As new risks emerge, the role of the Risk Officers and Risk Managers has become far broader and more complex, covering everything from regulatory compliance, operations risk and credit risk to data management, advanced technologies and industry disruption. Because the industry is changing so rapidly, financial institutions are compelled to ask whether their financial risk leaders are keeping up, or more importantly, keeping ahead of the change. Moreover, if the institution is just keeping up, the follow-up question is whether this current pace is enough. In other words, does the institution have flexibility in its talent, organizational structure, process and policies to protect itself from evolving risks?
Welcome to the CECL time warp. When the FASB announced its CECL requirement in 2016, it seemed like there was an endless amount of time available to meet CECL 2021 implementation deadlines. Now, in 2019, the road to implementation seems like a speedy downhill drive in a car with squeaky brakes – except there are, in fact, ways to check the brakes along the way.
“It is true, we shall be monsters, cut off from all the world; but on that account, we shall be more attached to one and other.”
— Mary Shelley, author of “Frankenstein, or The Modern Prometheus”
Reflecting on the current state of Artificial Intelligence (AI), one might say that in writing the novel “Frankenstein,” Mary Shelley unknowingly touched upon the fears and contradictions facing humans in the 21st century. Humans, in our desire to advance, are pushing the boundaries of innovation by creating intelligent thinking machines that could (in a worst-case scenario) become self-serving and fall out of the control of its creators.
For small and large institutions alike, financial models are growing more complex. Business leaders at financial institutions are more frequently relying on financial models to make informed and strategic business decisions, ranging from pricing and launching new products, to managing capital and setting reasonable internal risk thresholds.
What happens if right after you finalize your financial models and get ready to make critical pricing or balance sheet decisions, your head of risk modeling leaves your institution with little notice, and to your dismay, little documentation? While your former model developer was brilliant, your institution is now left with a range of financial models that may or may not be accurate or effective.
If you have followed the news about MoviePass and its recent financial downfall, you may have read about declining stock prices and angry customers, and made a mental note about what not to do in business. However, there is one critical but less obvious lesson to learn from the MoviePass pandemonium – and it is one that just might keep your financial institution from going down the wrong CECL road.
If credit unions want to stay on track for implementing the Current Expected Credit Loss (CECL) standard, they need to have already completed several milestone tasks and to complete several more by the end of the year. Credit unions also need to be sure they have allocated sufficient time to complete the tasks that need to be finished between 2019 and 2022.
After many quiet years, merger and acquisition (M&A) activity at banks has been on the rise in 2018, and several favorable trends will likely sustain the momentum through the remainder of the year. By the middle of 2019, as banks evaluate acquisition opportunities, they likely will add a new component to their customary due diligence: an exploration and understanding of the target company’s Current Expected Credit Loss (CECL) methodology.
Regulators require the model validation process to ensure that financial institutions are properly modeling for risk. Beyond regulatory compliance, model validation also provides business leaders with confidence in their models and helps to reinforce or reassess business and balance sheet decisions shaped by model outcomes. Considering the importance of model accuracy and effectiveness, it is critical to understand hidden risks in model validation practices. Whether a financial institution develops its financial models internally or works with a third-party model software vendor, it is critical to ensure your model validation partner understands and considers hidden risks in model validation. Some such risks include:
Changes in driver rate relationships are key influences determining the Interest Rate Risk (IRR) position of most institutions. Today, it is commonplace for financial institutions to incorporate testing for basis risk and yield curve shape risk in their IRR analyses. Three elements are needed for a successful basis risk and yield curve risk analysis solution: Asset Liability Management (ALM) model setup and fine tuning; defining the appropriate rate tests; and effectively communicating the institution’s Net Interest Income (NII) IRR position
Ensuring compliance with key model risk management (MRM) guidelines and regulations requires that risk managers for financial institutions assess and validate all financial models. As economic conditions evolve and regulators demand greater balance sheet transparency, financial institutions are developing and managing more models than ever before. To meet regulatory guidelines, many financial institutions must decide whether a method of financial calculation is considered a financial model or a tool.
A few years ago, “big data” emerged as a buzzword across many industries, including financial services. The concept and push was to capture all-encompassing information. While that talk has wound down, we’re now hearing an uptick in discussions about artificial intelligence and machine learning, interpreted as using big data to improve decision making.
At banking organizations, financial model validations can be simply viewed as a necessary task on a checklist for following regulatory guidance. Some institutions also believe that the quality of a model validation is less important when the institution or business line is successful and when local, regional and national economies are all thriving.
As interest rates rise, financial institutions are revisiting whether an in-house asset liability management (ALM) model or a third-party (outsourced) ALM model is the best option for monitoring and assessing interest rate risk (IRR). Many variables and factors need to be considered when making such a critical decision. The following four factors will help institutions identify when it is best to implement an in-house model and when to outsource to a third-party vendor to ensure compliance with regulatory mandates associated with measuring and monitoring interest rate risk:
The 6 Tenets of Effective Model Risk Management
As financial institutions progress in the new economic cycle — a cycle defined by gradual interest rate increases, regulatory uncertainty and economic growth — it may be time to revisit the financial models and model processes used to facilitate interest rate risk (IRR) analyses and other risk analyses such as capital stress testing. The accuracy and effectiveness of a model is critical because its outputs may alter the accuracy and effectiveness of related models and impact strategic decisions.