Repeal of Regulation Q: Impact on Bank Pricing and Changes

Transcription

1 Repeal of Regulation Q: Impact on Bank Pricing and Changes Zoya Lieberman, CTP Commercial Services Product Manager Informa Research Services Randy Rosen, CTP Deposit Product Manager Informa Research Services

2 Agenda Methodology Hybrid Commercial Checking Accounts Commercial Interest Checking Accounts Commercial Services and Fees General Strategy

3 InformaResearch Services Business Profile Established in 1983 Premier provider to the financial industry Three name changes, same executive team Meyer Weekly Interest Rate Survey BISYS Research Services Key acquisitions in our growth areas Barry Leads & Associates Market Trends Moorthy, Riggs & Associates Clients include 6,500+ financial institutions All of the Top 100

4 Methodology How the Survey was conducted: Informa Research Services requested professionals at various financial institutions with expertise in business/commercial banking to respond to this survey request. Participants had to have expertise in one or more of the following areas: ECRs, Commercial Checking Accounts, Cash Management, and Investment Sweeps. The survey was anonymous and was designed to capture how the industry is meeting this new challenge. Once the responses were received, they were reviewed by Informa s analysts for consistency and data integrity. Any ambiguous responses were followed up with the appropriate contact at the financial institution. All questions asked in the survey were focused on commercial/corporate product set, not on the small business segment. This is a follow up to the 2010 Impact of the Regulation Q Study Number of surveys completed and distribution of institutions surveyed: $100 Billion + (10 institutions) $100 Billion $50 Billion (7 institutions) $50 Billion $20 Billion (7 institutions) $20 Billion $10 Billion (6 institutions) $10 Billion $1 Billion (22 institutions) Less than $1 Billion (5 institutions)

5 Hybrid Commercial Checking Account

6 Do you offer or plan to offer a hybrid option that both offsets fees and pays interest on excess balances? % 6 68% 83% 86% % 4 32% 17% 14% 1 YES NO $100+ Billion $100 Billion $50 Billion $50 Billion $20 Bil llion $20 Billion $10 Bil llion $10 Billion $1 Billi ion <$1 Billion Overall, 79% of the respondents indicated that they plan to offer a hybrid checking account option, with only 21% indicating they do not plan to offer such a product. Most of the asset categories were heavily in favor of offering a hybrid product, except in the <$1 Billion asset range, with 6 planning to offer the hybrid product and 4 not planning to offer the hybrid account at all.

7 Which of the following reasons prevented your financial institution from introducing a hybrid product? 33% 42% PRODUCT STRATEGY SYSTEM LIMITATIONS LACK OF INTEREST FROM CLIENTS 17% 8% OTHER 42% of those responding indicated that the reason for not offering a hybrid product is product strategy, 17% indicated there was a lack of interest from clients, and 8% indicated that there were system limitations. 33% of those responding did have a different reason than those above for not offering the hybrid product: Core vendor cannot support the product Other priorities limit focus at this time Clients wish to leverage FDIC coverage It's a combination of product strategy, lackof client interest and system limitations

8 Will the fees associated with the hybrid account be: 38% 49% SAME AS ECR ONLY COMMERCIAL CHECKING SAME AS INTEREST ONLY COMMERCIAL CHECKING 13% DIFFERENT FROM OTHER COMMERCIAL CHECKING ACCOUNTS Overall 49% indicated the fees will be the same as the Commercial Analyzed ECR product, 38% indicated the fees on the hybrid will be different from other Commercial Checking accounts, and 13% indicated that the fees will be same as the Commercial Interest Checking product. Of the three response options for this question, there were two that seemed to stand out the most among the asset classes: <$10 Billion and $100 Billion $20 Billion indicated the fees for the hybrid product will be the same as the Commercial Analyzed ECR product. $20 Billion $10 Billion and $100 Billion+ asset class indicated that the fees for the analyzed product will be different than from Commercial Checking accounts.

9 Will the earnings credit and/or interest rates offered for the hybrid option be: 22% EQUAL TO THE ECR COMMERCIAL CHECKING PRODUCT EQUAL TO THE INTEREST ONLY SMALL BUSINESS CHECKING PRODUCT 6 18% EQUAL TO THE INTEREST ONLY COMMERCIAL CHECKING PRODUCT DIFFERENT FROM THE RATES OFFERED ON THE EARNINGS CREDIT ONLY OR COMMERCIAL INTEREST ONLY PRODUCT Overall, 6 indicated that the ECR and/or interest rate offered for the hybrid will be different from the rates offered on the earnings credit only or commercial interest only product, 22% equal to the ECR Commercial Checking product, and 18% equal to the Interest only Commercial product. None of the respondents indicated that the rates offered for the hybrid account will be equal to the small business interest only product. In the $100 Billion+ asset class, every institution indicated that the rates offered for the hybrid product would be different from the rates offered on the earnings credit only or commercial interest only product.

