Plansmith Blog

I’ve always said that deposit pricing (a/k/a “betas”), decay rates, and asset prepayments are “the big three” when it comes to interest rate risk (IRR) model assumptions. Why is that? Well, it’s because those are the ones that most people think have the greatest impact on model results, and, as a result, those are the ones that examiners tend to look at the closest. And while I don’t always agree that prepayments matter all that much (depending on the duration of any given institution’s intermediate- and longer-term assets), the current falling rate environment is certain to again shine the spotlight on them at regulatory examinations. As such, we thought it would be a good time to review a few key concepts and then go through the best practices to be sure you’re exam ready. So first, the key concepts:

What do massive shifts in deposits, economic uncertainty, and falling interest rates have in common? The potential to wreak absolute havoc on your institution’s liquidity position. One unplanned or mismanaged situation could mean falling out of policy limits, or worse.

Over the past several years, the banking industry has seen seismic shifts in deposits as trillions of dollars in Government stimulus were released into the economy, followed by a period of dramatic increases in market rates which then resulted in massive amounts of low yielding balances migrating into higher-paying CDs and non-bank investment products. Now, as deposit rates have begun to fall, we're seeing depositors look for higher yields both inside and outside the banking industry.

"Which measurements would you consider highest priority in 2026?"

I’d say that Net Interest Margin (NIM) changes and Economic Value of Equity (EVE) should continue to be the primary focus of IRR management in 2026. Gap calculations rarely give the full picture (they're focused on timing of repricing, not magnitude), and Duration measurements can be difficult to understand. Given the rate drops we've seen so far and the expectations for further decreases, all financial institution managers and directors should have a clear understanding of how future market rate changes could impact both shorter-term earnings (i.e., NIM in the next one and two years) and longer-term capital values (i.e., EVE).

As another summer fades into the review mirror, I think back to all those family vacations my wife and I took our kids on and the all too familiar question that came every year as we got closer to our destination (and the end of my patience); “Are we there yet?” And just like how we never seemed to get to that destination fast enough, the banking industry just can’t get to a place of deposit stability fast enough either.

In 2022 and 2023, the Fed increased the target Fed Funds rate by a total of 525 basis points. Those moves were aimed at tempering the overheated economy in the wake of the COVID pandemic. As a result of those increases, we saw massive shifts in deposit balances as consumers became more aware of opportunities to move balances from lower yielding non-maturity deposits into higher yielding CDs and alternative investment products. Now, as the Fed has begun cutting rates, depositors are actively looking both inside and outside their bank or credit union for the highest rate(s) they can find, significantly impacting financial institution liquidity levels and planning strategies.

Establishing and maintaining a sound interest rate risk (IRR) management 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, all too often, I see the same issues.

"Which measurements would you put highest priority on in 2024?"

I’d say that Net Interest Margin (NIM) changes and Economic Value of Equity (EVE) should continue to be the primary focus of IRR management in 2024. Gap calculations rarely give the full picture (focused on timing of reprice, and not magnitude), and Duration measurements can be difficult to understand. Given the extreme rate increases in the past two years and the bank failures in 2023, all financial institution managers and directors should have a clear understanding of how future market rate changes could impact both shorter-term earnings (aka the NIM in the next one and two years) and longer-term capital values (aka the EVE).

For the past few years, I’ve written about the varying circumstances surrounding Surge Deposits. From “the death of” to the “resurgence,” it seems to be a consistently hot topic – this year, with a slight twist. While previously keeping a close watch on the influx of demand deposits, we’re now seeing increased pressure on funding flowing either from non-maturity deposits (NMDs) into higher costing CDs, or out of financial institutions all together. 

Before we get further, if you haven’t yet read my other blogs discussing Surge Deposits, or could use a refresher, click here to do so.

It was only two months ago we released a blog discussing the critical role that liquidity management will play in 2023. Fast forward to now, and two financial institutions have been closed due to, at least in part, funding imbalances – the first banks in three years to fail. Although liquidity and interest rate risk often take a backseat under stable economic conditions, times like these require you to take an in-depth look into your asset liability management program to ensure you have a plan to both meet funding needs and stay in compliance with regulatory expectations.