Checklist for Successful Resolution & Recovery Planning
Online, August 17, 2016 (Newswire.com) - NEW YORK, NY - Financial institutions have been operating under a high amount of stress causing firms to go bankrupt. Some banks do not even have a recovery plan in place. Financial Institutions of all waves and sizes are required by the Federal Reserve and FDIC to submit recovery and resolution plans by certain deadlines. Unfortunately, some of the big wave three banks just failed their resolution plans.
Mark Wood, VP of Resolution Planning at M&T Bank, recently listed out key areas to focus on during planning stages:
What are some examples of obstacles you have faced when preparing a resolution plan? How did you recover from these instances?
MW:
Strategy Development
Actions:
- enhance integration with Treasury/ALCO & CCAR
- leverage inputs and challenge from internal "Strategy Development" group
- review & vet "downstream" impacts of strategy with appropriate senior governance
- expand internal insights from among the enterprise
- compare our plan contents with regulatory guidance to ensure adherence & avoid gaps
- keep apprised of specific details and resolution impacts concerning major initiatives & events (acquisitions, divestments, legal structure, new products/services, etc.)
Ensuring Sustainability & Repeatability
Actions:
- build internal depth and knowledge, with focus on experienced finance personnel
- institutionalize thorough documentation and data referencing disciplines
- centralize processes and controls wherever practical
- develop and manage planning calendar for resolution document development
- prioritize compilation of resolution data library contents and "feeder" sections
- rotational personnel assignments where practical and reasonable
In your mind (speaking from experience), what is the key to success when identifying parts of a Covered Insured Depository Institution (CIDI)?
MW:
- Thorough governance
- Detail orientation
- Thorough knowledge of organizational structures (legal &operations)
- Leverage appropriate resources, both internal and external
- Understand business interconnections
- Comprehensive financial acumen
- Proven business writing skills
- Version control
- Demonstrate controls with internal audit
What changes within the 165(d) and Insured Depository Institution (IDI) requirements do you predict for different sized banks in the next few years?
MW:
- Emphasis in providing a broad menu of executable strategic options to regulators which are supported by clear & concise data
- Additional specificity on regulatory requirements
- Somewhat relaxed standards for banks under certain thresholds -- based on complexity, structure, activities, size, etc.
- Increased focus on strategy alternatives . . . and less on static data requirements
What are a couple of the most successful business strategies you have utilized throughout your experience in implementing regulatory procedures?
MW:
- Continuous assessment of changing regulatory landscape
- Integrate resolution within the organization where of value
- Ensure and promote appropriate governance
- Clear communications
- Thorough vetting
- Increased utilization of visuals to "tell the story"
- Validation of data
- Staff with appropriate resources
Mark Wood has diversified experience among financial institutions, international manufacturing companies and public accounting. He currently leads the Resolution Planning efforts for M&T Bank, headquartered in Buffalo, NY. Previously, Mark directed M&T's Management Accounting function and served as a senior manager on its Finance Corporate Reporting team. His extensive responsibilities as a financial controller include business restructurings, financial reporting, forecasting, SEC requirements, project management, audit, treasury, human resources and administration.
Join Mark at the Recovery & Resolution Planning for Financial Institutions Conference, October 26-27, 2016 in New York City, NY. For more information, take a look at the conference agenda or contact Tyler Kelch, Digital Marketing Manager, marcus evans at 312.894.6310 or Tylerke@marcusevansch.com.
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