Regulatory Scrutiny Focuses on Inadequate Strategic Planning

June 2015

Regulatory Scrutiny Focuses on Inadequate Strategic Planning

Once again, regulators are zeroing in on inadequate strategic and capital planning processes at many community banks.

The Office of the Comptroller of the Currency listed “strategic planning and execution” as its first supervisory priority for the second half of 2015 in its mid-cycle status report released in June. That echoes concerns from the OCC’s semiannual risk perspective, which found that strategic risk was high for many banks as they “struggle to implement their strategic plans effectively.”

FDIC Chairman Martin J. Gruenberg said in May that regulators expect banks “to have a strategic planning process to guide the direction and decisions of management and the board. I want to stress the word ‘process’ because we don’t just mean a piece of paper.”

He said that effective strategic planning “should be a dynamic process that is driven by the bank’s core mission, vision, and values. It should be based on a solid understanding of your current business model and risks and should involve proper due diligence and the allocation of sufficient resources before expanding into a new business line. Further, there should be frequent, objective follow-up on actual versus planned results.”

In writing about strategic risk, the Atlanta Federal Reserve’s supervision and regulation division said that “a sound strategic planning process is important for institutions of all sizes, although the nature of the process will vary by size and complexity.” The article noted that the process “should not result in a rigid, never-changing plan but should be nimble, regularly updated (at least annually) and capable of responding to risks and changing market conditions.”

Given economic changes and increased market competition, community banks must understand how to conduct effective strategic planning. This is more important now than ever, says Invictus Consulting Group Chairman Kamal Mustafa.

The smartest banks are using new analytics to develop their strategic plans – not because of regulatory pressure, but because it gives them an edge in the marketplace and a view of their banks they cannot otherwise see, Mustafa said.

“Strategic planning is useless without incorporating capital planning. The most effective capital planning is built from the results of stress testing.  These critical functions – strategic planning, capital planning and stress testing – must be integrated if a bank truly wants to understand its future,” he said.

He advises banks to use the same fundamental methodology for both capital planning and strategic planning, or else they will run the risk of getting misleading results.

OCC Deputy Comptroller for Supervision Darrin Benhart also advises community banks to use stress testing to determine if they have enough capital. “Boards also need to make sure the institution has adequate capital relative to all of its risks, and stress testing can help,” he said in a February speech.

“We also talk about the need to conduct stress testing to assess and inform those limits as bank management and the board make strategic decisions. The most valuable and often most difficult risk management decision is knowing when to say “no” because you have exceeded your risk limits,” he said.

Editor’s Note: Invictus has developed proprietary forward-looking risk analytics that focus on portfolio risk/reward. They show a very different pro forma picture of community bank performance than the traditional pre-recession methodologies used by community banks, researchers and M&A investment bankers. These new analytics, which are integrated with stress testing and capital planning, are an essential part of Invictus’ strategic planning advisory services.  

Banks Struggle with Strategic, Capital Plans

The OCC says that many community banks are struggling to “execute strategic and capital plans given the current operating environment.” Examiners want to make sure that bank boards and senior management have developed adequate strategic, capital and succession planning processes with realistic plans and appropriate risk controls.

Source: OCC mid-cycle status report, semi-annual risk perspective