10 Which of the following methodologies would define how your Hybrid product will work? 2% 11% THE PRODUCT HAS AN ECR RATE TO OFFSET THE FEES AND AN INTEREST RATE EARNED ON THE EXCESS BALANCES 87% THE PRODUCT DOES NOT HAVE AN ECR, BUT THE INTEREST EARNED IS USED TO OFFSET THE FEES AND IF THERE IS EXCESS INTEREST THE CUSTOMER IS PAID INTEREST WILL OFFER BOTH OPTIONS LISTED ABOVE Overall the majority of the institutions surveyed (87%) indicated that the hybrid product offered will have an ECR rate to offset the fees and an interest rate earned on the excess balances, bl with only a small percentage (2%) indicating they will offer a product tthat t that t does not have an ECR, but the interest earned is used to offset the fees and if there is excess interest, the customer is paid interest. A selected group (11%) of those that responded indicate they will offer both hybrid options. The largest percentage (33%) of those that responded indicating they would offer both hybrid options is in the <$1 Billion asset range. In the $20 Billion $10 Billion asset class range, 2 indicated they will offer the hybrid product that does not have an ECR, but the interest earned is used to offset the fees and if there is excess interest, the customer is paid interest.

11 Commercial Interest Checking Account

12 Do you currently offer a commercial interest checking account? 9 83% 86% % 71% % 17% 14% 29% 3 YES NO 1 $100+ Billio $100 Billion $50 Billion $20 Billion $10 Billion <$1 Billion n $50 Billion $20 Billion $10 Billion $1 Billion Overall, 7 of those that responded to the survey indicated they currently offer a commercial interest checking account, with 3 indicating they are not offering such a product. In most of the other asset classes the percentages correlated closely with the overall statistics, except in the $50 Billion $20 Billion and $20 Billion $10 Billion asset class categories, where 86% and 83%, respectively, indicated they do currently offer a commercial interest checking account.

13 When do you anticipate offering a commercial interest checking account?: % % % 18% 38% 33% 13% THE END OF 2011 FIRST HALF OF 2012 SECOND HALF OF 2012 NO IMMEDIATE PLANS $100+ Billion $100 Billion $50 Billion $50 Billion $20 Billion $20 Billion $10 Billion $10 Billion $1 Bil lion <$1 Billion 3 overall indicated they do not currently offer a commercial interest checking account, 59% indicated they have no plans to offer such a product, 24% will offer the product toward the end of 2011, and 18% will begin to offer the product in the first half of For those that will offer the product in the near future, everyone will offer the product before the second half of In the $20 Billion $10 Billion and <$1 Billion asset class ranges, all respondents indicated they have no immediate plans to offer a commercial checking product, and in the $50 Billion $20 Billion asset class range they intend to offer the commercial checking product in the first half of 2012.

14 Where will the rate on the commercial checking account be positioned as compared to earnings credit rate? % 79% % 8% 5% 7% EQUAL TO ECR HIGHER THAN ECR LOWER THAN ECR $100+ Billion $100 Billion $50 Billion $50 Billion $20 Billion $20 Billion $10 Billion $10 Billion $1 Billion <$1 Billion Overall, a majority (88%) of those responding indicated that the commercial checking account rate will be positioned lower than the ECR rate, with 8% indicating the rate will be equal to the ECR and 5% indicating that the rate will be higher than the ECR. Every asset class, except in the $10 Billion $1 Billion and $20 Billion $10 Billion asset class ranges, indicated that the commercial checking account interest rate will be positioned lower than the ECR rate on a traditional commercial checking account.

15 Commercial lservices & Fees

16 If you anticipate offering an interest bearing checking product for commercial customers, will your Cash Management fee structure be identical to or different from commercial checking accounts with earnings credit? % 67% 64% 67% 71% % 33% 36% 33% 29% IDENTICAL 2 DIFFERENT $100+ Billion $100 Billion $50 Billion $50 Billion $20 Billion $20 Billion $10 Billion $10 Billion $1 Billion <$1 Billion Overall, 73% indicated that the Cash Management fee structure will be identical to commercial checking accounts with earnings credit, with 28% indicating they will be different. In the $100 Billion $50 Billion and $20 Billion $10 Billion asset class ranges all respondents indicated the Cash Management fee structure will be identical to commercial checking accounts with earnings credit, while in the <$1 Billion asset class, 67% indicated the fee will be different and 33% indicated the cash management fees will be identical, which is a reverse of the strategy to be implemented by the rest of the industry.

