fasb proposes disclosures for liquidity and …...“the liquidity risk disclosures would be...

OVER A CENTURY: BUILDING BETTER BANKS - HELPING COLORADANS REALIZE DREAMSRY: BUILDING BETTER BANKS - HELPING COLORADANS REALIZE DREAMS

September/October 2012

FASB Proposes Disclosures for

Liquidity and Interest Rate Risks

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September • October 2012

3

The Colorado Bankers Associat ion is proud to presentCOLORADO BANKER as a benefit of membership in the Association. No member dues were used in the publishing of this news magazine. All publishing costs were borne by advertising sales. Purchase of any products or services from paid advertise-ments within this magazine are the sole responsibility of the consumer. The statements and opinions expressed herein are those of the individual authors and do not necessarily represent the views of COLORADO BANKER, or its publisher Media Communications Group. Any legal advice should be regarded as general information. It is strongly recommended that one con-tact an attorney for counsel regarding specific circumstances. Likewise, the appearance of advertisers does not constitute an endorsement of the products or services featured by Media Communications Group.

5 Chairman’s Message

6 A Word From CBA...

8 FEATURE: FASB Proposes Disclosures for Liquidity and Interest Rate Risks

10 FEATURE: Corporate Account Takeover

14 FEATURE: Financial Literacy 2.0: A New Model for Educating Children and Young Adults in Personal Finance

15 FEATURE: Employee Communications: How to Be Remembered and Repeated through Video

Don Childears President/CEO

Jenifer WallerSenior Vice President

Amanda RogowskiDirector of Marketing

Caroline JoyDirector of Communications

Rachel PaulmanExecutive Assistant

Margie MellenbruchBookkeeper*

Craig A. UmbaughCounsel*

Jim ColeLobbyist*

Melanie LaytonLobbyist*

Garin BrayLobbyist*

Mitch LaycockBancInsure

* outsourced

Amanda Rogowski, CBA Director of Marketing, [email protected]

140 East 19th Avenue, Suite 400Denver, Colorado 80203

voice: 303.825.1575 – fax: 303.825.1585

Websites:www.coloradobankers.org

www.smallbizlending.orgwww.financialinfo.org

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5

Leadership is Critical to the Future of Our IndustryLet’s work together to ensure that the future of our industry is a strong one.

Dear CBA Members,

Over the past thirty years I have had the honor of being a banker in Colorado and have served different banking companies in markets all over the state. During this time, there has always been a tradition of bankers being the leaders in our Colorado communities. In addition to adding value to our customers, shareholders and employees, we were also committed to adding value to the communities we serve. You found bankers everywhere. They served on leadership boards across the spectrum, from economic development organizations focused on creating jobs to philanthropic organizations providing business experience to non-profits and social service organizations. We have led fundraising efforts for multiple organizations and provided political advice and support to mayors, governors and senators in rural Colorado.

This kind of leadership role is critical to the future of our industry and of our state. As bankers, even in spite of recent economic difficulties and attacks on our industry, I believe we must continue to provide leadership on all fronts.

I challenge all of us to build cultures in our banks which remain committed to supporting all parts of our communities. I challenge all of us to invest in our up-and-coming bankers and provide them with the leadership skills that can allow them to make a difference in the bank and in our communities. Leadership skills do not just happen. They need to be developed. Let’s commit to that development.

To this end, the Colorado Bankers Association strives to provide this kind of leadership training. Through our committees like the Government Affairs Committee and Legislative Review Committee, we teach bankers about the legislative process and the impact that bills can have on our industry. We introduce them to Colorado’s leg-islative leaders in hopes of building relationships. We have multiple opportunities for our bankers to meet with political leaders at the local state and national level through legislative lunches and legislative briefings. We pro-vide educational programming like our Economic Forum where we bring in outside speakers to give our bankers insights into the strengths and future of our economy. We provide our bankers access to regulatory leaders and other professionals who can expand our horizons regarding the future of our industry.

We are committed to developing leadership in our industry. We need to be part of the solution of helping our country emerge from a difficult recessionary time by helping create jobs and providing leadership. We need to work on improving the image of our industry and ensure that we hold the same kind of high leadership status that our industry has experienced over the past thirty years. I encourage you to learn more about how your bank can become a part of the solution and experience the many benefits and programs the Colorado Bankers Association has to offer. If you would like to learn more about these programs, please contact Amanda Rogowski at the Colo-rado Bankers Association, [email protected], or 303-825-1575. Let’s work together to ensure that the future of our industry is a strong one.

