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Rescuing Bank of America:
The Case for an Organizational Development Nexus Approach
Organizational Development ORG505
Cynthia Bage
Colorado State University Global Campus
Dr. Donna Graham
March 4, 2012
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Abstract
As an organization in need of structural revitalization, Bank of America Corporation (BAC) has
been in a state of fiscal crisis. Its lack of transparency and accountability could present a
challenge for an OD practitioner. Through a combination of results-based monitoring and
evaluation (M&E) and SWOT analysis, it can be possible to reinvigorate BAC through structural
downsizing, accountability measures, Appreciative Inquiry (AI), field theory interventions based
on emotional intelligence (aka: Change MAP), and Six Sigma implementation. Global financial
market conditions and external stakeholder demands for accountability could impact change
decisions, suggesting a need to reevaluate BACs organizational culture. Recommendations
include a voluntary conversion of investment and insurance divisions into independent
employee-owned companies in order for BAC to focus solely on creating stability for its more
traditional financial services.
Keywords: banking, organizational development, Bank of America Corporation
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Rescuing Bank of America:
The Case for an Organizational Development Nexus Approach
Since the onset of the current economic crisis, Bank of America Corporation (BAC) has
experienced a diminished book value per share (Ycharts, 2012) as well as a decline in financial
stability despite governmental intervention activities (Taibbi, 2012). Consumers and financial
experts have remained skeptical that BAC can remain relevant as a financial services provider
based on growing resentment over its refusal to adequately modify securitized mortgages slated
for foreclosure proceedings (Bank of America Corporation, 2011). It is apparent that BAC
requires a thoughtful and strategic Organizational Development (OD) process based on a
radically experimental approach. Through a nexus of five strategic OD interventions as well as a
reassessment of its core organizational principles, it might be possible to transform BAC into an
efficient and stable financial operation.
Organizational Diagnosis: Methodology and Challenges
In order to analyze BACs organizational effectiveness, I utilized its most recent SWOT
report summary (Datamonitor, 2011) as well as self-reported data submitted to the Securities and
Exchange Commission (SEC). Through both reports, I ascertained both positive elements and
institutional weaknesses that have impacted BACs public image as well as the organizations
overall performance. In perusing the BACs most recent SEC Form 10-K filing, it was crucial to
understand why customer deposits are categorized as liabilities. For this clarification, I turned
to AmosWEB (2012) which noted, The most important liability category is depositsfinancial
wealth that others have placed with the bank for safekeeping. The bank owes this wealth to these
depositors [emphasis added] ( 2). For this reason, depositor accounts traditionally have been
classified as liabilities and not assets because they are not directly-owned liquid assets.
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The challenge of using standardized accounting practices is further complicated by the
potential abuse of such standards to dilute accurate analyses of assets and liabilities in this
industry. It is vital for an OD practitioner to ascertain a proper organizational diagnosis of what
is ailing any financial institution, and in so doing can optimally understand its true organizational
status. This can be a challenge due to the evolving complexities of accounting standards, which
in turn may enable an organizational culture based on pseudo-transparency (i.e.: creating the
illusion of accountability where none exists). The Financial Accounting Standards Board (n.d.)
issued no fewer than 29 accounting standards updates in 2011 including pre-codification rule
SFAS no. 159, the impact of which can obfuscate any asset/liability ratio analysis. In order to go
beyond this faade, there needs to be a more reliable method to assess organizational vitality.
Group-Level Data Gathering Instruments
Any use of analytically-based OD interventions such as lean Six Sigma requires the use
of tangible data sets in order to better implement those aspects of OD improvements. In order to
create the best possible verified data, a practitioner would need to go beyond pre-existing self-
reporting measures and determine which systems can offer the most accurate statistical
information. Through a combination of results-based evaluation tools and supplemental SWOT
analysis reports, it is possible to derive a more accurate statistical profile of BACs
organizational reality and gauge the appropriate levels of intervention while creating realistic
success benchmarks.
