiskSpan

Chris is a financial and data analyst at RiskSpan where he develops automated analytics and reporting for client loan portfolios and provides data analysis in support of model validation projects. He also possesses extensive experience writing ETL code and automating manual processes. Prior to coming to RiskSpan, he developed and managed models for detecting money laundering and terrorist activity for Capital One Financial Corporation, where he also forecasted high-risk customer volumes and created an alert investigation tool for identifying suspicious customers and transactions.


Webinar: Building and Running an Efficient Model Governance Program

webinar

Building and Running an Efficient Model Governance Program

Join RiskSpan Model Governance Expert Tim Willis for a webinar about running an efficient program. This webinar will cover essential elements of a model risk management policy including how to devise policies for open-source models and other applications not easily categorized. They’ll discuss best practices for building and maintaining a model inventory, tips for assigning appropriate risk ratings to models and determining validation frequency.


About The Host

Timothy Willis

Managing Director – RiskSpan

Timothy Willis is head of RiskSpan’s Governance and Controls Practice, with a particular focus on model risk management. He is an experienced engagement manager, financial model validator and mortgage industry analyst who regularly authors and oversees the delivery of technical reports tailored to executive management and regulatory audiences.


Webinar: Managing Down Model Validation Costs

webinar

Managing Down Model Validation Costs

Learn how to make your model validation budget go further for you.  In this webinar, you’ll learn about:  Balancing internal and external resources, prioritizing models with the most risk, documenting to facilitate the process.


About The Hosts

Timothy Willis

Managing Director – RiskSpan

Timothy Willis is an experienced engagement manager, financial model validator and mortgage industry analyst who regularly authors and oversees the delivery of technical reports tailored to executive management and regulatory audiences. Tim has directed projects validating virtually every type of model used by banks. He has also developed business requirements and improved processes for commercial banks of all sizes, mortgage banks, mortgage servicers, Federal Home Loan Banks, rating agencies, Fannie Mae, Freddie Mac, and U.S. Government agencies.

Nick Young

Director of Model Risk Management

Nick Young has more than ten years of experience as a quantitative analyst and economist. At RiskSpan, he performs model validation, development and governance on a wide variety of models including those used for Basel capital planning, reserve/impairment, Asset Liability Management (ALM), CCAR/DFAST stress testing, credit origination, default, prepayment, market risk, Anti-Money Laundering (AML), fair lending, fraud and account management.


eBook: A Validator’s Guide to Model Risk Management

ebook

A Validator’s Guide to Model Risk Management

Learn from RiskSpan model validation experts what constitutes a model, considerations for validating vendor models, how to prepare, how to determine scope, comparisons of performance metrics, and considerations for evaluating model inputs.


New Capital Planning Expectations for Large Financial Institutions and What It Means For You

The Federal Reserve Board (FRB) recently released regulatory guidance outlining its capital planning expectations for large financial companies. The guidance addresses many areas of the capital planning process where regulators are looking for continued improvement within large bank holding companies and attempts to clarify differences in the Fed’s expectations based on firm size and complexity. The guidance is effective for the 2016 CCAR cycle.

The Federal Reserve has provided separate guidance for two different categories of large financial institutions:

  1. LISCC Firms1 and ‘Large and Complex’ firms were provided capital planning guidance under SR 15-18, and
  2. ‘Large and Noncomplex’ firms were provided capital planning guidance under SR 15-19.

SR 15-18 Summary

Specifically, SR 15-18 applies to firms that:

  • Are subject to the LISCC framework,
  • Have total consolidated assets of $250 billion or more, or
  • Have consolidated total on-balance sheet foreign exposure of $10 billion or more.

For the largest and most complex firms, the guidance clarifies expectations that have been previously communicated to firms, including through past Comprehensive Capital Analysis and Review (CCAR) exercises and related supervisory reviews.

SR 15-19 Summary

SR 15-19 applies to firms and ‘Large and Noncomplex’ institutions that:

  • Are not otherwise subject to the LISCC framework,
  • Have total consolidated assets between $50 billion and $250 billion, and
  • Have total consolidated on-balance-sheet foreign exposure of less than $10 billion.

Implications of these capital planning guidelines

Both sets of guidelines (SR 15-18 and SR 15-19) lay out the governance, risk management, internal controls, capital policy, scenario design, and projection methodology expectations relating to the capital planning process. They also lay out some important distinctions between the two institution types relating to how models and model risk management are expected to be used.

We summarize some of the key differences between what is required of these two institution types in the table below. 

Current 2017 LISCC Portfolio Firms

According to the Federal Reserve, here are the current LISCC firms:

  • American International Group, Inc.
  • Bank of America Corporation
  • The Bank of New York Mellon Corporation
  • Barclays PLC
  • Citigroup Inc.
  • Credit Suisse Group AG
  • Deutsche Bank AG
  • The Goldman Sachs Group, Inc.
  • JP Morgan Chase & Co.
  • Morgan Stanley
  • Prudential Financial, Inc.
  • State Street Corporation
  • UBS AG
  • Wells Fargo & Company

[1] Large Institution Supervision Coordinating Committee (LISCC) – the Board of Governors of the Federal Reserve has the responsibility for the supervision of systemically important financial institutions, including large bank holding companies, the U.S. operations of certain foreign banking organizations, and nonbank financial companies that are designated by the Financial Stability Oversight Council (FSOC) for supervision by the Board of Governors. A list of LISCC firms can be found at http://www.federalreserve.gov/bankinforeg/large-institution-supervision.htm.


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