Market Information News

Credit Underwriting Gets Grilled

Posted on October 24, 2018 Published by

Fall brings back so many of the things we love: kids going back to school, the return of regular schedules and, of course, football season. It’s also a great time to throw some burgers on the grill and enjoy the last few days of nice weather before many of us head inside for winter.

While grilling a meal with family and friends can be a great time, having your credit underwriting and analysis grilled by examiners is most likely not.

Credit Underwriting Gets Grilled

In 1996, the Comptroller of the Currency raised concerns regarding a trend of easing commercial underwriting standards. The concern was that changes in loan underwriting standards may have unintended effects on the risk parameters of loan portfolios that may be amplified with changes in the economy. We are hearing similar concerns from the regulatory agencies today regarding the easing of credit standards in the headwinds of fierce competition for a limited supply of deals.

The OCC issued Advisory Letter 97-3 (AL) in 1997 to highlight the major elements of an effective portfolio credit risk management process in response to what was perceived as an easing of credit standards. At the time, banks were managing an abundance of liquidity and competition in the market, and there was continued consolidation in the banking industry. Regulators were fearful bank management was moving away from the discipline of a long-term strategic portfolio approach to satisfy the pressure for growth and earnings. Sound familiar?

Examiners are expecting financial institutions to perform credit underwriting at a level commensurate with the complexity of the loan opportunity. Three key things typically form the foundation for a successful underwriting package: cash flow on the primary source of repayment, analysis of the collateral pledged to the loan, and review of global cash flow. Additional factors should also be considered depending on the opportunity, including:

1. Borrower trends

How is the borrower performing over a period of time, rather than simply the current year under review? A cash flow that is growing tighter could be an indication that the borrower is not passing price increases on to their customer or controlling expenses.

2. Balance sheet performance

A strong and strengthening balance sheet provides the borrower some flexibility if tough times are ahead. A balance sheet with minimal liquidity and equity could signal trouble if the income statement is negatively impacted.

3. Stress testing

Understanding how the borrower performs in various stressed situations can provide further detail on the overall risk profile of the borrower. Testing for changing interest rates is a common approach, but stress testing can also help understand changing margins, rental rates, tenant mix and more.

4. Tenant mix and strength

The performance of commercial real estate is directly related to the strength of the tenants. Understanding the quality of tenant and terms of the lease are important factors to fully understanding the likelihood that the property will continue to perform.

5. Commodity markets

Changes in commodity prices are key factors in determining if agricultural credits will improve or face additional hardship.

6. Budgets

In certain cases, your borrower should be providing a budget for anticipated financial performance. Not only can this help the financial institution, but this also helps to ensure the borrower is planning and looking ahead to credit or operational needs before they arise.

7. Guarantor strength

Guarantors are often the third source of repayment for commercial loans, after operations of the business and liquidation of collateral. Verifying liquidity and understanding contingent liabilities can provide support to the strength of the loan relationship.

The appropriate level of credit underwriting is one of the most important factors in determining the overall risk profile of a borrower. Examiners are paying attention and making sure financial institutions are completing a well-rounded analysis. And that’s why, no matter what, Credit Underwriting Gets Grilled!

 

Peter Nugent is Director and founder of Enlighten Financial, a specialized consulting firm that focuses on providing loan review and risk management services to community banks and credit unions. Peter guides the company’s service offerings, which include in-depth loan reviews, commercial and personal underwriting/analysis, internal process improvement and workout services. To talk to Peter directly, please call: (920) 354-6797.

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“The staff at Enlighten have been available for questions, in addition to the engaged work that they do. They've been very helpful as a resource beyond the major audit.”
— Meghann Kasper, Chief Credit Officer, Bank First
“Enlighten gives us a very good second set of eyes on our transactions. They're not afraid to challenge us on some of the work that we've done, which is what is needed. I don't need to pay somebody to tell me I'm good, I need to pay somebody to tell me where I've made mistakes.”
— Robert McPherson, VP of Risk Management, Peoples State Bank
“Enlighten provided industry best practices that weren’t going to show up in an audit report. They would say, ‘Hey, I noticed you do this. This is really unique, you do a really great job of it.’ And then they might add, ‘Some other clients that I have are doing something like this.’”
— Bill Beardsley, President, Michigan Business Connection
“By questioning some of our methodologies, Enlighten has helped us say, ‘Okay, this is where we need to train staff better and focus on so that they understand what they're doing better.”
— Robert McPherson, VP of Risk Management, Peoples State Bank
“The organization of the communication — before, during, and after the reporting process — was certainly better with Enlighten than what I've experienced with a lot of auditors.”
— Bill Beardsley, President, Michigan Business Connection
“The staff at Enlighten have been available for questions, in addition to the engaged work that they do. They've been very helpful as a resource beyond the major audit.”
— Meghann Kasper, Chief Credit Officer, Bank First
“Enlighten gives us a very good second set of eyes on our transactions. They're not afraid to challenge us on some of the work that we've done, which is what is needed. I don't need to pay somebody to tell me I'm good, I need to pay somebody to tell me where I've made mistakes.”
— Robert McPherson, VP of Risk Management, Peoples State Bank
“Enlighten provided industry best practices that weren’t going to show up in an audit report. They would say, ‘Hey, I noticed you do this. This is really unique, you do a really great job of it.’ And then they might add, ‘Some other clients that I have are doing something like this.’”
— Bill Beardsley, President, Michigan Business Connection
“By questioning some of our methodologies, Enlighten has helped us say, ‘Okay, this is where we need to train staff better and focus on so that they understand what they're doing better.”
— Robert McPherson, VP of Risk Management, Peoples State Bank
“The organization of the communication — before, during, and after the reporting process — was certainly better with Enlighten than what I've experienced with a lot of auditors."
— Bill Beardsley, President, Michigan Business Connection