Professional Documents
Culture Documents
FALL 2005
combination of rapid growth, new products with higher embedded The complete SR letter can be found on the Board of Governors
www.stlouisfed.org
risk and the easing of underwriting standards. In many cases, web site at www.federalreserve.gov/boarddocs/srletters/2005/
regulators have found that an institution’s credit risk-management sr0511.htm. For more information about the guidance, contact Scott
practices for home-equity lending aren’t keeping pace with these Smith at (314) 444-8836 or toll-free at 1-800-333-0810,
changes. So, on May 16, the Federal Reserve joined in issuing ext. 44-8836. ■
Feditorial
A Regulator’s Notebook: Keeping Track of
Real Estate and Mortgage Lending Practices
By Julie Stackhouse, senior vice president, Banking Supervision and Regulation
R
egulators frequently discuss emerging issues usually do a good job of underwriting CRE loans.
and ways to monitor trends. In the Eighth Most banks compete effectively in this market
District, our current list of “radar risk” issues because they know their market well and have
is short; however, a few continue from month- the ability to tailor loan terms and closely monitor
to-month, especially when we examine mortgage projects. Nonetheless, more CRE loans can mean
and commercial real estate lending practices. concentration risk—putting too many eggs in one
During the last year or so, we’ve seen noteworthy type of lending basket—thereby increasing the need
changes in the home mortgage market. Currently, for banks to maintain high underwriting standards
about one-third of all mortgage originations nation- and sound risk-management practices.
wide are adjustable rate mortgages, representing As a bank’s CRE concentrations grow, our exam-
almost one-half of the dollar value of new mortgages. iners will expect to see:
Some market analysts also report that interest-only • strong management information systems that
mortgages now make up roughly 10 percent to 20 can distinguish CREs by geographic location,
percent of the mortgage portfolios of some of the property type, loan-to-value and phase of con-
nation’s largest banks. struction; and
Although adjustable-rate and interest-only mort- • effective procedures for monitoring primary
gages are suitable for many borrowers, some bor- real estate markets and assessing the quality of
rowers have little cash flow flexibility—creating risk appraisals.
should interest rates change sharply. In other cases, For more significant concentrations in larger
the borrower’s ability to repay the principal balance organizations, we also may look for the bank’s abil-
is dependent not on the borrower systematically ity to stress-test individual loans and loan portfolios
paying down the principal, but rather the eventual by type and location.
sale of the home. So we become especially watchful In summary, today’s “regulator’s notebook” for
when these types of loans appear to finance specula- community banks is focused on the mortgage and
tive purchases. CRE markets. We realize that rapid growth in
We also carefully monitor commercial real estate these areas reflects opportunities for financial insti-
loans (CREs), which are growing in many com- tutions, but we still encourage bankers to engage in
munity banks’ loan portfolios. Community banks prudent risk management. ■
B
anking regulators have approved the longer need to collect and report CRA loan data; activities that revitalize or stabilize designated
final Community Reinvestment Act (CRA) however, examiners will continue to evaluate disaster areas, distressed or under-served rural
rules, which took effect Sept. 1. The goal bank lending activity during CRA examinations areas. The new regulations also clarify when
is to make CRA evaluations more effective in and disclose the results. Intermediate small discrimination or other illegal credit practices by
encouraging community banks to meet their com- banks also will be evaluated and required to a bank or its affiliate will adversely affect the
munity development needs while also reducing receive satisfactory ratings under two separately bank’s CRA performance evaluation.
regulatory burden. rated tests: the small bank lending test and a For more information, contact Allen North
The asset size threshold for small banks new, flexible community development test that at (314) 444-8826 or toll-free at 1-800-
has been raised from $250 million to include evaluates community development loans, invest- 333-0810, ext. 44-8826. Bankers also may
2
assets of less than $1 billion, without regard ments and services in light of community needs register for upcoming outreach seminars to
www.stlouisfed.org
to holding company affiliation. Intermediate and the bank’s capacity. learn more about the new guidance. (See the
small banks—banks with assets between For all banks, the definition of community Calendar section on Page 6.) ■
$250 million and less than $1 billion—will no development has been expanded to include
Federal Reserve Increases Number
of Cash Depots
A good idea catches on fast. In order to reduce costs, while also keeping
customers happy, the St. Louis Fed recently discontinued cash services
at the Little Rock and Louisville branches and established cash depots.
“We asked ourselves, ‘Are we located where we need to be, compared
to where we were when we began our operations?’” says Baumgartner.
