Test advanced editor Flashcards
What is the key characteristic of a Special Mention loan?
Has potential weakness (vs. actual/well-defined) weakness; generally relates to the structure of a loan
Characteristics of a Special Mention Item
? Inadequate supervision of credit ? Questions on condition or control of collateral ? Economic/market conditions may unfavorably affect obligor in future ? A declining trend in financial condition ? Structure
What is the key characteristic of a Substandard loan?
Has well-defined weakness
What are the loan classifications?
Pass Criticized - Special Mention Classified – Substandard, Doubtful, Loss
Classification on Investment Security
CCC+ rated bond w/ impairment = SS – amort. cost SS – inadequately protected, well-defined weakness, institution will sustain some loss if not corrected Doubtful – same as above plus collection or liquidity in full is questionable Loss – uncollectible; should be promptly charged off
Consumer Retail Classification Matrix
Past Due 90 days 120 days 180 days Open-End Substandard Loss Closed-End Substandard Loss 1-4 Family and Substandard Loss (loan in Home Equity, excess of LTV > 60% collateral value)
What is required for a retail loan that secured by residential real estate?
Loans that are secured by residential real estate require a current assessment of value at 180 days past due (not the original value!)
Weighted-Classification Ratio For CAMELS-rated banks
Weightings of classification ratios: ? Substandard @ 20% ? Doubtful @ 50% ? Loss @ 100% ? Value Impaired @ Variable % (ATRR) Take weighted total and divide by Tier 1 Capital and the ALLL
Asset Quality CAMELS Rating Guidelines
Rating WCR 1 0 – 5% Strong 2 5 – 15% Satisfactory 3 15 – 30% Fair/Less than satisfactory 4 30 – 50% Deficient 5 > 50% Critically Deficient
Asset Quality ROCA Rating Guidelines
Rating WCR 1 0 – 0.5% Strong 2 0.5 – 1.5% Satisfactory 3 1.5 – 3.0% Fair/Less than satisfactory 4 3.0 – 5.0% Deficient 5 > 5.0% Critically Deficient
If ALLL methodology is sound, but implementation is faulty, is the reserve adequate?
Yes, the reserve is adequate
FAS 114
Standards for specific reserve; loan-by-loan review of impairment
What should the FAS 114 reserve methodology include?
Three measurement techniques: ? PV of expected CFs ? Observable market rate ? Estimated fair value of underlying collateral Reserve allowance is difference btw the book value and the result from above valuation
Methodology Reasonableness Test
Tests adequacy of reserves – results should be compared to bank’s internal methodology Formula: ? Deduct identified losses ? 50% of doubtful ? 15% of substandard
Where are Credit Losses booked?
B/S I/S Loans ALLL Provision Undrawn Commitments & Letters of Credit O/Liab O/Expense Derivatives O/Liab O/Income
Accounting for Provision to the ALLL
Dr. Provision (expense) $10,000 Cr. Reserve (contra asset) $10,000 Loans $1,000,000 Reserve (10,000) Net Loans 990,000
Accounting for a Loan Charge-off
Dr. Reserve $5,000 Cr. Loans $5,000 Loans $995,000 Reserve (5,000) Net Loans 990,000
Accounting for a Loan Recovery
Dr. Cash $1,000 Cr. Reserves $1,000 Loans $995,000 Reserves (6,000) Net Loans 989,000
Why is a loan designated as Nonaccrual?
The purpose of designating a loan nonaccrual is to distinguish between: ? Loans that are of sound quality and performing as agreed Versus ? Loans that are weak and unable to perform, or will be unable to perform as agreed
When should a loan be placed on Nonaccrual?
When full payment of principal and interest is no expected; the loan can be < 90 days if feel loan collection is in doubt
Accrual/nonaccrual decision tree – when can a loan be put on accrual when the principal or interest are 90 days or more past due?
When the loan is both well-secured and in process of collection
Calculating Troubled Debt Restructuring Original bal. = $500,000 Paid down = $350,000 Recorded/accrued interest = $20,000 Modified note = $350,000 Due in 1 yr., interest rate = 4%
- Calculate the recorded amt. of the loan Principal bal. at restructuring $350,000 Accrued interest (to maturity) 20,000 Less any unamort. principal 0 Add any unaccreted discount 0 Deduct any charge-off netted 0
What credit score is considered subprime?
660
When is an appraisal not required?
? In which value is $250,000 or less ? A business loan with value of $1M or less and not dependent on the sale of, or rental income from, real estate as the primary repayment source ? Subsequent transactions resulting from an existing extension of credit
What are the supervisory Loan-to-Value limits?
Loan Category LTV limit Raw land…………………………..65% Land development…………………75% Construction Commercial, multifamily, & other nonresidential……….80%
What is Other Real Estate?
? Real property other than premises owned or controlled by the bank ? Usually acquired in satisfaction of a debt previously contracted ? Can also be: o Property formerly used for bank business o Originally acquired for expansion
What is required for ORE accounting?
