Credit Union Exam Solutions Presents With Flying Colors

Treichel: Hey everyone.

This is Mark with a special archive
episode of With Flying Colors.

I hope you enjoy.

Today I'm going to chat with
Todd Miller of my team, and this

episode is called Alco in Practice.

Essential reports, analysis
and a risk management.

Todd has tremendous, uh, background
in this, including being a director

of special actions and examiner
a capital market specialist

and supervising the entire West
coast's one third of the country's

capital market specialist at NCUA.

So, Todd, last week we discussed Alco
governance essentials and building an

effective committee structure, who should
be on the committee, et cetera, et cetera.

Now we're gonna pivot to a
LM or ALCO reporting and, you

know, policies, et cetera.

So with that, I'm gonna give you
free reign to share your wisdom.

So this should be all
laid out in policies.

I'm gonna go through some general things
and, um, that I think should be part

of most ALCO report packages and part
of most al alcohol's functionings.

This shouldn't be intended to
be an inclusive list, that this

are the only things you need.

If you wanna add other
reports, feel free to do that.

Some of this is how do you lay out your
business plan and how does the board

lay out performance, key performance
indicators and key risk indicators.

So this can change it a little bit,
but I'm gonna lay out what I think is.

Should be in a typical Elco package,
and some of what I lay out here might

not be in the package every month.

It might be in once a quarter.

We'll even talk about model validation
is that might only have to occur a

couple times a year, but we'll go
through just some general things

that I think should be in most Elco
packages out there, even though it's

not in an exhaustible inclusive list.

First one, credit unions operate
in an environment out there.

So somewhere within our Elco and
our organization, we should have

some basic economic data that we're
keeping track of what's going on

nationally and more important what's
going on locally when, especially

with managing credit risk, what's
happening in our local housing market?

If you're a business lender,
what's happening in our local

commercial real estate market?

What are employment trends within our
local area and our fields of membership?

Um, there should be just some general
economic information that's shared across

the committee because they're gonna
be determining tactics, strategies,

and well, credit union should not
make huge bets on the economy.

They do have to take a position
and make reasonable decisions on.

How they're gonna operate their lending
and investment programs, their deposit

gathering programs, and that's going to
be influenced by their local economic

factors or their expectations of which
direction the economy is gonna go.

And you, you can't really manage
any risk out within the organization

unless you have some basic information
about your financial statements

and your budgets and how are you
doing on budgets and comparisons.

Along that line, they're the
biggest ones that responsible.

How do we address
variances in our budgets?

Do we need to change strategy?

Do we need to change topics?

Do we need to change pricing if things
aren't going as the board expects?

I'm a big believer in
compliance dashboards.

Um, and within this,
there's lots of things.

So there's key performance,
syndicators, key risk indicators.

NCA gives you an exam report.

It has key ratios.

I do think each board, as they lay out
their business plans, they should lay out

what are the key performance indicators
and key risk indicators bring down.

And that strategic plan, you can get
really carried away with these, uh,

and maybe overburden the community,
but you also need to have enough what's

going on with each of those risk areas
in the organization and how the way to

measure your performance against your
strategic and business plans within

those performance indicators and.

I'm a big believer that especially
concentration risk is important for

most organizations, and I think a lot
of organizations, they will have these

types of ratios, but they're spread out.

I really think to be effective with
analco and even for boards of directors,

and we've talked about board governance
before, that these compliance numbers

really need to be put in one spot where
people can see them all in one place.

Liquidity reports and there's
different kinds of liquidity reports.

A lot of people use historical
measures for liquidity, and I think

that's fine for compliance purposes.

Uh, for an ALCO type, someone
who's responsible for managing

liquidity and interest rate risk,
they need cash flow forecasts.

And especially they need to be
looking at them out there three to

six months from now, how are we gonna
be deploying the funds available

to us into loans and investments?

How are we gonna be
gathering up those deposits?

What's our risk of deposits losing
what's going on with our borrowed money?

Those become very
important indicators Then.

I'll just throw something else out here.

Some alcoves, they will get reports
like this from various places.

Well, they might generate an
in-house cashflow forecast.

Their A LM vendor might
give them another one.

And you'll see some of this with
interest rate risk reports too.

They'll get 'em from multiple vendors.

