HERE'S WHAT WE'RE PREPARED TO HELP YOU ADDRESS:
GET ON TOP OF THOSE NON-PERFORMERS NOW.
- REGULATORS DON'T LIKE TO TELL YOU THINGS ABOUT YOUR LOAN PORTFOLIO YOU DIDN'T KNOW, AND THEY DON'T WANT TO TELL YOU HOW TO FIX IT.
- THE SOONER YOU MAKE A RECOVERY PLAN, THE MORE YOU WILL RECOVER.
- ARE YOU THE SQUEAKING WHEEL THAT WILL GET GREASED WHEN THE BORROWERS DO GET SOME CASH, OR ARE YOU BEING NICE GUYS TO PRESERVE THE BORROWER RELATIONSHIPS?
- THE CONDITION OF THE LOAN PORTFOLIO IS NOT ALWAYS THE PRIMARY REASON THE REGULATORS ISSUE ENFORCEMENT ACTIONS:
• MORE OFTEN, IT IS THE CONDITION COUPLED WITH THE ABSENCE OF APPROPRIATE ACTION BY MANAGEMENT.
• IF MANAGEMENT CAN DEMONSTRATE THEIR UNDERSTANDING OF THEIR PREDICAMENT AND THEIR WILLINGNESS TO ADDRESS IT IN A VIGOROUS AND TIMELY MANNER, THERE CAN ACTUALLY BE OPPORTUNITIES TO NEGOTIATE WITH THE REGULATORS.
- SO DON'T PUT OFF, FOR ANY REASON, GETTING STARTED ON A FORMAL ACTION PLAN FOR THE NON-PERFORMERS.
THEN, WHEN WE'VE TURNED OFF THE WATER, WE CAN START MOPPING UP THE OTHER ISSUES:
- WHAT IS THE MOST EFFECTIVE WAY FOR OUR DIRECTORS TO SPEND THEIR TIME?
• SHOULD THEY BE INVOLVED IN APPROVING LOANS?
• WHAT INFORMATION SHOULD THEY REVIEW AT REGULAR INTERVALS?
• WHAT FORMATS PRESENT THAT INFORMATION IN THE MOST USEABLE FORM?
- WHAT SHOULD THE LOAN POLICY SAY?
• HOW DOES OUR BANK DEFINE, MEASURE AND CONTROL RISK AND OUR EXPOSURE TO IT?
• CONCENTRATIONS? WHAT'S REASONABLE FOR OUR MARKET? HOW MUCH OF OUR CAPITAL ARE WE WILLING TO RISK ON A SINGLE TYPE OF LOAN OR BORROWER?
• HOW DO WE DEFINE "CREDIT QUALITY"? HOW DO WE MEASURE IT?
- WHAT SHOULD OUR PROCESS LOOK LIKE?
• IS IT EFFICIENT?
• DOES IT HAVE INTEGRITY?
- WHOSE JOB IS IT TO SPOT WEAKNESSES IN LOANS?
• THE CHIEF LOAN OFFICER?
• THE LENDERS?
• LOAN REVIEW?
• THE AUDITORS?
• THE EXAMINERS?
- WHAT CRITERIA DO WE USE IN SELECTING, TRAINING, MEASURING AND COMPENSATING OUR LENDING STAFF?
• HIRING CRITERIA?
• POSITION DESCRIPTIONS?
• PERFORMANCE STANDARDS?
• OBJECTIVES?
• ONGOING EDUCATION AND TRAINING?
• EVALUATION?
|