Results-based Monitoring and Evaluation Systems
The World Bank (Kusek & Rist, 2004) has proposed using results-based monitoring and
evaluation (M&E) to understand the effectiveness of governments in developing nations,
stating that it is a powerful public management tool that can be used to help policymakers and
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decisionmakers track progress and demonstrate the impact of a given project, program, or
policy (p. 1). Such a tool can also be effective for evaluating non-governmental organizations
(NGOs) as well as private organizations such as BAC. Jones (2011) has noted the benefits of
M&E in organizational development: The production and use of M&E information during and
after an intervention is generally seen as a central plank in systems for reporting and
accountability, in demonstrating performance, and/or for learning from experience and
improving future work (p. 3). Given BACs cultural trend to rely on pseudo-transparency
measures, the use of results-based M&E can give a more accurate impression of specific
organizational needs.
SWOT Analysis
One of the more traditional forms of performance evaluation is the SWOT analysis.
While some OD practitioners have used such reports typically as default analysis tools, the
results may not be sufficient to provide necessary information to determine appropriate
interventions. As one product management professional noted within the context of a Linkedin
discussion, SWOT is mostly applicable for static conditions of business. For dynamic or rapidly
changing businesses such as knowledge intensive industries, SWOT may not be that helpful
(Niraj K., 2008, 1). Therefore, BAC would benefit from a two-tiered approach that uses results-
based M&E as a primary tool with SWOT results utilized as supplemental information.
Individual Data Gathering Instruments
There are several options for gathering data from individual customers and employees,
and it can be challenging and somewhat daunting to find a set of tools that provide accuracy and
relevancy. Such toolsets must be compatible with the proposed interventions in order to provide
a better fit but also give compatible data for such diverse processes. The theoretical nexus-
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based intervention approach that I suggest herein may require redundant data gathering tools;
therefore, it is crucial for any individual surveys to merge any duplicative elements while
addressing unique concerns outside the range of commonality. For example, similar humanistic
elements address theories that support views that human emotions are intrinsic performance
motivators (Friedman & Ghini, 2010; Whitney & Trotten-Bloom, 2010). In contrast, the use of
Six Sigma can provide a strategic, focused approach to organizational effectiveness (Cummings
& Worley, 2005). Through a balance of both scientific and humanistic elements, it is possible to
create a more holistic individual survey instrument that accurately measures all perceived
dimensions of an organization.
Targeted Improvement Areas
Regulatory Compliance
When BAC submitted its FY 2011 10-K form to the SEC, the organizational authors
balked at certain mandated compliance requirements, particularly those pertaining to Fannie Mae
(FNMA) regulations on consumer mortgage recissions:
The announcement also confirmed FNMAs view of its position that a mortgage
insurance companys issuance of a [Mortgage Insurance] rescission notice constitutes a
breach of the lenders representations and warranties and permits FNMA to require the
lender to repurchase the mortgage loan or promptly remit a make-whole payment
covering FNMAs loss even if the lender is contesting the mortgage insurers rescission.
We have informed FNMA that we do not believe that the new policy is valid under our
relevant contracts with FNMA [emphasis added] and that we do not intend to repurchase
loans under the terms set forth in the new policy (Bank of America Corporation, 2011, p.
5).
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In addition, the report also stressed that investigations into foreclosure practices could result in
material fines, penalties, equitable remedies, additional default servicing requirements and
process changes, or other enforcement actions, and [], accordingly, could have a material
adverse effect on our financial condition and results of operation (Bank of America
Corporation, 2011, p. 7).
This specific report essentially delegitimized valid organizational concerns by stating that
accountability measures would weaken BACs overall financial strength, yet there is no mention
of balancing such losses through expenditure reductions in executive compensation and bonuses.
One of the most daunting challenges within OD is in finding the most effective trade-offs
between strategic and humanistic needs, and this balance is best determined when all
contingencies are included in the change process, creating an integrated and functional outcome
(Cummings & Worley, 2005). By ignoring the need for distributive justice, BAC most likely will
continue utilizing an approach best described through the metaphor of placing an adhesive
bandage on a fatal wound.