I'm a big believer there needs
to be one version of the truth

though in the organization.

And which of these reports
are you going to use?

It's not, let's use this one today.

This other one tomorrow, which
everyone makes us look good.

Let's lay out in policy, which
of these reports is gonna

be our decision making tool.

We can use other reports as a
model validation type thing,

another source of information.

But you do have to be careful that you
have one version of the truth going on.

We've seen clients written up for this,
especially with in their loan portfolio,

in their credit risk management.

They have different systems giving
them different versions of the truth.

What does that say about your
organization when you have

different versions of the truth?

It's not looks well, it doesn't
necessarily look very well when

you have different versions of the
truth Inside the organization is

cashflow Reports very important.

Uh, interest rate risk reports.

This is traditionally
the role of the alco.

How, what does our net interest
income and what does our NAV numbers

look like under various scenarios?

Card unions typically don't do these
every month unless you're really large.

The quarterly is quite common along
the lines with the interest rate

risk report at the elco level.

Elco members need to have a good
general understanding of the model

assumptions in those reports.

Do they need to see all 2000
of 'em that are in a report?

No, but they do need to have a good
general understanding which assumptions

move the numbers the most, and at
least occasionally they need to have

some good documentation of what those
numbers and those assumptions look like.

And that Alco should be actively
involved in establishing change control

procedures for those um, numbers.

It's an important piece and examiners
will criticize, uh, credit unions

at the Elco level if they don't
have a good handle around what

those model assumptions might be.

Investment portfolios in C'S regulation
lays out here is required investment

reports tickly those flow to Elco.

It's pretty common for Elco
to actually be the party that.

Step's investment strategy
inside that business plan.

Based on other things that are going on.

There should be some good reports
related to that whole investment

portfolio and their analysis.

Another piece of this, and
credit unions will hear this

all the time from examiners.

They want scenario and sensitivity
testing of their models back

testing of liquidity models.

I think that scenario and sensitivity
analysis is an important piece of this.

Like I said, members of the Alco
committee, they should know which

variables will move these numbers the most
and which ones they need to pay attention

to in terms of their member behavior.

The scenario analysis, it's really
important for your capital planning

and building your whole strategic plan.

What does our results look like
if A happens or if B happens?

Do we wanna have our loan portfolio
be 60% real estate and 40% consumer,

or do we wanna be a business lender?

We're it's 60% business loans
and 20% consumer loans and

20% residential real estate.

Those things make a difference
and credit union need to build

those into scenario analysis.

What happens if.

What happens if all these CDs that we've
gathered up in the last couple years walk

back out the door, we can't replace them.

What happens if our whole
deposit structure changes?

Those types of things should be laid
out in scenario analysis, especially as

we're building up our business plans.

Increasingly, we're seeing, and
the examiners ask credit ease to

stress test their loan portfolios.

This is a new thing.

To credit unions, it's not a new thing.

In fact, the first time I seen the
stress test was way back in the 1990s.

They had an egg lender where they had
an in-house database where they could

actually just change the price of
commodities and it would spit out, here's

all your farmers that were not gonna
make money or make money under this.

And that was way back in 1990.

Um, so it's not a new thing, but it's
new that examiners are increasingly.

Asking credit unions to do these
stressed and scenario analysis on their

loan portfolio, especially if they
have concentrations of number business

loans, because everyone's reading
that commercial real estate buildings

are empty or less full than they
used to be in certain markets though.

But scenario type of testing and
analysis, it informs your decision

making in a very positive way.

Another key part of Alco and sometimes
Alco delegates this, but I think Elco

really needs to stay on top of it, and
that's your pricing decisions, support.

How do we price our assets and how
are and liabilities and what are we

going to use to base that pricing on?

Now just about he, Carine will
have surveys, what a competitors

have for loan and share rates, but.

If you follow competitors, you're
gonna get their results and

their expenses and capital might
be very different than yours.

So I think you need just a little
bit more than that, and it's where,

here's an analysis of the yields
and returns and our loan portfolio.

Here's analysis of our cost of
funds, here's our analysis of our

borrowing and deposit structure.

You don't see this very often,
but I think it's very critical

is what's our marginal cost.

In marginal yields so many times as a
problem, case officer and a director

of special actions, you get into
institutions that have earnings problems.