? Should be booked at ORE upon physical possession ? Amount booked should be lesser of o Fair value less estimated costs of sale o Recorded amt. of loan plus any senior debt on the property ? Loss on loan, including costs, must be charged to ALLL at time of foreclosure
How is a lien perfected?
SAPS ? Search: UCC-11, search country records for previous ownership of collateral ? Attach: security agreement in coordination with promissory note ? Perfect: UCC-1 (Financing Stmt) filing ? Search: perform another UCC-11 search to ensure
What are the bankruptcy code chapters?
Chapter 7 – liquidation of debtor’s assets and distribution among creditors Chapter 11, 12, 13 – Reorganization ? Chap. 11 – Bus/ Indivs. that do not have steady income stream ? Chap. 12 – Farmers and farm family ? Chap. 13 – Wage earners & their proprietorships
Who determines Legal Lending limits?
? Established by laws of the state where bank’s headquarters is located ? National banks are subject to lending limits set forth in 12 USC 84
What is the Cash Coverage Ratio?
Net Cash from Operating Activities Financing Costs* + CPLTD** *Including interest expense, dividends **Current portion of LTD @ the end of the prior year Should be greater than 1
How do you calculate Cash After Debt Amortization?
Net Cash from Operating Activities - Financing Costs = Net Cash Income - CPLTD = Cash After Debt Amortization
Define Interest Rate Risk
The exposure of current and future earnings and capital arising from adverse movements in interest rates
What are the four forms of IRR?
Mismatch/Repricing risk Yield curve risk Basis risk Options risk
Who manages IRR?
Asset-Liability Committee (ALCO) Treasury Department Risk Manager Internal Audit
What are the most common IRR models?
Re-pricing Gap Income simulation/Earnings-at-Risk (EAR) Economic Value of Equity (EVE)
What does the Re-pricing Gap model capture?
Mismatch/Repricing risk
What are the key assumptions of the Repricing Gap model?
? All repricing within a specific time bucket occurs simultaneously ? Slotting assets, liabilities and OBS items based on the first repricing interval ? All maturing assets and liabilities are reinvested at overnight rates
What are the positives and negatives of the Repricing Gap model?
? Positives o Easy to produce and understand o Inexpensive o Clearly illustrates repricing gaps ? Negatives o Static, ST perspective
Asset Sensitive v. Liability Sensitive
Rates Asset Sensitive Liability Sensitive Increase + - Decrease - +
What does the Income Simulation/EAR model simulate?
A bank’s exposure to loss of earnings over a period of time
What are the key assumptions of the Income Simulation/EAR model?
? The BS is used to project earning is accurate ? Selected interest rate scenarios are robust ? New business will product expected results ? Runoff schedules and prepayment speeds are accurate ? Core deposit behavior is realistic
What is the key negative of the Income Simulation/EAR model?
? Not a reliable estimate of LT risk exposure
What does EVE calculate?
? PV of CFs from assets, liabilities, and OBS items based on a forecasted change in interest rates ? EVE = PV of assets – PV of liabs. +/- OBS
IRR Models: Strengths and Weaknesses
Criteria Gap Simulation EVE ST Exposure Yes Yes NA LT Exposure Yes No Yes Repricing Yes Yes Yes Basis No Can Can Yield Curve No Can Can
What are three types of rate scenarios?
? Shocks – Take base curve +/- 100 bps, 200 bps, and 300 bps ? Historical – analyze real life stress periods, adjust base case curve to mimic actual rate changes ? Hypothetical – macro-economically plausible ‘what if’ scenarios
At a minimum, what rate scenario must the bank look at?
At a minimum, the bank must look at instantaneous +/- 200 bps parallel shift in market rates
What does the ‘S’ component consider?
? Quality of Risk Mgmt – The ability of management to identify, measure, monitor, and control risk ? Market Risk Exposure – Give the bank’s size, complexity, and the adequacy of capital and earnings
Describe the 5 levels of rating for the ‘S’ component
1 – IRR sensitivity well controlled, min. potential that earnings/ capital will be adversely affected. RM is strong. Earnings /capital provide substantial support. 2 – IRR sensitivity is adequately controlled, moderate potential earnings/capital will be adversely affected. RM is satisfactory. Earnings/ capital provide adequate support 3 – IRR needs improvement or that there is significant potential earnings/capital will be adversely affected. RM need to be
What can be determined from the Balance Sheet?
Whether the bank has enough liquidity to handle a crisis
Net non-core funding dependence
= Net non-core funding – ST inv Loans, ORE, and Securities > 1 yr. Negative ratio is favorable Positive ratio means bank is relying too much on volatile liabilities
The Parent Company must …
Serve as the Source of Strength!
Double Leverage Ratio
= Equity Invested in Subs Parent Co Equity Capital If > 120%, too big
What is expected from the Board of Directors in managing Market Risk?
