Plansmith Blog

Dave Wicklund

is the Director of Educational & Advisory Services at Plansmith. He's a regulatory expert with 20+ years of experience as a senior bank examiner at the FDIC. Book time with Dave if you have questions or want to get started with a risk advisory service.

Recent Posts

Surge Deposits: Here We Go Again

Posted by Dave Wicklund on 11/1/22 10:00 AM

About two years ago, I wrote a blog declaring the end to, or “the death of,” Surge Deposits. In that post, I had noted how at the time of, and following the 2007-2009 Great Recession, the banking industry saw a substantial influx of deposits as real estate and equity investors liquidated positions and sought safe places to store their money and ride out the storm. I further noted that as CD rates plummeted during, and following, the economic crisis, CD holders weren’t being provided with any incentive to have their money “locked” into time deposits. As time deposits matured, CD holders routinely moved their balances into more liquid non-maturity deposits (NMDs). These former CD holders were essentially temporarily “parking” their money in NMD accounts, just waiting for CD rates to return to what they believed were more “normal” levels, at which time they’d move the balances back into time deposits.

Given the potential liquidity and interest rate risk associated with those surge deposits, regulators expected banks and credit unions to review their deposit composition, identify potential surge deposits, and consider the risk(s) associated with such deposits. In that 2020 article, however, we highlighted that in late 2018 and into 2019, we saw a market-wide spike in CD rates, and it was not uncommon to see one-year CD rates of near 2.75% and five-year CD rates of 3.25% or more. At the same time, most financial institutions left NMD rates at, or near their historic low levels, which should have been more than enough incentive for surge depositors to move their “parked” funds back into CD products. The whole point of the article was to highlight that any former “surge” balances still left in NMD accounts in 2020 should no longer have been considered “surge” or be viewed as having increased volatility characteristics, thus ending the “surge deposit” era.

While I still stand by that argument, it turns out that what’s old is new again, and we’re back to a new era of Surge Deposits; let’s call it Surge 2.0. So, what is Surge 2.0? Well, it’s what happens when the Federal Government injects trillions of dollars of cash into the U.S. economy. And no matter how you feel about the various pandemic-related Stimulus packages, the fact is that the bulk of that cash found its way into banks and credit unions everywhere. We saw deposits at most of our clients’ institutions grow at least 10-20% in 2020. That’s more than a ‘’surge"; it’s a tidal wave, and just like that first era of surge deposits that followed the Great Recession, these 2020 and 2021 surge deposits can be a great low-cost funding source. But, also like those post-recession surge deposits, you can bet that Regulators will be looking closely to see what you’ve done to assess their stability, and more specifically, what adjustments, if any, you’ve made to the decay rates you’re using in your interest rate risk model. More significantly, now that Treasury rates, and even deposit rates in many markets are starting to skyrocket, higher-yielding alternatives are now again available to depositors, and we’re starting to see non-maturity deposit balances at many of our clients beginning to decline.

Regulatory guidance states that as part of formulating decay rate assumptions, “banks should consider adjustments for qualitative factors to reflect current-period market conditions and anticipated customer behavior in response to interest rate fluctuations, for example by adjusting [for] the assumed runoff of surge deposits.” You may even be asked to expand your cash flow modeling efforts to include a stress scenario to show the potential run-off of these newfound deposits.

If you haven’t yet reviewed your deposit base and quantified the level of potential “Surge 2.0” deposits, we can do it for you (and it's not expensive). You'll get complete documentation, including a 20-year deposit trend analysis, and then we’ll show you how to use the results to adjust your decay assumptions and cash flow modeling scenarios.

Have questions or ready to get started with an analysis? Email us and we can schedule a time to talk.

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Three Considerations for Rising Rates in 2022

Posted by Dave Wicklund on 5/3/22 9:46 AM

The Fed has officially raised rates, with the intention of continuing to do so several more times this year. What does that mean for your financial institution, and how will it affect your Budgeting and ALM/IRR programs in 2022? Let’s focus on a few areas of concern, specifically Financial Reporting, Strategic Decision Making, and Board/ALCO oversight.

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Three Most Frequent Pitfalls of Interest Rate Risk Management Programs

Posted by Dave Wicklund on 12/1/21 9:15 AM

Establishing and maintaining a sound interest rate risk (IRR) program is crucial to ensure proper balance sheet structure and comply with Regulatory expectations. During my 20+ years as a senior FDIC examiner, I routinely saw organizations experiencing issues with their ALM/IRR practices, ranging from loose misunderstandings of the guidance to critical errors that put the health of the organization at risk. Unfortunately, in my current advisory role, I see the same issues all too often.