And what you really find out is they've
mispriced things, they price things to

meet the competition, but it doesn't
meet the needs of the institution.

And if you go back to the last
recession in 2008 before Covid hit.

A lot of the folks had problems is
because they followed the market in terms

of pricing loans in the entire market.

Underpriced for risk, and you wanna
have control of that decision or not.

And cost accounting
systems come into this.

It really depends on size and complexity,
but in general, you need a good pricing

decision, support set of reports,
whatever that might be for your

organization that you need to understand.

'cause pricing decisions, even
through the last little bit here,

when interest rates shot up, a lot
of card unions got into some earnings

issues for us short period of time.

Most of them adjusted pretty
well and have adjusted today.

But there are still some that are
still having some challenging issues

with earnings because they made
poor pricing decisions in the past.

Before that even hit.

This isn't in all Alco, but I do think
more and more it's becoming a big piece

of Alco is they need a comprehensive
set of credit risk management reports.

Now, do they need to be having discussions
at Alco about individual borrowers?

No.

Should they have a general idea of
what's going on in their loan portfolios?

Absolutely, yes.

How do you build that out so you
don't cross the line into getting

into the weaves, so to speak?

That becomes an individual credit union's
kind of challenge, but I do think in

general it's very hard for a credit
union to manage liquidity and interest

rate risk without assessing credit risk.

I just don't see how you
can manage those two without

having a handle on credit risk.

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But that's Todd Miller's take on Alco
and that they need to have control of

that credit risk assessment as well.

Agendas and minutes
are really a key thing.

The way I would lay out, what
does your agenda in minutes do

and what should they accomplish?

They should make it really transparent.

What you're using to make
decisions, the decisions you

made, why decisions were made.

And if you've got adverse trends, why
are you not doing nothing about it?

Some credit, ENC, things not
going the way they're on.

And I, okay, we'll just watch
that for a while, but we're

not gonna change anything.

Your minutes should really
be transparent that you.

Made that decision intentionally
and did so for specific reasons.

Um, it, I think a lot of places miss this.

They have their agenda.

They don't put a thought into it.

I think trend reporting is a big
piece of this in getting it right.

We have one, we have more than one client.

They'll rate their risk categories
and you should put that on the agenda.

Liquidity risk this month,
right on the agenda.

Moderate, increasing, moderate,
stable, high, increasing, high stable.

Like really where you spend your time
should get dictated by where your risk

is at and where your risk is going.

Uh, so those are critical things
to me and a lot of times when you

get issues with examiners question,
questioning a credit union decision.

It's because as they go through their
exam process and they read your minutes

and they look at your reports, it's
not clear and transparent to them what

decisions you made and why you made them.

So it, it's critical that you lay out
in your minutes, your alco minutes

that we made these decisions for these
reasons we weren't operating in a vacuum.

You can avoid a lot of
issues with your examiners.

From a board governance perspective,
it should be clear and transparent.

So if your board picks up these
minutes and looks through it,

they should be able to understand
why you did what you did with the

authority they've given you as well.

So you don't do it just for the
examiners, you do it for the benefit

of the organization, and it's the way
you keep everyone on the same page.

It's really unfortunate.

There's a few times.

We've been involved with credit unions
that end up in court and with the vendor.

They end up in court because of a qo.

They end up in court
because of some investment.

Broker did something to them and you
start deposing people and it's, they don't

remember why and they look at their own
minutes and it's, why did you do that?

I don't remember.

I don't know.

That's really not a good place to be in as
an organization when you don't understand

why you made the decisions you made.

So that kind of covers the reporting.

I just wanna talk about model risk a
little bit in line with the reporting,

because a lot of what Alco has done,
does and bases their decision on are

based on forward-looking models, be
that capital forecast, interest rate,

risk models, all this scenario stuff
we talked about in sensitivity testing.

Those are all done as part of
forward looking models, credit

stresses on your loan portfolio.

That's all models.

Model risk is something that
is a challenge for everyone.

I do think for Alco committees, committee
members need a general understanding of

key assumptions In all of these models,
if they're basing decisions on them,

they should have a basic understanding.

Do they need to be an expert on
the model and know everything?

No, but they should have a
good general understanding.

Um, the second piece of
this is model validations.

And this happens in different places
in different size credit unions on

some really large credit unions.