Bruce Alexander, CBA ChairmanPresident & CEO, Vectra Bank Colorado

6


A Word From CBA...

Education Key to ImageWe all want to improve the industry’s much battered

image — an undeservedly bad image. I believe the focus for the industry’s image enhancement has to be on the customer (not on us as the bank) and how we help them meet their needs – and we must talk candidly about big issues like Wall Street, mortgage lending, mortgage servicing, small busi-ness lending, and government regulation. We must answer three questions: 1) Who did what? 2) How do we get out of this mess? 3) How can banks help?

It basically is education that is needed, not spin.Those responsible on Wall Street should bear that bur-

den, not community banks. The reality is that three of the top 12 investment firms are bank affiliated, and the oth-ers are Goldman, Morgan Stanley, Barclays, BNP Paribas, Credit Suisse, Deutsche Bank, Nomura, RBC, and UBS. But the perception is that commercial banking was/is closely tied to Wall Street investment firms, which I believe stems from everybody in finance being called a bank. So the public and public officials assign blame to “banks” which improperly includes community banks.

We should be thinking about public education (not “PR”) that says:• Commercial banks didn’t have much connection to Wall

Street. Only a tiny fraction of the industry did.• Banks generally didn’t originate bad mortgage loans.

For example in CO in 2007, banks and subs did 58% of mortgage lending but only 18% of foreclosures. Conversely nonbanks did 42% of mortgage lending but 82% of foreclosures. That tells who did a good job of underwriting.

• Loan servicing problems largely were caused by sheer volume, much of it out of Freddie & Fannie. There have been government programs, big dollar settlements, servicers’ commitments to do better… While servicers aren’t blameless, still they generally only foreclosed on

those severely delinquent. It generally wasn’t a case of inappropriate foreclosures, just poorly handled ones. Servicers have partially apologized with the settlement – but the public doesn’t buy it.

• Small business has had diffi culty obtaining credit, but little of that was a result of banks being stingy. Customers’ income was gone, low or unstable and their assets were worth far less after 2008 so of course they had trouble getting credit – especially when the banks are under the watchful eye and heavy hammer of regulators. Yes it sucks for them – and us. We commiserate and are doing all we can to help, but we didn’t cause it and aren’t responsible. We wanted to help then and can help now.

• Banks are doing all they can to help consumers and businesses recover, but are severely restricted by government – and it’s getting worse. I know it is diffi cult to explain DFA and Basel III impact but that’s what we need to do. The “ask” isn’t to cut regulation (that’s a goal but not what we ask for). The “ask” is for consumers and businesses to understand the damage yet to come to them as a result of hyper-regulation. Then they can be angry at government and maybe we can make some progress rolling some of it back.

This messaging in time lets most of us in banking hold our head up high and say we didn’t do it but we’re here to help. That sits well with the public and most public officials, and sets the stage for rollback of some of this.

So, the focus has to be on them as the customer. Talk candidly and honestly about the big issues, and answer key questions. An improved industry image basically is educa-tion, not spin.

Don ChildearsCBA President/CEO

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FEATUREARTICLE

“The liquidity risk

disclosures would be

required for all public,

private and not-for-

profit companies;

the nature of the

disclosures will depend

on whether the

company is considered

a financial institution.”

FASB Proposes Disclosures for

Liquidity and Interest Rate Risks

On June 27, 2012, the Financial Account-ing Standards Board (FASB) issued a pro-posed Accounting Standards Update1 that would require new disclosures related to a

company’s liquidity risk (risk of encountering diffi culties while meeting fi nancial obligations) and interest rate risk (risk of fi nancial assets and liabilities to market interest rate fl uctuations). The new disclosures are intended to supplement existing risk disclosures and help financial statement users better understand certain risks inherent in fi nancial instruments.

The liquidity risk disclosures would be re-quired for all public, private and not-for-profi t companies; the nature of the disclosures will depend on whether the company is considered a fi nancial institution. The interest rate risk disclosures only would apply to fi nancial in-stitutions. The information in the proposed

disclosures would be standardized to allow for better comparability between companies.