? Approving policies, procedures, and strategies ? Liquidity risk profile ? Identifying executive level lines of authority ? Monitoring performance periodically ? Reviewing contingency funding plans
What is required in a contingency funding plan?
? Triggers ? Roles and responsibilities ? Scenario analysis ? Alternate funding sources
What are early signs of a liquidity problem?
? Deterioration in asset quality ? Changes in fund providers ? Decreased size of individual transactions ? Difficulty accessing longer-term maturities ? Increased pricing costs, increased Loan/Deposit ? Changing markets
Who is an insider?
? Directors ? Principal Shareholders ? Executive Officers ? Policymakers ? Related interests (business owners and immediate family that resides in house)
When is a shareholder a “principal” shareholder?
Must own >= 10% of stock for control
Which of these is a principal shareholder – (a) Bob owns 7% of the bank and his ex-wife Rachel who remarried and moved away owns 7% (b) Rachel owns 7% of the bank. Her daughter Sarah who owns 4% is staying with her while she looks for a job (c) Paul owns 6% of the bank. He is the 10% owner and managing partner of a law firm which owns 5% of the
a) No b) Yes c) Yes
What are the two categories of related interests?
1) Business which they control (25% is automatically control of business) 2) Immediate family living in house
When is an individual considered to have a controlling interest in a bank? In a company?
10%, 25%
What loan credit criteria apply to all loans made to insiders?
Must be same terms as loan to independent 3rd party
What loan pricing criteria apply to most loans make to insiders?
Same as the general public
What loan pricing exception is permitted?
Insider can receive the same discounts as all insiders
Who is an executive officer?
Treasurer President Corporate Secretary VP (unless Board Resolution to not included VPs)
How much can a bank lend to its executive officers?
Up to $100,000
What two types of loans to executive officers don’t count against the lending limit?
Loans for a home (1st Mortgage) or education
When is an overdraft a violation of Regulation O?
When there is no preliminary agreement and it is over $1000
What is a BHC?
A company (bank, corporation, or business trust) that has control (>= 25% of voting shares) of a bank
What is the largest asset on a BHC’s balance sheet?
Investment in bank subsidiary
What is the main expense on a BHC’s income statement?
Interest on debt
Originally, what activities were BHC’s allowed to engage in?
Activities closely related to banking (i.e. loans, securities, mortgage lending)
What is a chain banking organization?
2 or more banks controlled by the same individual or related interests
Which FR regulation implemented the BHC Act and Change in Bank Control Act of 1978?
Regulation Y
What is the primary advantage of a BHC?
Provides financial flexibility ? Consolidated tax returns ? Tax advantage to bank subs ? Treasury stock (repurchase) Wider investment powers Centralization of operations
What is a BHC allowed to charge for operations?
No more than a 3rd party – used to determine that method for allocating costs is appropriate
What is the primary “doctrine” for BHCs?
To serve as a source of strength to is subsidiaries
What is the Gramm-Leach Bliley Act of 1999?
? Allowed banks to be affiliated with securities firms and insurance companies ? Preserve separation of banking & commerce – allows activities “financial in nature” ? Held to higher standard (well-cap., well-managed, satisfactory CRA rating)
What are disadvantages of a BHC?
? Additional FR regulations and inspections ? Additional filings (FR-Y) ? Possible securities law regulations ? Possible dealings with minority shareholders
What are the four subcomponents of the “R” in the BHC rating system?
? Board and Sr. Mgmt. oversight ? Policies, procedures, and limits ? Risk monitoring and MIS ? Internal controls (this rating is “forward looking”)
What are the four subcomponents of the “F” in the BHC rating system?
? Capital ? Asset quality ? Earnings ? Liquidity (this rating is “point in time”)
What does the “I” for the BHC rating system capture?
? Assesses the impact of nondepository entities on the depository subs (includes Parent and all nondep. subs)
What is the rating scale for “I” of the BHC Rating System?
? Low likelihood of significant negative impact ? Limited likelihood ? Moderate likelihood ? Considerable likelihood ? High likelihood
How can a BHC have an adverse effect on bank subs?
? Excessive risk and fail ? Adverse intercompany transactions and excessive dividends
What should be considered for “I” of the BHC Rating System?
? Is capital adequately distributed across all subs? ? Do intra-group exposures undermine condition of banks? ? Is parent cash flow dependent on excessive dividends? ? Impact of strategic growth plan, op losses or poor control environment of parent/nonbanks ? Legal/Rep risk of parent and non-banks
What is included in the “C” component of the BHC Rating System?
? Overall assessment ? Forward-looking and static assessment of consolidated BHC ? Not a numeric average
What is included in the “D” component of the BHC Rating System?
? “D” stands outside of composite rating ? Use primary/functional regulator’s rating ? For multi-bank holding company, weighted average of composite ratings