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Bank credit standards: Do we have any left? (January 4, 2008) E-mail

By Edward T. O’Leary, veteran banker. A full biography of O’Leary appears at the end of this article 
 

Industry veteran asks where bankers’ judgment has gone
 
My banking career began in the mid-1960s at The Bank of New York’s commercial loan officer development program.
 
I was one of about 20 young men (we were almost exclusively men in the training program in those days) who were put through a more or less open-ended process of writing credit reviews in support of commercial lending applications. Our “clients” were the lenders, nominally, but the real client was the bank itself. The bank had its standards, and the occasionally adversarial role of the lending officers was understood and acknowledged.
 
In those days, such programs didn’t have a set term. You did it until you “got it.” One finished when one was finished. In my case, I got through it in just under 15 months, probably less because of my MBA than due to the bank’s need to get another credit man onto the lending line upon the completion of the bank’s merger with the Empire Trust Company.
 
That program served me very well for the next 40 years.
 
It gave me a very clear idea of what the bank expected in its loan portfolio in terms of risk. The training also taught very specifically what was expected of me: thoroughness, no bad credit, adherence to standards, no surprises.
 
Mind you, this was before there was such a thing as a formal loan review process or a credit policy that extended for dozens of pages. 
 
I had the idea in those days that all “big” banks did things pretty much the same way with the same degree of formality. I think that was accurate, based on my conversations with other bankers from different institutions.

Signs of changed times
Forty years later I have come to wonder about how standards are taught and inculcated at the big banks. Does the same degree of thoroughness exist that I recall from my formative training? How do banks today maintain a sound credit culture? How are lenders trained, and then nurtured, in the practice and application of their skills?
 
What we witnessed during 2007, and on into this year, has not been very encouraging.
 
Big banks and their stockholders are beginning to live with the consequences of some incredibly poor credit decisions—stupid and short-sighted, in my judgment, and on an epochal scale.
 
Who are the lenders making these underwriting decisions? Where were they trained? What sense of standards did they acquire in their formal training processes? Is anyone accountable?
 
The really curious thing to me today is how what I would call the “bad” credit decisions were largely made by the very large banks—“megabanks” in today’s parlance.
 
Yes, they are probably made by men and women much younger than I am today. However, the appalling thing, at least to me, is that they haven’t been trained very well. Sure, bad credit could slip through the system even at the old Bank of New York. But today we as an industry spend a huge proportion of our salary budgets on “risk management” and “risk abatement.” We tell ourselves and each other confidently that our systems can identify and track risk in our portfolios and that our loan review process uses the latest mathematical modeling techniques. The problems of the oil field in the 1980s, and the commercial real estate or LBO excesses of the 1990s simply couldn’t happen today.
 
Tell me, then, how the major banking houses ended up with billions of dollars of leveraged buyout debt on their balance sheets without permanent takeouts? Unless I completely misread the situation, these are largely credits by makers and on terms that would not be bankable in the bank’s own permanent credit portfolio (rate, covenants, etc). Does one side of the house leave its common sense in the vault when underwriting credit? Are the depositors of these banks, with their primary capital ratios of 7% or 8% of assets, the lenders of last resort?
 
That seems to be happening right under our noses.

Where’s the “Old Maid”?
Then there’s the subprime mortgage credit business. To be fair to the banking system, much of the subprime loan originations that are now burdening our financial system were underwritten and placed by nonbank lenders that do not receive the scrutiny that our industry receives from the various regulating authorities.  But what about the portion originated by the mortgage underwriting subsidiaries and affiliates of banks, and placed into the financial system to be packaged and sold to third parties?
 
The more egregious violations of common sense were not committed by the banks. Yet the banks were nonetheless originating and placing subprime mortgage credit that they would not accept onto their own balance sheets.
 
The child’s card game of Old Maid makes the point. When you got dealt the Old Maid, you were out of the game. Today, the Old Maid is sliced, diced, traded, packaged, and sold in such a way that no one knows where the Old Maid is. The point is that she is feared to be everywhere. And this is seizing up a substantial portion of the markets. She is buried within portfolios to be discovered in months or perhaps years to come—and by holders who had no appetite for that risk to begin with.


A double-pronged lapse, and its lessons
We really have two categories of failures here.
 
First, there is the abdication of common sense. Credit was underwritten with standards not appropriate to the originator and the ultimate source of takeout (i.e., the depositor).
 
