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Next blog: Senate Banking Committee - Deposit Insurance Reform - Be Careful! Why isn't collateralization enough?
Q: Why do state, county and municipal treasurers have a need for banking due diligence, even if all of their funds are collateralized? (Why should their auditing firms require this as well?)
A: The following are some of the not so obvious but compelling reasons.
1. Our service provides documentation that the treasurer is meeting their fiduciary
responsibilities for tax payers’ deposits as well as it mitigates
their banking risk.
This effort is regardless if they have all of their deposits collateralized and/or
“have known their banker(s) for years”.
2. We know of no banker, who a treasurer interacts with, ever warning them that their bank
is having financial or operational issues. Since
government deposits are in the order
of millions, if not tens of millions of dollars, these types of deposits are coveted by
banks. How do we
know this - because bankers have told us during a call to see
why their rating fell.
Further, and as important, if their “banker” is not the CFO or president, most banks
have various departments whereby a silo environment
(not sharing information among
departments or teams) exists. As a result, their banker is in the dark about the
bank’s financial or operational condition. Even if the
“banker” is the CFO or president we have never heard of one of our government
customers tell us – “Oh the president or CFO told us
that they were having financial or operational issues”.
Many conversations over the years are initiated by our government customers whereby
they see a rating that is less than Green with Three
Stars (our highest) and they call us to see why. Together, we review the Research
Report and see what is driving the lower rating. After we
have consulted with them, they now have data, not opinion, to call their
banking contact and see if the banker’s story is consistent with the
data.
This type of conversation usually elicits an explanation of what the bank is doing to
resolve the issue or issues. Although infrequent, a few
of our government customers have told us that they switched banks due to problems we
made them aware of and that the bank was not addressing or not
addressing promptly.
3. We offer a time-tested, completely transparent track record, non-biased and no conflict
of interest (no bank has paid us to rate them) proactive
service. Since we can detect financial and/or operation issues quarters prior to a
bank’s potential failure, (Silicon Valley Bank, Signature Bank
and First Republic Bank are examples) our service provides treasurers or finance
managers with assessments and plenty of time to discuss
these issues with their banker before they become more or too serious.
Hence, they are able to be proactive instead of being forced to be reactive – which is
never a desired outcome.
4. Even if all of your deposits are collateralized, can you afford to wait a week or more
if your bank fails - to have access to those deposits?
Historically, the FDIC has found another bank to absorb a failed bank’s deposits,
just over 85 percent of the time.
However, even if the FDIC can’t find an acquiring bank,
regardless of the type of resolution, the FDIC looks over all collateralization
agreements and if every “I” isn’t dotted and every “T” isn’t
crossed there are going to be delays.
5. Are you aware that many banks have operational shortfalls when it comes to keeping the
percentage of securities’ value as outlined in a
collateralization agreement up to the required amount. There could be a number of
reasons for this very subtle situation.
a. Are the bank’s personnel that handle this function not
held to a high level of diligence and/or professionalism?
b. Are they not aware of their customer’s requirements that
the bank agreed to?
c. Is the bank experiencing financial difficulties?
Wouldn’t someone depending on the bank’s securities’ values want to know if the bank has
to keep buying securities to keep up with a securitization agreement?
This last question is exactly what got Silicon Valley Bank into problems. They kept
buying US securities even though the value of those securities kept falling! Yes, our
model picked up this problem nine quarters prior to the quarter of failure!
6. How do you debate a candidate, answer a legal suit or address negative social media posts
about how you are protecting taxpayers’ deposits, if the only box you have checked off is
– we collateralized all of our deposits.
Our service provides a proactive and sound rebuttal to all of the above.
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