Liquidity Risk DisclosuresRequired liquidity risk disclosures in the

proposed ASU would include:• A fi nancial institution to disclose carrying

amounts of classes of fi nancial assets and liabilities, including off-balance-sheet fi nancial commitments and obligations, in a table segregated by their expected maturities

• A fi nancial institution that also is a depository institution to disclose information about time deposits, including a table detailing the cost of funding from

CHRIS MERIWETHERCPABKD, LLP



9

the issuance of time deposits and acquisition of brokered deposits, during the previous four fi scal quarters

• An entity that is not a fi nancial institution to disclose expected fi nancial cash fl ow obligations in a table, segregated by their expected maturities, without being required to include the reporting entity’s fi nancial assets in that table

• All reporting entities to disclose available liquid funds, including unencumbered cash, high-quality liquid assets and borrowing availability, in a table

• All reporting entities to provide additional quantitative or narrative disclosure of the company’s exposure to liquidity risk, including discussion of signifi cant changes in the amounts and timing in the tabular disclosures and how they managed those changes during the current period

Interest Rate Risk DisclosuresThe interest rate risk disclosures in the proposed ASU

would require fi nancial institutions to disclose the following:• Carrying amounts of classes of fi nancial assets and

liabilities according to time intervals based on the contractual repricing of the fi nancial instruments

• An interest rate sensitivity table that presents the effects that shifts of interest rate curves could have on net income and shareholder equity

• Additional quantitative or narrative disclosure of the company’s exposure to interest rate risk, including discussion about signifi cant changes in the amounts and timing in the tabular disclosures and how they managed those changes during the current period

While FASB acknowledges the U.S. Securities and Exchange Commission’s (SEC) rules for management’s discussion and analysis (MD&A) currently require certain disclosures about liquidity and interest rate risks, the board felt there was strong demand from fi nancial statement users for audited, standard-ized and consistent disclosures that are complementary to those found in the MD&A of public companies. These disclo-sures would provide additional new information about these risks for nonpublic entities.

The effective date of this ASU will be determined after FASB considers the feedback received from comments; that feedback is due September 25, 2012. For more information, contact your BKD advisor.

If you have additional questions, contact your accounting advisor. 1 (ASU) (http://www.fasb.org/cs/BlobServer?blobcol=urldata&blobtable=MungoBlobs&blobkey=id&blobwhere=1175824112049&blobheader=application%2Fpdf)

Chris Meriwether is a manager at BKD CPAs & Advisors. Contact the author at [email protected].

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FEATUREARTICLE

“Corporate account

takeover, or CATO,

is a term used for

electronic crime where

cyber criminals gain

access to business

customer online

banking accounts and

send fraudulent wire

and ACH transactions

to accounts controlled

by thieves. ”

Corporate Account Takeover

Earlier this year, just one hour before a bank was scheduled to educate their Board of Directors on the concerns of corporate account takeover, the bank’s call center

received a call from one of their customers ask-ing why the bank’s Internet Banking website was down. When the customer attempted to connect, they received a message stating the “Site was down for repair, check back in 24 hours.” The bank verifi ed the site was up, and upon further investigation found the customer’s machine had been compromised and fraudulent transactions were being created.

Does this sound familiar? According to a survey conducted by Financial Services Information Sharing and Analysis Center (FS-ISAC), attacks targeted at bank customers where hackers attempted to take over cus-tomer banking accounts was greater in 2011 than in the two previous years put together. They go on to say about a third of these attacks were successful.

What is Corporate Account Takeover?Corporate account takeover, or CATO, is a

term used for electronic crime where cyber crimi-nals gain access to business customer online bank-ing accounts and send fraudulent wire and ACH transactions to accounts controlled by thieves.

What Can Our Bank do to Protect Our Customers?

Corporate account takeover is particularly tricky for banks, since, in many cases, the cus-tomers are the ones getting breached. Below is a general list of 10 good security suggestions you can use to help protect your customers from these types of attacks. This list is not designed to be exhaustive, but can be used as a minimal guide.• Conduct a formal risk assessment and

control evaluation periodically;• Based on the risk assessment, develop and

approve policies and procedures as part of a layered security program;

• Continuously educate employees, particularly those using Internet banking systems;

• Educate customers, and suggest customers perform a related risk assessment and control evaluation periodically;

• Ensure basic security controls are in place, such as: malicious software protection, fi rewall, patch management, dual control, encryption, intrusion detection, web

