Over Pricing Your Largest Most Profitable Customers

One of the biggest mistakes many FIs make when setting pricing strategy is to establish a ‘base lending rate’. Often this ‘base rate’ is applied regardless of the type, size, or term of the loan, and worse, is often set to Prime. For example, when considering a five-year fixed rate on a commercial real estate loan, from time to time we come across a client or prospect that applies their ‘base rate’ of Prime which today would be 8.5%. The problem with that approach is we are ignoring a fundamental principle of finance – we’re ignoring interest rate risk and the term structure of rates.

The Prime lending rate is an overnight rate – technically Prime can change any day. Obviously a 5-year rate is a much longer-term rate. Comparing Prime to a five-year fixed rate is really comparing apples and oranges. Let’s dig into this a little further. Today, Prime is 8.5% and a five-year fixed rate advance from the FHLB is 4.25% – a difference of 4.25%. In February of 2022 Prime was 3.25% and a five-year FHLB advance was 2.25% – a difference of only 1.00%. In February of 2020 Prime was 4.75% and a five-year FHLB advance was 1.50% – a difference of 3.25%. And in February of 2018 Prime was 4.50% and a five-year FHLB advance was 3.00% – a difference of only 1.50%. As you can see, the relationship between five-year rates and Prime is highly inconsistent. Over the past 6 years Prime has been as much as 4.25% and as little as 1.00% above a five-year rate. So, we have to ask ourselves, why would I tie the rate on a five-year fixed rate loan to Prime?

The other challenge this practice can lead to in the current environment is over-pricing some of our largest, most profitable customers or prospects – which could lead to losing existing relationships or get in the way of winning new relationships. We model loan scenarios for FIs all across the country many times each day so we see a large number of loan opportunities and how they are being priced in the market. Particularly on larger deals – say $1,500,000 and above – we often see rates in the mid to low 7% range. However, we also see rates as high as 8.5% on the exact same scenarios – particularly when the FI currently follows the ‘base lending rate’ philosophy. One of the ways Pricing Manager can help your FI earn more net interest income is by helping win more larger, profitable deals by pricing more competitively.

If you would like to learn more about Pricing Manager, please contact Strunk at info@strunkaccess.com or 800-728-3116.

Strunk Response to January 2024 CFPB Proposed Changes to Overdraft Fees

In mid-January of this year, the Consumer Financial Protection Bureau (CFPB) proposed a new rule to restrict overdraft fees charged by very large financial institutions (Those with assets over $10B). View the PDF of the Proposed Rule with Request for Comment here:

https://files.consumerfinance.gov/f/documents/cfpb_overdraft-credit-very-large-financial-institutions_proposed-rule_2024-01.pdf

When the Board of Governors of the Federal Reserve System first adopted Regulation Z in 1969, it excepted from Regulation Z’s definition of finance charge any charges for honoring checks that overdraw a checking account unless the payment of the check and imposition of the fee were previously agreed upon in writing. The Board subsequently made “minor editorial changes” to this exception, (e.g., to reflect “items that are similar to checks), such as negotiable orders of withdrawal. Under the new proposed rule, Regulation Z would generally apply to overdraft credit provided by very large institutions unless it is provided at or below costs and losses as a courtesy to consumers.

The proposed rule would accomplish this by updating two regulatory exceptions from the statutory definition of finance charge. First, the proposal would update an exception that currently provides that a charge for overdraft is not a finance charge if the financial institution has not previously agreed in writing to pay items that overdraw an account so that the exception would not apply to “above breakeven overdraft credit”. Second, the proposal would update a related exception that provides that a charge imposed in connection with an overdraft credit feature (e.g., a charge for each item that results in an overdraft) is not a finance charge if the charge does not exceed the charge for a similar transaction account without a credit feature (e.g., the charge for returning each item). The CFPB has provided two options to very large financial institutions to determine whether an overdraft charge is considered above breakeven overdraft credit. A financial institution may calculate its own “breakeven standard,” charging a fee required to cover losses and direct costs related to the provision of courtesy overdrafts; or a financial institution may use a “benchmark fee” of either $3, $6, $7, or $14, determined by the CFPB by analyzing charge-off losses and cost data.

