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

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

Posted by Dave Wicklund on 3/24/20 9:40 AM

In perhaps the most overused sports quote of all time, hockey legend Wayne Gretzky said, “I skate to where the puck is going to be, not where it has been.” That piece of advice is usually used to inspire people to look ahead to emerging markets and business opportunities. Right now, however, I think that quote can serve as a guide for us to examine where this is all going, and how we should be planning for what’s coming next. We know where the puck has been; rates have dropped to historic lows, the stock market has plummeted, most of you have closed your lobbies to commercial traffic, and you’ve probably taken numerous other steps to try to limit the impact that this pandemic will have on you and your bank or credit union.

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The 4 Big Backtesting Questions Revisited

Posted by Dave Wicklund on 2/5/20 2:50 PM

As we move into a new year, you may still be working on a few of those items you didn’t quite get to in 2019. And for a lot of our clients, one of those items is often backtesting. Given all the confusion surrounding backtesting, it can be pretty easy to keep pushing it to the bottom of the “to-do” list.

So, we thought it might be a good idea to dust off a blog I wrote back in 2015 to jump start your 2020 so you can get one more thing crossed off your list. In that blog, we looked at a few of the most common questions we get on backtesting. Specifically, we discussed who should do it; how often it should be done; what period should be covered; and if you need to backtest just model results, or also key model assumptions.

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4 Reports for Analyzing & Understanding IRR

Posted by Dave Wicklund on 11/18/19 1:48 PM

Knowing and understanding your organization's risk position is important. Regulators expect you to keep a close eye on your IRR exposure and be ready for a rising rate environment.

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Regulatory Expectations: IRR & Liquidity

Posted by Dave Wicklund on 11/6/19 10:51 AM

Does your organization have the IRR and Liquidity knowledge it needs to succeed?

Regulatory guidance emphasizes the importance of effective corporate governance and outlines expectations for both board members and senior management personnel. Specifically, interagency guidance identifies the board of directors as having the ultimate responsibility for the risks undertaken by an institution – including IRR and liquidity.

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The Real Reasons to Outsource Your IRR

Posted by Dave Wicklund on 10/15/19 11:01 AM

As you grow, your organization has more and more things to manage.

  • Strategically, you’re working to find the right markets to penetrate with the ideal products and services.
  • Financially, you’re making sure your earnings are meeting or exceeding targets.
  • And organizationally, you’re looking for the right talent to expand and grow.

One thing you can’t ignore is the role Interest Rate Risk plays in the banking industry today.

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What is Managing Your Own IRR Really Costing You?

Posted by Dave Wicklund on 4/10/19 10:53 AM

Regulatory compliance costs are skyrocketing!

The focus of safety and soundness examinations continues to move towards asset/liability management and ensuring financial institutions are complying with the guidance issued in the last several years.

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