17 Do you anticipate making any rate changes to the commercial money market/savings or sweep product options you offer as a result of the repeal of Regulation Q? 15% 5% 5% YES, RATE CHANGES TO BOTH COMMERCIAL MONEY MARKET/SAVINGS AND SWEEP PRODUCTS YES, RATE CHANGES TO MONEY MARKET/SAVINGS ONLY 75% YES, RATE CHANGES TO SWEEPS ONLY NO CHANGES Overall, the majority of respondents 75% indicated there is no anticipation of making fee changes to the commercial money market/savings or sweep product options. Two groups of respondents, 15% and 5%, indicated they would be making fee changes to both commercial money market/savings and sweep products, along with the sweep only product. Only 5% indicated they would be making fee changes only to their commercial money market/savings product. In the $20 Billion $10 Billion asset class, all respondents indicated they would be making no fee changes to the commercial money market/savings or sweep product options. In the $10 Billion $1 Billion asset class, 27% indicated they will be making fee changes to sweeps only, and in the <$1 Billion asset class, 2 indicated they will be making fee changes to money market/savings products.

18 After the Repeal of Regulation Q, did you create or are you planning to create a commercialdda product that includes an investmentsweepinto sweep into a bank Money Market Deposit Account? % 68% 71% 6 57% 43% % 32% 29% 1 YES NO $100+ Billion $100 Billion $50 Billion $20 Billion $10 Billion <$1 Billion $50 Billion $20 Billion $10 Billion $1 Billion The majority of respondents (77%) indicated that they did not create nor are planning to create a commercial DDA product that includes an investment sweep into a bank Money Market Deposit Account, while 23% indicated they intend to create such a product. of the respondents in the $20 Billion $10 Billion and <$1 Billion asset class indicated they do not plan to create a Money Market Deposit Sweep product. The highest percentage that indicated they plan to create a Money Market Deposit Sweep product is in the $50 Billion $20 Billion asset class (43%).

19 On which of the following segments will your financial institution be passing a standard FDIC fee on to a Non interest DDA? 75% 32% SMALL BUSINESS ACCOUNTS MIDDLE MARKET/LARGE CORPORATE ACCOUNTS 84% SMALL BUSINESS PUBLIC FUND ACCOUNTS 35% MIDDLE MARKET/LARGE CORPORATE PUBLIC FUND ACCOUNTS Overall, the majority of respondents indicated that an FDIC fee would be passed on to a noninterest DDA for middle market/large corporate accounts (84%) and middle market/large corporate/public fund accounts (75%), while only 32% and 35%, respectively, indicated they will pass an FDIC fee on to small business accounts and small business public fund accounts. In the $20 $10 Billion dollar asset range, none of the respondents and only 1 in the $100+ Billion asset range indicated they would be passing an FDIC fee on to small business accounts. Yet in the same two asset class ranges, 33% and 2, respectively, indicate they will be passing an FDIC fee on to the small business public fund accounts.

20 Do you currently charge or anticipate charging an FDIC fee on the following products? INTEREST BEARING CHECKING FOR COMMERCIAL AND CORPORATE CLIENTS 26% 19% 11% 65% INTEREST BEARING CHECKING FOR PUBLIC FUND CLIENTS HYBRID CHECKING FOR COMMERCIAL AND CORPORATE CLIENTS 7 51% COMMERCIAL AND CORPORATE MONEY MARKET DEPOSIT ACCOUNTS PUBLIC FUND MONEY MARKET DEPOSIT ACCOUNTS DO NOT OFFER ANY OF THE ABOVE PRODUCTS Overall, a large majority of respondents indicated they currently charge or anticipate charging an FDIC fee on commercial checking (65%), public fund interest bearing (51%) and commercial hybrid checking (7) products. Yet only 26% indicated they will be passing an FDIC fee on to commercial money market accounts, while 19% will pass this fee on to public fund money market accounts. 11% overall indicated they do not offer any of these products.

21 General Strategy

22 For any commercial interest bearing accounts you might have developed, how would you describe your marketing posture? % 8 73% 86% 86% % 12% 4% 2% 5% 5% 14% 14% 1 DEFENSIVE AGGRESSIVE PROMOTIONAL NO DEFINED STRATEGY $100+ Billion $100 Billion $50 Billion $50 Billion $20 Billion $20 Billion $10 Billion $10 Billion $1 Billio on <$1 Billion Overall, 82% indicated that they have a defensive strategy when it comes to their marketing posture. Only 12% of the banks stated that they do not have a defined strategy, while 4% report being aggressive and 2% promotional (part of a specific campaign). In the $20 Billion $10 billion asset range, of the respondents use a df defensive posture. In the $100+ Billion asset range, 9 are planning to have a defensive posture, with the rest of the financial institutions having no specific strategy. Institutions in the $10 Billion $1 billion asset range reported an aggressive and promotional strategy posture (5% each).