It's a whole separate function of
internal audit and the ERM process.

In smaller credit unions, it actually
falls a lot of times to the Alco

committee itself to validate their
own models, and sometimes it's even

down to the finance department to just
validate their own cash flow forecast.

It doesn't really.

There's right, there's different
answers to who handles model validation

in a different size organization.

The point I wanna make is community
members should be comfortable with

efforts made to validate their models.

How frequently do we do
it within an organization?

From a governance perspectives, it can be
happening in different departments and be

driven by different people, but at the end
of the day, the folks using those models

to make decisions should be comfortable.

With what their organization has done
to validate those critical models

and make sure they're accurate.

That covers most of what I have to say.

I think that gives people a good
general understanding of things.

Maybe any one of these days, you
can get another person to do a

podcast just on the whole credit risk
reporting piece of it, because it

can be as big as the other pieces.

And I think it's an ever-growing important
piece and we see more and more examiners.

Want justification for concentration
risks, whether that's in your

investment portfolio, loan portfolio.

NCUA hasn't really talked about liability
concentrations, but I guarantee you

it will be coming in the future on
their part as they get comfortable with

their whole concentration risk on the
asset side of the balance sheet today.

Todd, as you're talking through that,
I'm envisioning a couple d, you know,

different listeners, not specific people,
but someone out for a walk listening

to this on their iPhone versus someone
sitting at their laptop versus someone

driving in their car and they're you.

You had so much information
packed in there.

I know that some of the listeners
are gonna go, when I get to my

laptop, I need to re-listen to
this and I need to take some notes.

And when I get to my laptop,
I need to forward this episode

just to my committee, et cetera.

'cause there was just
tons of information there.

I wrote a lot of different things down.

And the listeners can't see this,
but you might not even be, if

I hold it here, you can see it.

I got two different pins.

I got a, a black one and a red one.

And.

As you were talking on some things that
I wanted to, I didn't wanna interrupt

you 'cause I didn't wanna break
your flow 'cause that was fabulous.

But I wrote a couple different
things down that linked to

things that it triggered for me.

I'm gonna walk through some of those.

I'm gonna ramble with some of those
and then you can pivot and see

if there's anything that I said
that that you wanna respond to.

So you talked about stress
testing and everybody's hearing

that there's empty buildings.

And that's a type of commercial load
risk and that you need to have better

tools that are doing stress testing.

And I believe we've given guidance and
or NCUA has criticized credit unions that

when you're doing that stress testing,
you don't wanna just stress commercial

over here and then stress real estate,
residential real estate over here

and then stress your visa over here.

Then stress your deposits over here.

There needs to be some sort of cascading
effect where you might, you might

stress two factors or three factors.

That was one thing I wanted to mention.

And there we, I also wanna mention
that we have a separate, you

and I did a separate podcast.

With the sole topic of model risk.

And so if someone is listening and you
wanna hear more about what Todd said

relative to model risk, I think we
probably have a 20 or 30 minute podcast

that we did specifically on model risk
scenario and sensitivity analysis.

I think if I'm linking this right
to some of our conversations.

We've had situations where a documented
resolution or an examiner finding was

given to a credit union where they said
that you need to update those and you

need to be reevaluating those things
and careful what you ask for in CA is

what we've seen because people have
come through this cycle and they have.

Reevaluate, uh, what the reality is
and then projecting that forward.

And I'm gonna get some of this
wrong, but I think you're gonna get

the point I've trying to make here.

But when NCA asked you to do some back
testing, that back testing sometimes

will actually work the opposite of what
NCA thought and your assumptions might.

Show that your deposits are more sticky.

So that's something that I wanted
to throw out there to governance.

Many of these things, if any,
NCA, you hit on governance at a

covered couple different points.

We have a separate podcast on governance.

We are seeing NCA almost
link every examiner fighting.

Maybe not examiner fighting,
but document resolution If NCA

is unhappy about something that
happened since the last exam.

They seem to always now link it
back to corporate governance, which

makes some sense in most instances.

But it just impresses upon me that
the corporate governance is even

more important that it's ever been.

I've said in another podcast, it
almost seems like it's done training

on a national level or pointed out
that they need to do this 'cause

we're seeing it so consistently.