Second, we actively participated and profited handsomely through elaborate structures of fees in originating paper we knew to be problematic at underwriting. The fact that “low doc” loans or loans made under excessively limber credit standards were not meant for our own portfolios is hardly sufficient to excuse the banks for assuming a decent share of the blame for the problems we see today.
 
Here’s my short list of what we’ve learned.
 
First, as an industry, we don’t seem to know, or appear capable of learning, what we don’t know.
 
Second, commonsense was left at the door, whether bankers were originating LBO credit or subprime mortgages for the national market.
 
Third, loan review systems failed miserably and probably systemically.
 
Fourth, we are destined to learn these lessons all over again. Sure, the faces will be different (and the practitioners are probably not yet in senior high school), but we as an industry will relearn these lessons with little if any experience residue of today’s pain and cost to the shareholders. Why am I so pessimistic? Because our experience in credit underwriting seems to be unfailingly consistent.
 
A major concern in my mind is not just the abdication of common sense in the area of credit. It is also just how concentrated the banking system has become. For example, Bank of America’s deposit liabilities alone contain nearly 10% of our financial system’s money supply, as conservatively defined. The top institutions are approaching 50% of the total. There never has been much room for error on a bank’s balance sheet, with our historically low equity-to-assets ratios, compared to the industries representing our borrowing customers. Today, though, the whole system seems to be placed at a level of risk that is historical in its size and complexity.  Remember, too, that it is official government policy that no bank is “too big to fail.”
 
I am reminded of an old saying that is probably as figuratively true to today as it has ever been: “A bank has to be right 99% of the time, as the remaining 1% is the loan loss reserve.” ABABJ online


oleary.jpgAbout the author
Ed O’Leary, now a banking consultant based in Albuquerque, N. M., is an industry veteran, having worked in banks large and small in both credit and managerial ranks. He served as president and CEO of First National Bank in Albuquerque and its successor, First Security Bank of New Mexico, from 1991 until 2001, when First Security was acquired. Since that time until September 2005, he served First National Bank of Santa Fe as Senior Managing Director in its Albuquerque office. Until his recent retirement, he was also a member of the bank’s board.
 
As an experienced commercial lender, loan workout professional, and executive bank manager, he brings 40 years of commercial banking experience to this viewpoint article. He began his banking career at The Bank of New York and held positions of successively increasing responsibilities at Southeast Banking Corp., Miami, Fla.; First National Bank of Midland, Texas; and Liberty National Bank of Oklahoma City, Okla.
 
O’Leary holds a Bachelor of Science from Boston College and a Master of Business Administration from Columbia University. He is a graduate of ABA’s Stonier Graduate School of Banking.


Among his published writings is his occasional series in ABA Banking Journal, “Would you make this loan?”. O’Leary also speaks frequently on banking. This includes participation in several ABA Community Bankers Council telephone briefings for community bank directors and other ABA telephone briefings.
 
You can e-mail him at This e-mail address is being protected from spam bots, you need JavaScript enabled to view it . O'Leary's website can be found at www.etoleary.com.
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Ken Proctor said:

Amen. Somewhere in the mid-90s, those banks that used to actually train lenders in credit fundamentals....stopped doing it. Everyone switched to the "hunter and skinner" model....lenders became "deal guys"....hardly even originating loans....instead...getting them "pre-packaged" from brokers. At the same time...banks credit standards evaporated..."yeah, that appraisal is a little old...but everyone knows property values have gone up". They looked more intently for reasons to make a loan...rather than understanding the critical elements of the credit and whether the borrower would ever actually be able to repay the loan if anything at all went wrong. The sad news is.....many bank loan portfolios still have loans that will go bad over the next several months. The crisis is not over...and I don't really think banks learned anything from it. Everyone wants to blame sub-prime loans, or the economy or bad luck....rather than inept and inadequate underwriting and portfolio monitoring. But....that's just my opinion.
 
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March 08, 2010
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Neal Davies said:

We bankers must be among the dumbest people in the world.

During every economic downturn, we learn lessons, most of which are not very new since we learned the same lessons in the previous downturns, and we say intently “never again.” Then when things cycle upward again, we yield to competition and begin to stretch terms, pricing, underwriting and policy.

Comes the next downturn, we will behave similarly. It seems to be our nature.

This time the savagery by the regulators left a particularly bloody playing field and my guess is that the next time will be different only by degree.
 
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April 03, 2010
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