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What Your Board Needs to Know and How to Train Them

Posted by Dave Wicklund on 6/2/21 9:51 AM

Regulatory guidance states that the board of directors has the ultimate responsibility for the risks undertaken by an institution – including interest rate risk (IRR) and liquidity management.

The board is typically made up of a diverse group of individuals from varying backgrounds and career paths. Unlike most positions within a financial institution, a board member does not necessarily come from a banking background. One board could easily include a local entrepreneur, a farmer, a financial planner, a retired financial institution CEO, and a local insurance agent; while another board could be comprised of almost all former bankers. It’s often the most differing group in a similar role across financial institutions – so, since one size does not fit all, how do you train directors for their position on the board?

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The Outsourcing Dilemma: Time, Cost, and Control

Posted by Dave Wicklund on 12/1/20 10:58 AM

Is IRR and Liquidity Cash Flow Model Outsourcing Right for You?

That is a question a lot of CFOs and Presidents struggle with. Here at Plansmith, it really doesn’t matter to us whether you run the model yourself, or you outsource it to us. In fact, we have many clients on both sides of that fence, and even some that do a little of each. We just want you to be comfortable with whichever option you choose, be confident in your model results, and be sure your ALM process will pass the test at regulatory exams.

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Negative Interest Rates Explained

Posted by Dave Wicklund on 11/2/20 9:14 AM

Given the current low-rate environment, I’ve again been getting some questions on “negative rates” and the impact they would have on financial institutions, and more specifically interest rate risk modeling. We’ve all heard about negative rates in Japan and parts of Europe, so it would seem reasonable to wonder about the impact that negative rates could have here in the U.S.

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3 Reasons to Revisit Your IRR Policy Limits

Posted by Dave Wicklund on 6/3/20 12:17 PM

Do you have appropriate policy limits for all key interest rate risk measurements? How did you set your set them, and do they really still make sense for your institution?

When market rates weren’t changing, most institutions were in general compliance with policy limits. However, with the steady ramp up of rates through mid-2019, and then the massive drop in March of 2020, we’ve seen numerous financial institutions fall out of policy compliance. We’ve also heard from many of our clients that just aren’t sure what they should use for limits for the various non-parallel rate shock scenarios and now emphasized net income shock measurements. The old industry standard limits that so many institutions are still using just don’t seem to be working anymore.

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Key ALM/IRR Activities to Perform in 2020

Posted by Dave Wicklund on 4/22/20 9:09 AM

Given the historic low U.S Treasury rate environment and the recent 150 basis point near-immediate drop in rates, we’re expecting an increased regulatory focus on interest rate risk (IRR) and liquidity management.

It’s no doubt that financial institutions will see pressure to not only reforecast their 2020 budgets, but also to run future IRR shocks and more custom “what-if” scenarios as part of their regular IRR modeling program. Liquidity management and stressed-scenario cash flow modeling are also more important now than ever.

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Surge Deposits: R.I.P. (2018-2019)

Posted by Dave Wicklund on 4/8/20 10:57 AM

For the past ten years or so, surge deposits have been a material issue in asset/liability management. At the time of, and following the 2007-2009 Great Recession, the banking industry saw a substantial influx of deposits as real estate and equity investors liquidated positions and sought safe places to store their money and ride out the storm. The impact of this flight to safety was compounded by Government sponsored initiatives such as the Transaction Account Guarantee (TAG) Program and increases in Federal deposit insurance levels.

As a result, banks experienced significant deposit growth, and while these surge deposits would have normally been seen as a good thing, the near evaporation of loan demand left many banks with far more deposit dollars than they could effectively put to use. In turn, market liquidity levels skyrocketed, but margins were compressed. For the purpose of this article, we’ll refer to these funds moving from real estate, equities, or any other investments into the banking system as Type I Surge Deposits.

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Wayne Gretzky, the Barber Shop, and Your Contingency Funding Plan… What They Have In Common, and What You Should Be Doing NOW - Part II

Posted by Dave Wicklund on 3/25/20 9:37 AM

In my 20+ years at the FDIC and now 8 years here at Plansmith, I honestly never imagined that all those Contingency Funding Plans (CFPs) I’ve read and written would actually be relevant. I always viewed them as a good way to layout the framework for monitoring funding risk and alternate sources of liquidity, but I certainly didn’t think that the “systemic stress” scenarios would really ever be something we’d actually be dealing with. 

For those of you who didn’t see it, click here to read the blog I posted yesterday focusing on some things you can do help your community get through this current crisis. Today, we’re going to turn our focus to what you can, and should, be doing to limit the impact that this crisis might have on your institution.

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