The proposed rule represents a pivotal development in consumer finance regulation and would have a negative impact on the financial industry and consumers. Overdraft protection has been beneficial to millions of consumers since its inception. Research supports the fact that consumers who use overdraft protection, especially those who use it frequently, value the service. Even the Consumer Financial Protection Bureau’s (CFPB) research supports this fact. Furthermore, the CFPB has access to consumer complaint data in its own database, showing that complaints regarding overdraft protection and fees are extremely low. Strunk believes that a regulatory agency essentially setting limits on fees that can be charged by a financial institution sets a very dangerous precedent.

At present, the proposal pertains to financial institutions under the CFPB’s jurisdiction – those with assets over $10 billion. It is unclear what the impact will be on institutions with assets of $10B and below. However, if this proposal is enacted, the possibility exists that it will be adopted by other regulatory bodies. Also, regardless of additional regulatory action, all institutions may feel “competitive pressure” to follow the standard set by the very large financial institutions.

For now, no changes to existing overdraft programs should be made prior to knowing exactly how this process will play out. When discussing Overdraft Privilege and the current regulatory landscape, Strunk always emphasizes two things:

  1. If you charge a sustained or continuous overdraft fee today, discontinue this practice immediately. Strunk has never endorsed that practice, and it is a flash point for regulators.
  2.  If you charge re-presentment OD fees, discontinue this practice as well and investigate the 24-month look-back restitution to consumers. This is an area where regulators have come out with clear guidance in the last 18 months and Strunk has previously issued recommendations to clients.

If your organization has questions regarding this matter or would like to schedule time to discuss, please contact us at support@strunkaccess.com or 800-728-3116.

Repayment Plan Management from Beginning to End

A Fresh Start Repayment Plan is a tool available to overdrawn customers that will allow them to repay the overdrawn balance in up to four payments and will also allow them to retain the use of their checking account. It also may help financial institutions recover and collect on accounts which may have otherwise charged off.

Included with Strunk’s hosted ODP Manager software, financial institutions have access to Strunk’s library of Fresh Start documentation. The library contains a Fresh Start Profile that addresses recommended features and optional considerations, a recommended Fresh Start Policy and Procedure Guidelines, a suggested Assessment template to determine Account holder’s ability to repay the Fresh Start Repayment Plan, and a recommended Fresh Start Agreement. These documents provide the necessary information to start offering and setting up Fresh Start Repayment Plans.

ODP Manager Formal Demand and Final Demand collection letters advise customers overdrawn for more than $100 to ask if a Fresh Start might be an option to repay the overdrawn balance in 4 payments or less. Once a customer contacts the institution, an assessment should be completed to confirm the customer’s ability to repay the Fresh Start Repayment Plan.

If a customer qualifies and accepts the Repayment Plan, ODP Manager users can enter a repayment schedule for each account. The repayment schedule can be used to generate the Fresh Start Agreement to be signed by the customer. It will also create payment reminders to show when a repayment should be due. The payment should be verified in the core system and then tracked in the repayment schedule once paid. If the account defaults on the repayment plan, the Fresh Start Default Letter can be generated in ODP Manager to inform the customer that the account has been closed, charged off, and reported to the appropriate agencies.

ODP Manager offers two reports related to Repayment Plans. The Fresh Start Tracking Report lists all accounts that have been identified as being in repayment by an ODP Status Code. A Repayment Schedules summary report can also be used to track the status of Fresh Starts, including payments made and outstanding balances. Both report options can be exported to PDF or Excel.

If you have any questions about Fresh Start Repayment Plan options in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com to find out more.

Options to Customize Letter Templates

Strunk’s hosted ODP Manager software includes a suite of standard, recommended, and compliant letter templates. These templates are set up so users can easily generate the letters due each day. Even though Strunk provides the recommended letter content, the ODP Manager software allows the letter appearance to be customized to match other letters sent by an institution.

The letter headers and footers can include logos or text so that letters can be printed on letterhead instead of plain paper.