RUSS HORN, CISA, CISSP, CRISCPresidentCoNetrix

Account Takeover continued on page 12



11

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fi ltering, email fi ltering, etc.;• Ensure appropriate authentication/

authorization controls are in place, such as: multi-factor authentication, two-way authentication, and out-of-band authentication;

• Ensure a process is in place to detect anomalies and respond to suspicious activity;

• Implement a fraud-detection system;• Develop an incident response plan;• Test and review processes and controls;

Resources:• National Cyber Security Alliance

– NCSA’s mission is to educate and

therefore empower a digital society to use the Internet safely and securely at home, work, and school. This website provides information and educational programs for protecting the technology individuals use, the networks they connect to, and their digital assets. http://staysafeonline.org/

• BBB Data Security – The Better Business Bureau (BBB) created this website specifi cally to educate small businesses on the most common data security issues they face. Data security guidelines and suggestions are presented to help improve the security posture of small businesses. http://www.bbb.org/data-security/

• OnGuardOnline – This website

was created by the federal government to help people be safe, secure, and responsible online. This website is part of the National Initiative for Cybersecurity Education. http://onguardonline.gov/

• US-CERT, Cyber Security Tips – This website is published by the United States Computer Emergency Readiness Team (US-CERT) and describes and offers advice about common security issues for non-technical computer users. http://www.us-cert.gov/cas/tips/

• Texas Bankers Electronic Crimes Task Force (ECTF) – This site was created to promote awareness and provide information to bankers on cyber related crimes and risk management practices to help protect banks and their customers. http://www.ectf.dob.texas.gov/index.htm

• Sound Business Practices for Companies to Mitigate Corporate Account Takeover – This document was created by the National Automated Clearing House Association (NACHA) to help companies mitigate the risk of corporate account takeover. The document was developed for companies of all sizes and outlines business processes to consider when reviewing and implementing security procedures. https://www.nacha.org/userfi les/File/Sound%20Business%20PracticesBusinessesFinal042811.pdf

• Small Business Information Security: The Fundamentals – This guide was published by the National Institute of Standards and Technology (NIST). The guide identifi es recommended practices to improve information security in small businesses. http://csrc.nist.gov/publications/nistir/ir7621/nistir-7621.pdf

Russ Horn, CISA, CISSP,CRISC is the President of CoNetrix, a provider of network consulting, security testing, risk management, and information security compliance software to fi nancial institutions. Visit our website at www.conetrix.com.

ACCOUNT TAKEOVER – continued

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FEATUREARTICLE

“Financial illiteracy

isn’t new, but the

consequences are

more severe than ever

with bankruptcies,

student loan defaults

and credit card debt at

an all-time high.”

Financial Literacy 2.0:

A New Model for Educating Children and Young Adults

in Personal Finance

The need for technology-based financial education that truly engages a genera-tion of digital natives who have a high bar for how they receive information is one of

the most important educational and social issues of our day. Year after year, hundreds of thousands of young adults across the country are graduating from high schools and colleges without the skills, training, or tools necessary to manage and navigate the myriad of financial decisions in front of them.

Credit card bills, debt, saving, and invest-ing are not top of mind for most high school students, yet the financial decisions they make today will have long-term effects on their lives. Poor financial awareness jeop-ardizes teens’ ability to succeed in today’s complex and competit ive env ironment. In this economy, students nationwide are experiencing greater financial stress and a real need for preventive financial education.

Financial illiteracy isn’t new, but the conse-quences are more severe than ever with bank-ruptcies, student loan defaults and credit card debt at an all-time high. High school seniors scored just 48% on a recent national fi nancial literacy test conducted by the Jump$tart Coali-tion assessing students’ knowledge on credit, saving, banking, insurance and retirement. The survey also found that:• 32% of high school seniors use credit

cards, but more than half of these students did not know that paying off a credit card more slowly will result in higher fi nance charges.

• 60% of high school seniors did not know that they could lose their health insurance if their parents become unemployed.

LARA LOVEMANProgram Director EverFi

Personal Finance continued on page 16



15

Employee Communications:

How to Be Remembered and Repeated Through Video

Communicating through video has never been easier.

Millions of online videos are being viewed each month by employees and that number is projected to con-tinue rising. If you’re not currently

using video as a way to communicate to your teams, you are likely missing out on a huge opportunity.

