This article provides an overview of the Unified Financial Institutions Rating System, commonly known as CAMELS, which is used by regulators to assess the safety and soundness of banks. The CAMELS rating system evaluates six key components of a bank’s performance: Capital Adequacy, Asset Quality, Management, Earnings, Liquidity, and Sensitivity to Market Risk. Each component is rated on a scale of 1 to 5, with 1 representing the strongest performance and 5 the weakest.
Evaluations of the components take into consideration the size and sophistication of the institution, the nature and complexity of its activities and its risk profile. The purpose of this article is to provide insight into how the regulators assess safety and soundness and the factors that impact the ratings.
Typically, a safety and soundness examination that results in adverse CAMELS ratings will discover regulatory violations and control breaches that could result in potentially large monetary penalties and other enforcement actions and adverse publicity (though the CAMELS Ratings are not made public, enforcement actions are). Additionally, a high CAMELS Rating could:
- Impede a banks ability to grow through mergers and acquisitions, investment or adding more branches and expand across state lines
- Require an institution to pay higher deposit insurance premiums
- Impair an organization’s access to primary credit at the Federal Reserve’s discount window
- Subject the institution to increased regulatory scrutiny and more frequent examinations.
Within the last year, two banks were the subject of OCC regulatory actions for engaging in
unsafe or unsound practices, including those relating to strategic and capital planning; liquidity
risk management; interest rate risk management; credit risk management, Allowance for Loan and Lease Losses (“ALLL”) methodology, corporate governance, and internal controls. The violations required the banks to take immediate remedial action, including:
- Filing a corrective action plan to address violations and provide quarterly updates on the progress of the plan.
- Ensuring that capable senior executive officers are in place to perform present and anticipated duties, factoring in each officer’s performance, experience, and qualifications as compared to their position description, duties and responsibilities, and that an annual written performance appraisal is performed and prepared for all Bank senior executive officers.
- Submitting a detailed Strategic Plan to establish objectives for the bank’s overall risk profile, earnings performance, growth expectations, balance sheet mix, off-balance sheet activities, liability structure, and capital and liquidity adequacy, together with strategies to achieve those objectives.
- Prohibiting significant deviation from the products, services, asset composition and size, funding sources, structure, operations, policies, procedures, and markets without written approval of strategic plan.
- Maintaining higher capital requirements.
- Submitting for written approval Interest Rate Risk and Contingency Funding plans that meet strict requirements outlined by the OCC.
Doran Jones Recommends:
Banks should be performing periodic monitoring and testing by all three lines of defense that would review the factors that determine the CAMELS rating individual component scores from the point of view of the regulators. Known issues from monitoring, testing, audits and regulatory examinations can provide insight into potential problems with any of the components. Our experience has shown that many institutions fail to recognize when changes to their business and outside factors have had an adverse impact on the component factors since the last CAMELS rating assessment. We recommend that banks periodically perform a review of these factors, especially during periods of market and economic volatility like we are currently experiencing.
The review should engage key business stakeholders in addition to senior members of risk and compliance.
We suggest a risk-based approach that starts with a review of relevant risk assessments, controls, management reports and metrics, etc. to identify higher risk processes for more frequent review.
The objectives and benefits of performing these reviews, include:
- Ensuring that processes and policies that are critical to the bank’s ongoing safety and soundness keep up with the bank’s growth and changes to the internal and external business environment.
- The early detection of deteriorating ratings to minimize the required remediation efforts by allowing for incremental improvements instead of onerous revisions to processes and systems.
- Preventing unpleasant surprises during regulatory examinations and potentially costly regulatory actions.
- Maintaining the bank’s reputation and the confidence of clients and shareholders.
- Enhance business managers’ ability to accurately identify, measure, monitor and control the risks of their business units.
While a full review process is beyond the scope of this article, we will describe some of the more important items for review based on our experience.
- Asset Quality
The asset quality rating reflects the level of current and potential credit and default risk associated with loan and investment portfolios and real estate and other assets, including off-balance-sheet holdings. The regulators consider the ability of management to identify, measure, monitor and control all risks that may affect the value of the bank’s assets, including, but not limited to, market, operating, credit, counterparty, reputational, and compliance risks.
The more important factors used to determine an institution’s asset quality include:
- The adequacy of loan and investment policies and procedures and underwriting standards.
- The effect on the bank’s risk from off-balance sheet transactions, including
- Credit derivatives
- Letters and lines of credit
- Unfunded commitments
- Financial futures
- Interest rate swaps
- Foreign exchange
- Options
- The adequacy of loan loss and other valuation reserves.
- The amount of underwriting activity and counterparty risk exposure.
- The quality and diversification of assets, including loans and investments.
- The effectiveness of internal controls and management information systems.
- The ability to quickly identify and collect problem assets.
Doran Jones Recommends:
- Review loan policies and procedures to determine if they are adequate based on the above factors, and if they need updating. Examples of items they should adequately cover include:
- Loan evaluation analysis requirements
- Exception reporting
- Credit standards
- Documentation standards
- Appraisal requirements
- Loan quality evaluation and monitoring
- Portfolio limits and strategic goals
- Acceptable collateral types and coverage limits
- A loan charge-off policy that is consistent with regulations and accounting standards
- Senior management and board review of charge-offs
- Review risk management process and controls with particular emphasis on:
- Off-balance sheet transactions
- Loan loss reserves
- Concentrations of credit
- The banks primary lending areas (ex: credit cards, residential mortgages, commercial lending)
- Review investment securities policies and procedures to determine if they are adequate based on current and
- upcoming regulatory requirements. Examples of items they should adequately cover include:
- Investment objectives
- Permissible investment types
- Diversification guidelines
- Quality ratings requirements
- Valuation procedures
- Exceptions policy
- Policies reviewed at least annually
- Limitations on investment authority of officers
- A requirement for dual authorization of securities transactions
- Clear requirements over the custody of bank securities
- Adequacy of investment securities records that are kept by persons who cannot initiate trades
- Clear trading limits for individual traders and overall positions
- Review Allowances for Credit Losses (ACR), including:
- Analyzing trends and identifying root causes for any material changes and management rationale for the changes.
- Determine if prior period ACL balances support subsequent actual charge-offs and review loans in workout that could hide or delay charge-offs.
- Review loan loss risk identification and classification processes, policies, and procedures to determine if they are adequate and if they need updating.
As a result of the above recommended activities management can gain an insight into where the value of their assets are vulnerable to market, credit counterparty and other risks, the effectiveness of its risk controls and identify any gaps. Strong asset risk management processes and procedures can safeguard the integrity of the institution’s balance sheet.
Conclusion
Recent events have proven that banks are operating in a particularly dynamic environment and that both internal and external changes can quickly change the factors that determine a bank’s basic safety and soundness. Prudent risk management practices require that these factors be proactively and periodically reviewed, and any weaknesses addressed in a timely manner.
Contact us to learn how a strategic partnership with Doran Jones can provide you with cost-effective solutions by leveraging our expertise with these and other critical risk and compliance functions.