Rescuing Bank of America

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Rescuing Bank of America:

The Case for an Organizational Development Nexus Approach

Organizational DevelopmentORG505

Cynthia Bage

Colorado State University Global Campus

Dr. Donna Graham

March 4, 2012

This work is licensed under the Creative Commons Attribution-NonCommercial-NoDerivs 3.0

Unported License. To view a copy of this license, visit http://creativecommons.org/licenses/by-

nc-nd/3.0/ or send a letter to Creative Commons, 444 Castro Street, Suite 900, Mountain View,

California, 94041, USA.


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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 bankowes 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 ofBACs

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 lenderis 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 ofconsumer 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 rosterexhibits 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 OneStructural 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 TwoAccountability 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 ThreeUse 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 FourField 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 FiveLean 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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