Since the founding of the Federal Reserve System in 1913, the
Now the boards of directors for all Reserve banks, the Board of Governors population has shifted and business climates have changed. Yet, despite
and the Fed’s Conference of Presidents have approved and announced the increased usage in electronic payments over the past few years, the
locations for three additional depots which will open within the next six to committee found that cash remains not only a vital part of the payment
12 months. system but also is increasing. By the end of 2004, about $720 billion of
Under the cash depot system, the Federal Reserve signs a contract with U.S. currency was in circulation, 88 percent more than 1994.
a third party, usually an armored carrier, which then accepts cash deposits The committee examined several possibilities before deciding on four
and delivers orders for financial institutions. The Federal Reserve pays all possible options:
transportation costs between the Reserve bank office and the depot opera- • establish cash depots;
tor, and the operator must follow strict procedural guidelines. • identify new locations to offer currency services;
A Federal Reserve office in a different city maintains the responsibility
for counting deposits and preparing orders. Currently, Memphis services • make no changes and continue regular service; or
the Little Rock depot, while Cincinnati is servicing the Louisville depot. • shut down cash services at some locations, which would require some
For the new cash depots, Atlanta will serve Birmingham, Dallas will serve commercial banks to receive services from another Fed location farther
Oklahoma City, and Seattle will serve Portland, Ore. from their bank.
So far, the transition to cash depots has gone smoothly with little to no The decision became apparent after the Fed’s Retail Payments Office
impact on commercial bank customers. John Baumgartner, vice president decided to discontinue check operations in Little Rock and Louisville.
of Cash Operations at the St. Louis Fed, credits good planning, which began Without check processing, the Cash department would have to pick up all
about 18 months before the depots were created. No specific dollar figures support and overhead costs for those two facilities. The Fed’s Cash Product
are in yet, but the Fed has already seen dramatic cost savings. Office had also instructed the Eighth District to maintain customer service
“The Eighth District basically became the proving ground to show that without dramatically increasing costs.
cash depots could work for the System,” says Baumgartner. “We started Baumgartner explains, “Our senior management felt that cash depots
the ball rolling, and I’m proud to say that our staff will be assisting other were the best solution for maintaining a service presence in our markets,
districts as they begin their transition to cash depots.” with a minimal impact on costs to the financial institutions we serve. If we
The move to cash depots began with the Strategic Direction Project, had gone to a full shutdown, for instance, customer service as well as cost
undertaken by the Fed’s Council of Presidents, which studied cash service would have been affected. But with cash depots, we’re proving to financial
across the country. During the project, the committee examined the popu- institutions that our focus is not just to reduce costs—we also value our
lation and the volume of currency usage in the markets the Fed serves. customer service relationships.” ■
RegionalRoundup
St. Louis Fed Publishes Resource Guides 2005 Economic Policy Conference • terrorism-risk insurance and
The St. Louis Fed has pub- Appeals to Bankers insurance against natural
lished two new resource guides, The St. Louis Fed’s 2005 disasters; and
which are designed to help small Economic Policy Conference, • other security-related risks.
and micro businesses located in “Federal Credit and Insurance The final conference session
and near Little Rock and Mem- Programs,” will be held Oct. will be a panel discussion that
phis. Both the Little Rock and 20 and 21 in St. Louis. Leading evaluates the current state of
Memphis editions of The Resource scholars will discuss the evolving federal credit and insurance pro-
Guide for Small Businesses list role of the federal government in grams and that looks toward the
many resources for startup busi- the private credit and insurance future of these programs.
nesses and existing businesses markets. Sessions will address The conference agenda is
wishing to expand. Readers an array of existing federal pro- available at http://research.
also will find information about grams, including: stlouisfed.org. For more details,
nontraditional lending sources • Social Security, Medicare contact Denise Cain at denise.
and where to obtain technical and Medicaid; a.cain@stls.frb.org or (314) 444-
expertise. • Small Business Administra- 8567, or toll-free at 1-800-333-
The guides can be downloaded tion and other loan-guaran- 0810, ext. 44-8567. ■
at www.stlouisfed.org/ tee programs;
community. Then click on • federal housing programs,
“Other Publications.” For more including housing-related
information, contact Amy Simp- government-sponsored
kins at (501) 324-8268 in Little enterprises;
Rock or Dena Owens at (901) • deposit insurance and
579-4103 in Memphis. defined-benefit pension
guarantees;
“FedACH,” “FedLine,” “FedLine Advantage” and “FedWire Funds” are either registered or unregistered trademarks or service marks of the
Federal Reserve Banks. A complete list of marks owned by the Federal Reserve Banks is available on www.frbservices.org.
Are We Saving Enough?
By Kevin L. Kliesen