Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall...

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Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan Office of Financial and Insurance Services

Transcript of Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall...

Page 1: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Industry Trends, Supervisory Concerns and The Directors/OFIS

Role Addressing Them

MCUL Fall Leadership Conference

John J. Kolhoff, Assistant DirectorMichigan Office of Financial and Insurance Services

Page 2: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Agenda

Industry Trends Supervisory Concerns Role of the Director and Regulator Questions

Page 3: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Industry Trends

Page 4: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Industry Trends Michigan credit unions remain safe and

sound. Well capitalized with aggregate Net Worth to

Avg. Assets of 12.17%.

Page 5: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Net Worth / Total Assets

10.50

11.00

11.50

12.00

12.50

13.00

2003 2004 2005 2006 2007

Per

cen

tag

e

Page 6: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Industry Trends Earnings trending downward from .64% at

December 2006 to .30% ROA. NIM has stabilized at 4.76%. Provision for ALLL to Avg. Assets up

from .39% at December 2006 to .74% at June.

Page 7: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Return on Average Assets

0.00

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

0.90

1.00

2003 2004 2005 2006 2007

Per

cen

tag

e

Page 8: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Industry Trends Aggregate delinquency climbing from 1.08%

of total loans to 1.34%. Aggregate charge offs stable at .53% of

average loans. Aggregate loan delinquency up 24% from

December 2006 at $281 million. First mortgage delinquency (fixed rate) up

74% to $98.5 million (or 1.20%). First mortgage delinquency (adjustable) up

51% to $12.1 million (or .48%).

Page 9: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Delinquency

0.00

0.20

0.40

0.60

0.80

1.00

1.20

1.40

1.60

2003 2004 2005 2006 2007

Per

cen

tag

e Total Delinquency

1st Mtg Fixed

1st Mtg Adj

Oth RE Fixed

Page 10: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Net Charge Offs / Average Loans

0.00

0.10

0.20

0.30

0.40

0.50

0.60

0.70

2003 2004 2005 2006 2007

Per

cen

tag

e

Page 11: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Industry Trends Commercial RE/Construction/Land

Development commitments up 381% to $32.7 million (2.6%).

Total MBL delinquency up 311% to $16.8 million.

Number of MI institutions down to 227 (from 250 at 12/05).

Mergers are of like kind as well as small to larger institutions. Trend is expected to continue.

MI has not shared in the economic improvements seen nationwide.

Page 12: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Supervisory Concerns

Page 13: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Supervisory Concerns

Increased credit risk due to falling property values. Lack of recognition of Commercial purpose real estate

loans. Unrecognized losses due to falling market values

and/or management’s perception of low credit risk. Liquidity/market risk impact on CU who are

inexperienced in the product. Non traditional products slowly moving into Michigan.

Real Estate Lending

Page 14: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Supervisory Concerns

Lack of due diligence on new programs Lack of recognition of the more volatile market

values of commercial real estate values. Lack of understanding on how the new products

impact the inherent credit, liquidity, and interest rate risk of the institution.

NCUA 723 compliance.

Commercial Lending

Page 15: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Supervisory Concerns

CU have significant connection because of their SEG based roots.

Recent “geographic” FOM diversification has helped but as we know doesn’t mitigate the regional connection to employers.

Credit Union Technical Assistance Program.

Automotive Industry

Page 16: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Supervisory Concerns

Narrowing margins and member service competition has pushed CU to diversify into more complex balance sheet products and riskier services.

Some management teams have not completed appropriate due diligence, set up adequate control systems and/or demonstrated an understanding of the implication these products have on the institutions risk profile.

Management

Page 17: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Supervisory ConcernsMichigan Chartered

CAMEL Components 3, 4 or 5

C 7 (3.1%) A 46 (20%) M 57 (25%) E 81 (36%) L 12 (5.3%)

Page 18: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Supervisory Concerns

Average Credit Union Size $89.6 million Average Problem C.U. Size $38.1 million

Excludes CenCorp

Michigan Chartered3, 4 or 5 Institutions

Page 19: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Director’s Role

Page 20: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Directors Role

Understand the duties prescribed by the bylaws, common law, and regulations.

Have an interest an ability to keep well informed about the CU.

Be loyal to their office and not engage in activities adverse to the CU.

Generally a Director should:

Page 21: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Directors Role

Possess the integrity not to use their office for personal benefit.

Be Capable of retaining confidences. Be able to evaluate facts, free from

prejudices or personal interests, in reaching sound, independent decisions.

Generally a Director should:

Page 22: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Directors Role

Differentiate their “oversight” role from the “hands on” participation of executive management.

Remember that their authority rests with the board, not with each individual director.

Understand their primary responsibility to protect the members interests.

Generally a Director should:

Page 23: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Directors Role

Be involved in communications with auditor/examiners.

Ensure Safety and Soundness and accounting deficiencies are handled appropriately.

Generally a Director should:

Page 24: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Regulators Role

Ensure the Safety and Soundness of the CU Industry.

Ensure compliance with appropriate regulations.

Ensure compliance with Board approved policies.

Report to the chartering agent, insurer AND the Board of Directors findings.

Page 25: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

Questions?

Page 26: Industry Trends, Supervisory Concerns and The Directors/OFIS Role Addressing Them MCUL Fall Leadership Conference John J. Kolhoff, Assistant Director Michigan.

John J. Kolhoff

Email: [email protected]

Phone No: 517-373-6930

Office of Financial and Insurance Svcs

611 West Ottawa

Lansing, MI 48909