23 How will you train your sales associates to sell interest bearing DDA vs. non interest bearing DDA? % 77% 83% 71% POSITION NON INTEREST BEARING DDA NEUTRALLY BESIDE INTEREST BEARING DDA 6 LEAD WITH NON INTEREST BEARING DDA % 23% 17% 29% LEAD WITH INTEREST BEARING DDA $100+ Billion $100 Billion $50 Billion $50 Billion $20 Billion $20 Billion $10 Billion $10 Billion $1 B illion <$1 Billion Overall, 14% will train their sales teams to offer both accounts to their customers without bias, while 86% indicated that the sales effort will be with a non interest bearing checking account. In the asset size categories of < $1billion, $100 Billion $50 Billion, and $100+ Billion, all respondents stated that they will lead with the traditional ECR commercial checking account. No respondents from the survey indicated that they will lead with the interest bearing DDA.

24 Which channels are you planning to use in order to promote the new commercial checking offerings? 14% BRANCH 63% 32% COMMERCIAL SALES TEAM FINANCIAL INSTITUTION WEB SITE 14% DIRECT MARKETING DO NOT PLAN TO PROMOTE AT ALL 2% 63% of the overall respondents are not planning to promote a new commercial checking offering at all. With 32% directing their promotional efforts to the commercial sales team and 14% to the branch and financial institutions web site, only 2%will directly marketthethe new commercial checking account. For all asset classes, as indicated with the overall responses, the majority do not plan to promote the new commercial checking account. The only exception is the $20 Billion $10 Billion category, with 67% indicating they are planning to use a commercial sales team to promote the new commercial checking account.

25 What commercial checking account product does your financial institution anticipate primarily selling? % 8 91% % 18% 2 14% 9% 33% 33% 29% 29% 29% % ECR ONLY COMMERCIAL INTEREST ONLY HYBRID CHECKING ONLY $100+ Billion $100 Billion $50 Billion $50 Billion $20 Billion $20 Billion $10 Billion $10 Billion $1 Billio on <$1 Billion An overwhelming majority (95%) indicate that they will primarily be selling the traditional ECR only product. In addition to the ECR only commercial checking, 23% are also planning to sell the hybrid commercial checking, with 18% planning to sell interest only commercial checking account. In the <$1 Billion category, none of the respondents indicated that they are planning to offer an interest only commercial account.

26 Will you continue to allow the payment of third party vendors (using earnings credit) following the repeal of regulation Q? % % 53% % 55% 43% 57% 4 6 YES 2 17% NO $100+ Billion $100 Billion $50 Billion $50 Billion $2 20 Billion $20 Billion $1 10 Billion $10 Billion $1 Billion <$1 Billion The responses were evenly distributed, with 47% indicating that they will allow use of ECRs for the third party fees, and 53% not allowing or discontinuing the soft charges for the third party fees. In the $50 Billion $20 Billion asset range, responded that they will allow the third party fees to be soft charged going forward. In the $20 Billion $10 Billion asset range, 83% will not allow the third party fees to be passed through the analysis.

27 On which level in the client relationship will the charges be applied? % 8 68% 67% 86% 71% % 2 32% 33% 14% 29% 1 TOTAL RELATIONSHIP PER INDIVIDUAL ACCOUNT $100+ Billion $100 Billion $50 Billion $50 Billion $20 Billion $20 Billion $10 Billion $10 Billion $1 Billion <$1 Billion OVER RALL 75% of the overall respondents indicated that the clients will be charged for the services based on the total relationship, with 25% planning to use a per individual account structure. In the $100+ Billion category, 9 are planning to use the overall relationship as the basis for account analysis.

28 Strategic Summary Commercial interest bearing accounts will not have an aggressive marketing campaign. They will be offered as a defensive posture. The commercial sales team will be trained to lead with traditional non interest bearing commercial checking accounts. Financial institutions are not planning to heavily promote the new interest bearing commercial checking accounts. Those institutions that are planning to promote the new interest bearing commercial checking accounts are not going to develop a new distribution channel or invest in the new technology. Financial institutions are planning to have interest bearing checking account options for multiple market segments, including sole proprietors, small business, and commercial customers. Half of the financial institutions are going to allow the third party charges to be passed through the account analysis. Financial institutions are basing service charges on the total client relationship instead of individual id accounts.

29 Contact Information Zoya Lieberman, CTP Agoura Road #300 Calabasas, CA Direct Line RandyRosen Rosen, CTP Agoura Road #300 Calabasas, CA Direct Line