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April 20, 2009 by Steve Williams Steve Williams

For Those About to RAROC

“If you applied even a partial capital charge to the banking industry for the $9 trillion in total securitizations, then the entire industry would be woefully undercapitalized and the largest banks would be sub-investment grade… A public debate about the capital banks require to navigate the modern day financial markets seems long overdue.”  –Comments from The Institutional Risk Advisor, 2008

As we sit here on a Monday, searching for glimmers of hope in a post-TARP world, does anyone think the banking industry has gained the wisdom and prowess necessary to avoid major financial crises in the future?

I was a young banker in the early 1990s, the last time a major “war against risk” was being waged in our industry. The S&L crisis had hit, FDICIA laws were passed and the acronym RAROC was coming to the fore.

This risk-based profitability framework that was started by Bankers Trust in the late 1970s promised to create wiser and more analytic bankers. As opposed to jumping willy nilly into new ventures or making dumb loans, bankers would scrutinize their risk-taking opportunities and only proceed if the transaction could jump over a hurdle rate on economic capital.

Young and idealistic, I immediately became a RAROC groupie. I built Lotus 123 spreadsheets to analyze loan portfolios, hung around at Sendero conferences and devoured books on chaos theory. “Yes,” I thought, “This new thinking and sophisticated tools will rid our industry of stupid decisions for once and for all!”

Yet, even as a 29-year old industry consultant, I can recall worrying about the need to change banks’ internal cultures to truly manage risk. Full of spit and fire, I wrote in a July 1993 editorial to the American Banker the following passionate plea:

The fundamental mission of a financial organization is balancing – balancing risk and return, deploying capital to appropriate transactions. But when this process is fragmented so the balancing dynamic cannot be tracked and bankers cannot learn from the outcomes of past decisions… the industry is consigned to a future of boom and bust.

Ahh, such a sage warning, but anyone can write about managing risk – it’s actually living up to risk management principles that’s hard to pull off. Although we witnessed the pain of Sarbanes Oxley paperwork and weighty new enterprise risk management (ERM) structures in most banks, our industry has clearly done a miserable job of slaying the risk dragon since the last banking crisis.

We’ve seen the large players fall under the weight of sophisticated stupidity in the form of complex securities, reinsurance and credit default contracts. We’ve seen liar loans anointed by government-sponsored risk models. At the same time, it hasn’t just been large banks that lost their RAROC mojo. For smaller banks, the explosion of construction lending is a dire symbol of sloppy risk-taking. Here’s how the story unfolded. From 1998 – 2008, construction loans in the banking industry knocked out a 16% average annual growth rate and increased by a whopping $500 billion. These loans became the lifeblood of small community banks. Competition heated up and soon these deals were being done with minimal spreads and fees. The watchword inside most banks was to not lose any deals to competitors, and price was the weapon of choice.

Sure, the community banks got growth, but they also ended up with one heck of a special assets challenge. During this same decade, delinquencies and non-accruals in bank construction portfolios jumped to an embarrassing 11.5% by the end of 1998.

Now let’s think about this experience from a Risk Adjusted Return On Capital perspective. If we assume an optimistic 50% recovery on the deals that went bad, our lifetime loss rates on this portfolio coupled with internal workout costs will clearly exceed any tiny spread we generated on this portfolio since their inception. RAROC would say the banking industry did nothing but destroy capital with its half trillion of new construction loans over the past decade.

Whether we like it or not, our industry is in for slower growth, but maybe this is yet another opportunity for smarter growth. Maybe another shot at risk management tools can act like a sip of sour wine, a nibble of stale cracker and quick confession to the priest – it’s time to try to be better bankers again.

It’s time to stop making RAROC some interesting topic at RMA conferences that no one would dare mention at their own loan committee. It’s time to rebuild those crusty, analytic teams that love to debate the merits of risk-taking at the top of their lungs. It’s time to line up accountabilities and incentives to put individual responsibility and ownership back into the business of taking risk.

Forget all the banal regulatory paperwork that gives us carpel tunnel. If our industry is truly going to take intelligent, calculated risks, there are a few key priorities:

  1. Culture, not models must drive RAROC – as Warren Buffet has famously been quoted, “Beware of geeks bearing formulas.” Today, RAROC activities sit at too low a level in banking organizations. There are three individuals who must drive RAROC – the CEO, CFO and Chief Credit Officer. Notice I didn’t say the head of Risk Management or Internal Audit. That’s because most folks in the organization won’t listen to their message that “the sky might be falling.” RAROC only gets attention if it’s evangelized by management involved in the heat of the day-to-day business. The CEO can drive the balancing of risk and return in the strategic planning process. The CFO can begin to integrate return on economic capital concepts into management reporting and profitability analytics. The Chief Credit Officer can dial this thinking into credit memorandums, loan pricing and portfolio reporting. Importantly, all three can help their organizations search for “canaries” – those macro warning signs that things have gotten too crazy. For instance, while many higher ups claim the housing bust was unforeseeable, a simple ratio of average home price to average household income has been revealing the impending bust for many years now. Skepticism about popular industry trends is one of the key requirements for bank executives.
  2. Pricing differently than market takes serious guts – during the boom times, there were some feeble attempts by our industry at loan pricing models. Remember how we would run the loan pricing model, see a rate 75bp above our competition, snicker at each other and price at 10bp below the competition? How surreal now to think that banks would be better off if they priced to the model and ended up with 80% less volume. It’s time to get serious about pricing to model instead of pricing to market.
  3. Public markets will always cajole us into destroying capital – one of the most serious strategic issues facing publicly traded banks is the incessant hunger for top-line revenue and earnings growth from Wall Street. Most cognitive psychologists say humans naturally overestimate return and underestimate risk – not the best genetics to build great bankers. When our industry collectively starts to under-price risk, pressure builds to meet new industry benchmarks for growth. Those banks managing risk start to look like stodgy ol’ codgers in their Lincoln Continentals listening to Mathis eight-track tapes. At times like this, it take the strongest analytics and the resolve of the board and management to prove the risk-takers wrong. It is a very difficult job convincing investors.

I’m fortunate to know a great banker named King Milling, former Vice Chairman of The Whitney Bank in New Orleans. A year or so ago he scrawled me an interesting note during a meeting:

As regards to the world of banking, strong competition arrives as the economy expands, resulting in a shift of leverage from the financial sector to the customer. Under these conditions, bankers become stupid over and over again.

King gets it. As we enter the post-TARP era, workout and compliance challenges will consume us for several years. The economy will start to get better. Spreads will be decent. Entrepreneurial business activity will start up again. Asset values may start to appreciate. Volumes will start to grow. Competition will heat up. And what about the banks’ pricing? Credit standards? Appetite for rate risk?

That’s up for the next generation of bankers to… hopefully… do a better job of this time.

So GonzoBankers, here’s an anthem to take with you on the post-TARP road. Picture Angus in the schoolboy outfit slinging the Gibson guitar and Brian’s ever-gravely voice:



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