Letters can be signed by the user that generated the letter or if requested, they can be signed by a specific person, department, or the institution name. If signature images are provided, they can be added so that they show when the letter is generated.

If an institution would prefer to have a letter display a branch contact’s name or the phone number of the branch, the contact information can be updated based on the branch assigned to the individual account. This allows the letters the flexibility to direct users to contact a central location or their local branch to discuss the Overdraft Privilege program.

These options allow financial institutions to feel confident in generating ODP program letters that not only are compliant, but also represent an institution’s desired letter appearance.

If you have any questions about customizing letter templates in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com to find out more.

Vendor Due Diligence Material Tracked in Strunk’s Vendor Manager Software

Financial institutions regulated by the OCC, FDIC, and Federal Reserve must conduct due diligence on third-party relationships per the Interagency Guidance on Third-Party Relationships: Risk Management. Regulators expect financial institutions to review vendor documents thoroughly rather than just glance over them. Organizing all your vendor management in a secure, web-hosted database is the first place to start in this process. Strunk’s Vendor Manager software simplifies the overwhelming task of monitoring existing vendors and onboarding new ones.

A centralized repository for your due diligence documents ensures that your financial institution has a vendor management program that allows you to engage your vendors at each phase of the vendor lifecycle. This will ensure that all departments and business lines can easily access a unified document from your financial institution while dating it to make sure that it’s the most recent document. This process assists your financial institution in evaluating vendors to ensure they align with operational, financial, and regulatory standards.

Strunk’s Vendor Manager software automates due diligence process by sending alerts to financial institution stakeholders and vendors, saving time and effort. Vendor Manager automates vendor due diligence, providing a practical framework for deciding which vendors to assess in-depth, assessing the risk they present, and monitoring their performance. The Vendor Manager provides proactive risk management and reduces administrative burden. Strunk’s Vendor Manager software can help with your financial institution vendor due diligence to ensure that your organization has a process when entering into a third-party relationship. Click here to learn more.

 

Importance of an Effective Contract Review

The Interagency Guidance of Third Party Risk Management states that an effective third-party risk management life cycle consists of planning, due diligence and third-party selection, contract negotiation, ongoing monitoring, and termination phase.

One of the most critical aspects of the third-party life cycle is the contract negotiation phase. It is essential to evaluate a vendor’s contract with other parties, including sub-contractors, which might transfer or bring additional risk to the financial institution. A vendor contract, sometimes referred to as a vendor agreement, is a legal document that outlines the terms of an exchange of goods or services for payment between the two parties.  Through this agreement both parties understand their responsibilities and obligations during the transaction.

The primary object of a vendor contract is to ensure that all parties involved are aware of what is expected in terms of deliverables, payment, and other relevant details. In the event of non-compliance, the vendor contract also specifies the consequences. Negotiating vendor contracts at the outset of any vendor partnership assists financial institutions in better managing their risks. Vendor contracts usually contain legal provisions, often in a specific order.

Strunk’s Vendor Manager Software allows you to score individual contracts based on the presence and quality of key provisions. Strunk’s vendor contract review enables financial institutions to identify gaps in their contracts and manage the vendor’s risk appropriately.

Flexible Fields in ODP Manager

ODP Manager has a standard list of requested fields that are used in the recommended ODP Manager letter templates and reports. These fields are included in the extract file created by an institution’s core or report writer and are updated when the file is imported daily into ODP Manager.

ODP Manager mappings are customizable and can also allow additional institution-specific data fields to be imported. These fields will be marked as flexible fields and will be labeled with an institution-specific label in ODP Manager. Once the fields have been mapped and imported into the hosted ODP Manager software, letter criteria can be adjusted to use the additional data field values. Report groups can also be updated to use the newly available data fields as well.

This flexibility allows institutions additional opportunities to customize ODP Manager to make ODP Program management in the hosted software more efficient or informative. If you have any questions about adding Flexible Fields in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com to find out more.

Automatically Archive ODP Manager Reports

The ODP Manager hosted software includes a suite of standard reports that are updated after each daily import. These reports can be viewed in the browser or exported to PDF or Excel. Reports for the most recent seven As of Dates are accessible.