Very few employees in this short-attention span society will actually read all the way through an email before deciding what part is relevant to them.

Many bank leaders have made the tran-sition as a way to have stronger visibility

within their banks, some by launching weekly video updates, Fireside Chats or Town Hall teleconferences.

It is a perfect example of how you can connect to team members in real time, and be reminded to answer whatever important questions are on everyone’s mind.

FEATUREARTICLE

“Twenty-five years

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Employee Communications continued on page 18

16


PERSONAL FINANCE – continued

• 83% of high school seniors did not know that stocks are likely to yield higher returns than savings bonds, savings accounts and checking accounts over the next 18 years.

• 64% of high school seniors did not know that a house fi nanced with a fi xed-rate mortgage is a good hedge against a sudden increase in infl ation.

• 52% percent of the high school students did not know that they could check their credit report for free once a year.

When we founded EverFi, our goal was to reach these stu-dents through sound pedagogy while engaging the private sector and putting them on the forefront of technology and education. EverFi is an education technology company that provides valu-able content in areas such as fi nancial literacy, student loan management, digital literacy and other key life skills for the 21st Century learner. Our award-winning, proprietary software-as-a-service platform is designed to provide a highly interactive experience for students and features the latest in technology and instructional design including rich media, 3D simulations, social networking and adaptive pathing. The EverFi curriculum teaches, assesses and ultimately certifi es students in over 600 core fi nancial topics.

Through our funding model, these platforms are under-written by corporations and foundations, allowing them to be free to schools and budget neutral to states. Our products are free to K-12 schools and underwritten by bank partners who buy licenses for the use of our software and are able to white-label and customize the portal. This unique public-private partnership gives banks the opportunity to meet their social responsibility, marketing, regulatory or customer acquisition objectives in a way that serves the needs of students, families, schools and communities.

Financial illiteracy is on the verge of reaching epidemic proportions, yet ironically, the American public tends to seg-ment this and other social problems away from the issues that entrepreneurs typically go after. Whether it’s poverty, fi nancial illiteracy, obesity or disease eradication, there is often a belief that non-profi ts or non-governmental organizations will be the ones to step in.

EverFi has a different point of view. We believe there is a unique place for innovation and entrepreneurship in these social dilemmas. The private sector is ready and willing to help. More and more fi nancial services companies are looking

Personal Finance continued on page 18



17

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PERSONAL FINANCE – continued

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to incorporate fi nancial education into their products to teach consumers about mortgages, credit cards, and other accounts. And since most public schools do not have the fi scal resources to fund fi nancial literacy education, EverFi is partnering with these companies and organizations like the Washington Bankers Association to create an entirely new system to drive innovation in public schools.

The company will be operating in over 3,500 K-12 schools and colleges in all 50 states this year. The program has been received with enthusiasm throughout the country from schools, legislators, families and students. Our partners have felt the same enthusiasm in leading their community in an important initiative to help produce a more informed, fi nancially-equipped generation of students and community members.

By leveraging technology in innovative ways in the classroom, EverFi platforms are educating children and teens on critical concepts that they will carry throughout their lives.

Interested in sponsoring the EverFi Financial Literacy platform for the schools in your community? Contact Lara Loveman, Program Director at EverFi 202 656 7540 or lara@everfi .com.

According to a few who have adopted this practice, it was hard to change at first, but the benefits are now clear, as team members get on board more quickly and can accurately ref lect key messages with greater ease.

Videos that demonstrate your bank’s strategy and initiatives are arguably the quickest and easiest way to capture people’s attention. It also helps employees understand the work they are doing and how it fits into the larger strategic direction.

With the volume of information and regulation your employees have to decipher, you have to become much more strategic, and understand what your people are thinking. Decisions can be complicated, and you can see great resistance to change. Reaching employees through video helps cascade important communications to all levels in the organization.

Kendall Colman and Molly Hughes, are with Colman & Company, the endorsed vendor for leadership development for CBA. They are offering a Video Demo Day on September 27, 2012, in Denver, for you to see how easy video can be to communicate with your employees. Please visit www.colmancoaching.com for details or call 303.589.5749.

EMPLOYEE COMMUNICATIONS – continued

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Nancy Brook

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Managing Payments, Driving Solutions

fasb proposes disclosures for liquidity and …...“the liquidity risk disclosures would be...

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