Creating Good Faith among Consumers
When an organization such as BAC offers a product or service to customers, its success
depends upon an increase in consumer trust. Absent that trust, an enterprise can devolve into an
entropic decline while consumers embrace other, more trustworthy competitors (Urban, 2003).
Recently, BACs decision to charge a monthly debit card fee backfired when customers staged
nationwide move your money protests in conjunction with the Occupy Wall Street movement
(Rothacker, 2011). The popular term good faith describes this component of consumer trust
that must exist for BAC to grow and stabilize for the future, and any decisions that diminish this
trust require sufficient analysis before being announced and/or implemented.
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Expanding Leadership Diversity
BACs executive leadership roster exhibits a 9:4 male/female ratio of a strictly
homogenous racial/ethnic background (Bank of America, 2012). This apparent lack of diversity
is one that can be problematic within the financial sector as it does not mirror the diversity of the
general population (Tomasdottir, 2010). This is not a call for enforcing executive hiring quotas,
but rather suggests a need to improve the qualified pool of diverse leadership candidates from
within the BAC organization based on ethical considerations that surpass legally-mandated
diversity requirements (Epstein, 2008).
Recommended Interventions
After assessing BACs organizational state, an OD practitioner might wish to combine
seemingly contradictory elements to create a nexus-based and holistic intervention plan in an
effort to improve long-term organizational health. Through a combination of structural
downsizing, sustainable and ethical accountability practices, Appreciative Inquiry concepts,
applied field theory via a Change Management Process, and expert implementation of lean Six
Sigma tools, it is possible to create an approach that can address the complexities of BACs
organizational structure. This theoretical approach may seem time-consuming, but can provide
BAC the discipline needed to shift from short-term reactivity to a comprehensive long-term
solution that can provide both immediate stability and continued improvement. The ultimate goal
is for long-term organizational survival, which BAC has routinely sacrificed through its short-
term triage approach.
Intervention One Structural Downsizing
While BAC has attempted to use exponential growth and merger/acquisition (M&A)
strategies to increase growth within the organization, a recent SWOT analysis noted a
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fundamental weaknesses created through acquiring Countrywide and, more recently, Merrill
Lynch (Datamonitor, 2011). Unfortunately, former CEO Ken Lewiswho was later investigated
in the State of New York for refusing to disclose to shareholders the deleterious impact of the
Merrill Lynch deal (Taibbi, 2011)touted these same acquisitions as the bright spots for the
first quarter [of FY 2009] (Baritromo, 2009, p. 18). The true impact of such mergers have been
hidden through the use of statistical models that ignore variables such as the number of initial
bidders prior to the M&A activity as well as the interstate/intrastate specificity of such deals (Al-
Sharkas & Hassan, 2008). Without accurate data inputs, it is highly unlikely that BACs
leadership can set and achieve realistic OD goals.
Wilber (2011) has suggested implementing an external regulatory mandate for reducing
the size of banking institutions in an attempt to create stability within the financial services
industry. Such an approach depends upon the will of federal lawmakers and regulators; therefore,
it would be preferable for BACs executive leadership to set an example for the rest of the
industry through voluntary reductions-of-scale. Structural downsizing can work in a way that
does not create a greater pool of unemployed individuals if each ancillary service (i.e.:
investment services, life and property insurance) incorporates as separate, employee-owned
companies. This can permit BAC to focus and fine-tune its operational structure in a way that
provides short-term stability of assets management while helping it to focus on providing more
traditional banking and lending services over the long term.
Intervention Two Accountability Measures
Sartor (2011) complained that, in reference to BACs 2010 Corporate Responsibility
Report, [BAC] has spent $11.6 billion [out of a total of] $20 billion in a series of [strategic
environmental] investments that are not specifically listed in the report and dont appear to be on
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the companys website either ( 4). While this is merely one symptom of BACs accountability
deficit, there are other signs that point to an overall need for greater organizational transparency.
Its SEC 2011 10-K report offers summaries of selective data over a five-year period, which is the
minimum required by federal regulation:
To derive the FTE basis, net interest income is adjusted to reflect tax-exempt income on
an equivalent before-tax basis with a corresponding increase in income tax expense. For
purposes of this calculation, we use the federal statutory tax rate of 35 percent. This
measure ensures comparability of net interest income arising from taxable and tax-
exempt sources (Bank of America Corporation, 2011, p. 38).