And then here's my last comment and
then I'll let you respond to any of

these that you might might want to What?

Going back to what I was actually
doing, exams, you go in and.

NSU A doesn't do an audit.

There's the supervisor committee
or the CPA audit, but you'd have

your regular trial balance and
you'd loans totaled up to $15.24179

million, and you'd compare that
to the regular loan trial balance.

Then you'd have the visa trial
balance, which was different.

Then you'd have the commercial loan trial
balance, which might have been different.

Then you might have the real estate
loan trial balance, and then on

top of that, you've got these.

Big systems that credit Union seems to
have some time where they, where they're

doing analysis and loss analysis, and I
don't wanna name particular companies,

but there are other vendors out there
that will provide these other analysis.

And we saw in some situations where an
examiner said, Hey, you have all this a

LM stuff that says that this loan type
is X at the end of March and it's off by.

$4,000 on a multimillion dollar
program because its purpose

isn't to be that trial balance.

And in, in that instance, we gave some
guidance to this credit union that they

might wanna get those a LM reports as
of April instead of as, as of March,

so that the examiner doesn't try and
link it back to their call report.

And there's no requirement that
those a LM reports be linked.

I think you might have said, even you've
seen some situations, so there's a lot

of workload tied to that for that vendor.

The vendor might give you a discount.

Not only do you have the avid
advantage of NCA, not trying to link

it to something that it shouldn't,
and that doesn't happen that often.

That was really more of
a one-off, but all right.

Those are the brain dump of what I wrote
and read on different things I wanted to

mention relative to the notes I have here.

Did that any of that trigger any, uh,
clarification or follow ups from what I

said that you might want to add there?

I think I'll respond to all of them just
briefly and we will do the last one first.

Balancing reports, and this is back to
my one version of the truth type thing.

You do need within your organization
processes to reconcile reports.

Now, you might run credit risk,
things that might be done at a

mid bunt or not a quarter end.

You built this workflow in
there and most organizations

now have large data warehouses.

Information is lodged in
a couple different places.

It might be off a little
bit for ER accounting.

Reports, and it's probably okay for them
to be off a little bit, but examiners

just wanna reconcile things to the penny.

I mean, that's just a waste of
their time when you're in a one or

two or a $5 billion organization or
even a $500 million organization.

But Freddy and themselves should
have internal controls to reconcile

these different reports and
make sure they're appropriate.

A LM reports your a LM
people capital markets.

Who's ever looking at a LM?

Uh, I always looked at them and
tied them to a balance sheet.

The, these roughly look good.

Okay.

Within, and this happens almost all
the time within your loan type codes

in your vendors, a LM type codes.

Sometimes things just don't map exactly.

Small errors never bothered me.

Simple things were investment
securities where you know exactly what

the balance is on exactly that day.

Those should tie exactly every
time, and it didn't happen often

in my career, but it, it did happen
once or twice where there were

material errors in an A LM model.

In some of this was intentional on the
part of the card, not giving their vendor

actually accurate information about
certain items on their balance sheet.

NCUA tends to wanna reconcile this
stuff to the penny because even though

they don't catch very much fraud, it's
usually caught other ways by internal

audit or an employee writing out
another employee or caught by accident.

But a lot of times when NCUA
does catch fraud, it is because

these reports don't reconcile.

Or they'll see strange things as they get
their share loan download, and that's not

tying with a general ledger or there's a.

Funky account within that trial balance
that's been used to hide errors.

So that's why MCUA is sensitive to that
issue is because the frauds they have

caught, it's been caught for that reason,
not the point of our thing here today.

We'll go back to sensitivity
scenario analysis.

You see this a lot in exam reports.

They want you to beep up
sensitivity scenario analysis.

As an Elko though, you need to keep
in mind those are two totally separate

things, even though examiners often
use the words interchangeably.

Sensitivity analysis is about
determining which factors move

those model results the most and
which assumptions move it the most.

Scenario analysis, you're trying
to figure out what could or might

happen under different conditions.

It's not related to you.

Those core basic assumptions at
all two very different purposes.

We go back to this credit modeling
and you mentioned where we stress

this credit portfolio, real estate,
differently from the consumer, differently

from the residential real estate.

And yeah, they're done differently,
but more and more years theme

for credit unions to really
justify their capital adequacy.

