A new study by financial information firm Sageworks has revealed what gets the most attention from examiners of credit unions and other regulated financial institutions.
The Raleigh, N.C.-based firm surveyed representatives from 180 financial institutions about their most recent federal examinations. The respondents included chief executives, chief financial and credit officers, credit analysts, compliance and risk management staff, and third-party consultants involved in examinations.
Asset quality, sensitivity to market risk and capital adequacy were examiners’ largest areas of focus, according to the study; for NCUA-examined respondents, liquidity was also an attention-getter.
NCUA-examined institutions comprised 14% of the respondents. None of these institutions had more than $10 billion in assets, and 60% had less than $500 million in assets. About half of all the respondents had total assets of $75 million to $500 million. About 18% had $500 million to $1 billion in assets, 14% had $1 to $2 billion in assets and 8% had assets of more than $2 billion.
Here’s a closer look at those and a few other things Sageworks said are getting attention in examinations.
1. Asset quality
A full 60% of the respondents said Office of the Comptroller of the Currency, FDIC, Federal Reserve and NCUA examiners focused most on this. According to respondents, examiners were particularly critical of failing to complete annual loan reviews, inconsistency in how cash flow analyses were conducted, stale loan file documentation, appraisals and financial information, handling problem loans and troubled debt restructurings, concentrated levels of commercial real estate and risk rating systems.
2. Market risk sensitivity
This was examiners’ next highest concern, with 37% of respondents saying it got most of their examiners’ focus, according to the survey. Many respondents noted widespread anticipation of higher interest rates and said examiners have been critical of their institution’s interest rate risk models.
3. Adequate capital
Criticisms and directives on capital adequacy were more common among financial institutions examined by the Federal Reserve and FDIC. Sageworks said examiners required only 3% of all respondents to take action on their capital levels, however.
Examiners criticized the Allowance for Loan and Lease Losses calculation processes at about one of every six institutions, though only 6% of respondents said examiners required them to take action, required a third-party evaluation or criticized the ALLL level. A few said examiners believed their provisions were too high, according to the study, but more often the concerns related to documenting supporting conclusions for Q factors.
5. Stress testing
The survey found that examiners gave recommendations on stress testing practices even though 99% of respondents had assets below $10 billion. One-third said examiners pressured them to start or expand stress testing, and 3% said examiners required stress testing implementation by the next exam. Sageworks found that 43% of institutions are already stress testing, though Dodd-Frank does not require them to do so.
6. Credit underwriting
About 20% of respondents said examiners criticized their credit underwriting practices, and 4% of banks and credit unions were required to take action on them. Risk rating criteria, documentation and cash flow analysis were all areas respondents mentioned were criticized.
Examiners criticized credit administration practices slightly more frequently than credit underwriting, according to the study. Almost a quarter of institutions reported it, but only 6% of those were required to take action on their practices. Documentation and organization, including systems for tracking and requesting financial information, were common points of contention, the study said.
8. Loan concentrations
One in five institutions received criticism or was required to take action on loan concentrations, the survey found. Often, commercial real estate attracted attention, though only 14% of banks and credit unions said they received criticism or were ordered to take action related to commercial real estate risk management.