However, according to Cafferty (2010), BAC ended [2009] with a tax benefit of almost $2
billion ( 7), which may or may not have been corrected in future tax calculations as described
in the most recent SEC 10-K filing.
As it turns out, financial reporters have corroborated that BAC has routinely engaged in
statistical duplicity. Trainer (as cited in Taibbi, 2012) recently notes that BAC recently used a
brand new FASB pre-codification ruleSFAS no. 159which has allowed the organization to
artificially boost earnings when the value of their own debt declines ( 6) within the context of
their filing SEC form 10-K. In lay terms, BAC was able to artificially re-state earnings when its
own credit quality went into the tank (Taibbi, 2012, 6). This accounting legerdemain in
BACs SEC filings apparently denotes a culture of secrecy within the organization, which could
lead to future instability if not corrected. In order for an OD practitioner to provide accurate
diagnostic feedback, it is essential for BAC to give fully accurate and accountable data
unfortunately, this apparent culture of obfuscation can sabotage the change process.
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Intervention Three Use of Appreciative Inquiry
One of the more promising developments in OD is a tool known as Appreciative Inquiry
(AI). Whitney and Trotten-Bloom (2010) have promoted the view that [AI] suggests that human
organizing and change at its best is a relational process of inquiry, grounded in affirmation and
appreciation (chapt. 1, 2). AI also creates a more democratic input process within an
organization by involving those within the lower levels to help plan, evaluate, and implement the
AI process. This democratization can contribute to the stability and growth of BAC by ensuring
that upper level decision makers and front level employees alike understand their role in
creating and maintaining the desired evaluative culture (Preskill, 2007, p. 6). In addition,
Srithika and Bhattacharyya (2009) have noted AIs positive role in overcoming change resistance
during the unfreezing process associated with Lewins field theory.
Intervention Four Field Theory-based Change MAP
Freedman and Ghini (2010) developed a continuation of Lewins field theory through
applying Emotional Intelligence (EQ) concepts, which they christened the Change
MAnagement Process (aka, Change MAP) in an attempt to overcome fear-based resistance to
organizational change. [This] process helps managers develop a commitment to shared vision of
a better organization, implement new initiatives while managing resistance, and then build clarity
and alignment in a continuous improvement process (chapt. 2, 101). Conley (2010) affirmed
the effectiveness of the Change MAP tool as a means of establishing trust through transparent
accountability measures while creating a consistency between verbalized goals and leadership
buy-in. This process employs a continuous change process that utilizes EQ as its central
operating component (Friedman & Ghini, 2010). While it shares certain humanistic elements
with AI, both can work in tandem and contribute to a more democratic change process.
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Intervention Five Lean Six Sigma Implementation
Aruleswaran (2009) has described the growing popularity of lean Six Sigma within
financial institutions as a means to improve efficiency and customer satisfaction. It is a tool that
GE Financial successfully implemented to create growth and promote efficiency (Cummings &
Worley, 2005), which can also give BAC similar advantages in a highly competitive financial
services marketplace. When implemented properly, lean Six Sigma can consolidate the size of
data warehousing architecture (Six Sigma Training Assistant, 2009), which is particularly useful
for globalized organizations such as BAC. As a purely analytical tool, it complements more
humanistic interventions without unnecessary duplication of goals and information while
satisfying the need for empirical data sets during the OD process.
Intervention Challenges
The benefit of employee-owned dispersal of ancillary services may not fit with an M&A-
based culture, although Burck (1984) once foretold the eventual result of such a business model
as being harmful to local communities through the creation of institutions vulnerable to these
orgies of corporate cannibalism that are initiated by Pearl Harbor tactics (p. 660). Because of
such forces, an OD practitioner devoted to implementing accountability measures could face
resistance based on BACs transparency-related objections in its 2011 SEC 10-K filing. More
humanistic OD strategies might also elicit resistance due to their democratizing effect on BACs
organizational culture. The one intervention that may prove less daunting would be lean Six
Sigma, although it still requires a great deal of accountability and open communication. It is
more widely accepted as an OD process and can be successful, provided that an OD practitioner
has achieved the status of a Master Black Belt practitioner (Six Sigma Training Assistant, 2011).