They're almost going down
to a capital planning path.

And so you get into the ones credit
unions and they're over 10 billion.

They're required to do this combined
stress test and the Federal Reserve even

sets the conditions for those stress.

And here's what the interest
rate scenario's gonna look like.

Here's what the economy's gonna look like.

Um, those are very technical and very
precise, but I think for a lot of

credit unions, the scenario analysis
and different conation levels.

They can do that on a less precise
way and probably need to do a combined

analysis of some of these stresses to
determine if their capital is adequate.

You have regulatorily
required capital levels.

The reality is in many marketplaces,
and depending on the way your

balance sheet structured is those
regulatory capital levels are

probably not sufficient for you.

To be competitive and optimal.

You serve your members, you're
gonna need more capital than that

regulatory capital in the real world.

And as your competitors have more
capital, you're gonna need more

capital to keep up with them.

Yeah.

And capital planning is a necessary
part of every organization.

And.

I can see a day where these required
tests for 10 billion getting moved

down to credit unions at 5 billion,
and examiners are gonna start wanting

people at 1 billion to do it, even
though the reg might not require it.

It's just an evolution that examiners go
through where best practices, they tend

to filter it down to smaller and smaller
organizations, and I don't necessarily

see that as a bad thing in many ways.

It's a good thing.

And I just started out the whole thing.

Large organizations have committee
charters and small organizations put

it in policy, and I said, even these
small organizations, you should think

about having committee charters.

So it's just a natural
evolution of things.

So I think more and more you're gonna
see examiners push organizations of

all size to go to a comprehensive
capital planning type, and we

help people out with some of that.

You see it consistently in exam reports.

They want support for concentration
risk, which is really another way to say,

prove you have enough capital to do this,
which is the, uh, other side of the coin.

Which words do you use?

Prove you have enough capital or prove
you can support your concentration risk?

It's the same question,
just different sides to it.

Did I hit all the points you had
written down there and you did.

You did fabulous.

Yeah.

You hit 'em all.

I have different color pens too and I have
notes and I always say I'm gonna check

off on my notes when I address something.

But I get talking and I never do.

So I make and then I just don't really
look at very much star he are podcast

that, that just makes me smile too.

'cause it reminds me of my dad.

I used to go to a lot of
race horse races with my dad.

He had the daily racing form and he
had four different colored highlighters

and he had three different colored
pens and everyone meant something.

And then you'd get there, you'd
do all your handicapping, which is

almost as fun as going to the race.

And then you'd get there and you'd see
the odds and you'd do something different.

Then you'd go back and you'd look at in
blue, he, he said he wanted blue as his

top horse, for example, in each race.

And then you only went with
that like half the time.

You'd go home and you'd do the debrief
of the, all that color coding and,

and you'd realize that you were
onto something you just needed to

follow with your convictions and
the assumptions you had going in.

So that's a total sack word to this.

But all that color code
made me think of that.

So that made my heart smile.

Alright, Todd, so what else as we
wrap this up, is there any final

thoughts you wanna make relative
to, to what we've discussed here?

No, I think we'll just go reiterate
something at the beginning.

There's no one right answer for
all of this that you're trying to

accomplish the same general things,
but really you make all this fit in

work within your corporate culture.

It's all part of your corporate culture.

You build this around the knowledge,
skills, and abilities of your staff and.

A good reason to do this and have
this in a very formal way is it

improves the knowledge, skills, and
abilities of the rest of your staff.

And I guess that kind of leads to one
thing that examiners do bring this

up occasionally, is it's important to
continue the training of all your staff.

That they have ongoing training and
various areas that they're responsible for

listening to our podcast as part of that.

But um, that's right.

That's right.

That is an important piece for and be
members, and it's an important piece

for any organization that you dedicate
resources to improving those knowledge,

skills, abilities of your staff members.

Fantastic.

This is gonna be an
instant classic episode.

I got a feeling that, uh, that
people are again, gonna wanna

listen to this more than once.

There's a lot of really good advice
and counsel in this and I, I wanna

thank you for your time today, Todd.

It was my pleasure, mark.

I enjoyed doing these.

These are fun.

These are very fun and listeners,
I want to thank you for listening.

I hope you'll listen again soon.

This is Mark TriCal signing
off with Flying Colors.