If an institution would like the option to review, analyze, or retain past reports, users are able to export and save the reports as needed. However, if reports are not exported and saved within the most recent seven As of Dates, then the report data is no longer available. ODP Manager offers an alternative to manually saving and retaining reports. Upon request, Strunk can set up a Report Archive which automatically archives the requested reports after each daily import. This will alleviate the need to remember to manually save report copies.

The archived reports are saved as PDF files within the software. For each import As of Date, a folder containing the archived reports is created and can be downloaded. If an institution would rather download the archived reports to save to a network drive instead of accessing though the ODP Manager software, a Download Reports Archive link can be set up instead.

If you have any questions about the Report Archive option in hosted ODP Manager, please contact Strunk Support at support@strunkaccess.com to find out more.

How can Strunk’s software help with your vendor management program?

Regulators take compliance with vendor management regulations seriously due to the critical role third-party vendors play in delivering products and services. Using third-party services can increase the risk of a banking organization, but this does not mean that the organization can neglect its responsibility to perform all activities in a safe and sound manner. It is the responsibility of the organization to ensure compliance with all applicable laws and regulations, including those related to consumer protection and security of customer information. What exactly are the Regulators looking for in a Vendor Management program? Regulators will look for your program to have structure, be consistent, and have accountability. Strunk’s software can be your perfect solution to achieve your objectives. Let’s take a closer look at how it can help you.

The first thing that needs to be accomplished is to have the right structure for your program. The financial institution needs to have a well-documented policy describing how your board and senior management intend to execute vendor management. Strunk’s Policy Manager Software can provide your financial institution with a structured, centralized single source of truth for your organization’s policies. You can also use Policy Manager to document all of your procedures, including links to policies, ownership responsibilities, automated change logging, and multiple file attachments. If your financial institution does not currently have a vendor management documented policy, Strunk can start you off with our recommended standard policy.

Next, the financial institution must establish a consistent framework for implementing the policy that was established. Strunk’s Vendor Manager software can streamline and standardize the entire process. The Vendor Manager software is designed to transform a complicated process into a more organized and self-documenting workflow. It helps to streamline and automate the process, making it more efficient and easier to manage.

The financial institution must be accountable for its vendor management program. Strunk’s Risk Assessor software can assist in identifying what risk your organization must consider with your Vendor Management program, while also mapping what controls and procedures are in place for that risk.

Preparing for your next Vendor Management exam is crucial for your financial institution. Strunk offers several tools that can help you in this regard. While regulators do not expect perfection, they do expect progress and performance. By utilizing Strunk’s software and expertise, you can ensure that you are up-to-date and organized for your upcoming exam. This will make exam time much easier.

Credit Unions: Size Matters When Making Loans

When making auto loans most credit unions look at the term of the loan, the age of the car or truck, and the creditworthiness of the member when determining the rate for the loan. Most institutions look at loan to value, debt to income and/or the credit score of the member before deciding to make or decline the loan request. But, very few credit unions look at the size of the loan when setting rates and all of them are missing out on a huge opportunity.

The three main factors when trying to meet profitability goals from a consumer loan portfolio are: 1) creditworthiness of the borrower; 2) term of the loan and 3) SIZE of the loan. Most financial institutions consider the size of the loan by the age of the vehicle. Many years ago the age was a good substitute for the size of the loan but not anymore.

Small dollar car loans are not nearly as profitable as larger loans when factoring in the costs associated with underwriting and servicing these installment loans. Even if the credit report and term of the loan are equal when evaluating a loan, credit unions should not offer the same rate for a $10,000 loan vs. a $25,000 loan, or a $50,000 loan.

Strunk’s loan pricing solution factors in all drivers of profitability and we will help you set rates based on your credit union’s target return. The tool is very inexpensive, easy to use, and will increase your credit union’s bottom line. In a recent meeting with a 25 year tenured CEO of a credit union she said “I’ve never heard of looking at the size of a loan to determine the rate for a loan. When can we get signed up?”

Contact Strunk 800.728.3116 or at info@strunkaccess.com to learn more about our loan and deposit pricing solution.