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Future OD Trends
Globalized Market Concerns
BACs leadership has embraced a long-term global expansion of their services (Bank of
America Corporation, 2011), although current global economic problems have created an
immediate need to cut costs through minor management reductions in Australia and Hong Kong
(Tan, 2012). If the global economy continues to decline, BACs current plan is to distribute loss
throughout the organization by way of systematic risk management protocols (Bank of America
Corporation, 2011). While this flexibility seems pragmatic, BAC could sustain further losses
which could impact global financial markets, culminating in sustained disruption in response to
the effects of well-intended global austerity measures (Kitromilides, 2011). The fate of
international economics and the globalized banking system are interdependent, permitting both
elements to collapse simultaneously under aforementioned entropic forces propelled by BACs
status quo policies.
Financial Sector Industry Concerns
While consumers might assume that banking and investment services are products
provided by banks owned by organizations such as BAC, the reality is that any banks real
product is its internal accounting process (AmosWEB, 2012). Therefore, it helps to understand
this reality before looking at any of the aforementioned interventions in a practical way. An OD
practitioner who understands this nuance can develop strategies to overcome and transform
change-resistant behavior into positive action using both AI and Change MAP strategies.
Regrettably, BACs leadership has expressed a resistance to further regulatory restrictions on
their profit margin (Bank of America Corporation, 2011) and in so doing will likely continue to
engage in dysfunctional cultural behaviors that imperil the organizations long-term future.
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External Stakeholders as Cultural Change Agents
Ratigan (2012) has criticized the dominant financial industries culture as one that rewards
grift rather than thrift and has suggested a need to shift that culture into one that rewards
productivity:
[I]f an organization can get its interests back into alignmentfor example, if banks
refused to give bankers bonuses when they failthen it can motivate more productivity.
If bankers can make money only when they help society solve problems, then that is what
will happen because it is the only way bankers make money (chapt. 1, 40).
The values-based change that Ratigan (2012) posits is one centered on an ethos of visibility,
integrity, choice, and interests, all of which exist as components of accountability and
transparency. Furthermore, the collective stakeholders who gravitate towards the Occupy Wall
Street (OWS) movement consider themselves a diverse demographic who agree upon concerns
such as transparency, accountability, empowerment, the value of labor and individual privacy,
the need for education as a human rights concern, and an awareness of individual privilege and
its impact on society (The Sparrow Project, 2011).
When BAC customers recently joined with OWS supporters to express their
dissatisfaction with industry-related foreclosure practices, it resulted in an increased number of
depositor account closures (Digitale, 2011). Some branch managers feared a disruption to the
organizational supply chain and instinctively closed individual locations during an Occupy the
Banks event (Hall, 2011). According to Ychart (2012), BACs book value share was beginning
to improve until the beginning of October 2011, after which it failed to recover.
As Goodman (2011) asserted, Bank of America may lose upward of $185 billion from
customers closing accounts ( 23), while any long-term sustained account closure activity could
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serve to destabilize BAC and could result in even more ineffective short-term survival measures
based on status quo projections. Therefore, BACs executive leadership would do well to address
these stakeholder concerns and create long-term change in response to legitimate public criticism
of operational practices.
Conclusion
While BAC survives in its present organizational structure, it is unclear how long that
survival will last beyond the current fiscal year. Without a comprehensive and holistic OD
intervention based on humanistic and statistical practices, it is unclear if this organization will be
able to survive past the end of the current global economic crisis. Its leadership seems to be in a
state of denial exacerbated by a strategic shift in financial accounting standards combined with
external governmental interventions and an internal cultural denial of organizational
responsibility. While its current organizational structure is relatively young, it could soon
collapse and destabilize a fragile global economic system that cannot afford to fail.
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