Strengthening Financial Risk Management at the FDIC
Improving Financial Reporting Horizon 1
RECOMMENDATION 1.3: ADOPT A SET OF NEW FRC
The antecedent of the FRC was the FDICs Failure Projection Working Group, an
informal, interdivisional forum for discussing various failure-projection models and
their implications for the FDIC. This working group developed initial contacts and
working relationships between divisions at a time when the FDIC had what one
participant described as a stove-pipe culture.17 The FDIC culture of the time and
the evolving composition and objectives of the working group warranted an
informal, open, and flexible process.
In 1998, the FDIC converted the working group into the Financial Risk Committee.
Most of the FRCs organizational processes and practices were inherited from the
informal working group rather than being deliberately chosen, so the FRCs
processes are generally informal. These processes are described and assessed
The current FRC organization and process
The FRC is tasked with determining reserves the FDIC should set aside for
depository institutions that may fail. The FRC obtains the most accurate, current,
and complete information by bringing together a wide group of constituencies, from
within and outside the FDIC (Exhibit 1-9). The primary participants of the FRC are
four divisions DIR, DSC, DRR, and DOF each of which is represented by one
to three FRC principals, numbering eight in total. The FRC also formally
receives input from the Office of the Comptroller of the Currency (OCC), the
Federal Reserve Board (FRB), and the Office of Thrift Supervision (OTS).
The FRC operates on a quarterly cycle for two reasons. First, much of the analysis
is based on data in Call Reports and Thrift Financial Reports that depository
institutions file quarterly. Second, the FRC is tasked with computing the CLR,
which is included in the FDICs quarterly financial results.
Each quarter, the FRC process begins when DIR finishes entering the Call Report
data into its databases and cleaning the data to remove errors. This clean data is
generally available 2 months after the start of each quarter. In the next 3 weeks,
DIR and DSC calculate the input estimates (e.g., the Pro Forma Model) and compile
background materials that the FRC will consider. In the last week of the quarter,
the FRC holds a preliminary meeting with other federal bank regulators and a final
meeting to decide on the CLR and 2-year Projection.
Calculating estimates and compiling materials. In the last month of each quarter,
DIR continuously updates the reserve list,18 which is the basis for the CLR
calculations. As described above, DIR runs the Pro Forma Model to project which
of these institutions will have capital above and below two percent of assets after
one year. DIR then gathers these results into a spreadsheet to compute the CLR
estimate according to the established CLR methodology. At the same time, DIR
personnel run the three models that provide inputs into the 2-year Projection of
failed-bank assets, and DSC compiles its 8-Quarter list based on its supervisory
All these results are disseminated to FRC participants along with various other
reports that speak to the health of insured institutions. These reports typically
consist of: DSCs Quarterly Lending Alert, DSCs report on the Real Estate Stress
Test (REST) Model, DSCs report on the Statistical CAMELS Offsite Rating
(SCOR) Model, DIRs Market Trends Report, a report from DIR comparing the
CLR for the quarter using the Research Model to the CLR as calculated under the
prevailing methodology, DIRs CAMELS Migration report, DSCs report on Large
Insured Depository Institutions (LIDI), and DIRs Risk Case. Altogether these
materials comprise 60 to 100 pages, with a 2- to 4-page summary up front.
Preliminary FRC meeting. At the beginning of the last week of each quarter, the
FRC principals meet with representatives from the OCC, FRB, and OTS. The
purpose of this preliminary FRC meeting is to gather supervisory perspective on
insured institutions for which failure is reasonably possible. The other federal bank
agencies provide information on the majority of insured institutions that FDIC does
not supervise. During this meeting, the FRC principals are briefed on the most
important at-risk institutions, and the FDICs reserve list is updated to reflect any
recent status changes (e.g., changes in CAMELS ratings).
Final FRC meeting. In the final 1 to 3 days of each quarter, the FRC principals
and some of their supporting staff meet for the FRC decision meeting at which
the group decides on the CLR and 2-year Projection of failed-bank assets. Typical
attendance at these meetings is 25 to 30 people. Discussion is informal and open to all.
At the end of the meeting, the group comes to a consensus about the CLR and
2-year Projection, and these decisions are reported formally to DOF within 1 day.
Performance of the FRC process
The remainder of this section assesses the FRCs organization and processes on
nine dimensions. It scores well for using the most current information and for
fostering constructive interdivisional debate. On the remaining seven dimensions,
the FRC lacks formal processes and procedures that could make it more efficient.
Purpose. All the FRC participants understand that the primary
purpose of the FRC is to produce the CLR and 2-year Projection, but
there is less clarity about what would constitute improvements to
these estimates. For example, the trade-off between accuracy and
smoothing volatility is not well understood.19 Furthermore, there is an
outstanding issue about whether the FRC should report additional
measures of the financial risks faced by the FDIC.
Pace and frequency. FRC processes are compressed into the final
few days of each quarter. That compression is largely dictated by data
availability (which takes the first 8 weeks of the quarter) and reporting
needs (which requires an output by the end of the quarter).
Preparation and materials. The briefing materials distributed in
advance are comprehensive, but they typically are too voluminous for
the participants to read in the short time available before the FRC
meeting. There is a summary memo, but it does not digest the
materials into an easy-to-read dashboard of key indicators.
Additionally, some of the backup material is unnecessary.
Participants. The FRC meetings are essentially open to all who are
interested, so the process is inclusive, fosters interdivisional contacts,
and incorporates the best information from all parts of the FDIC.
However typical attendance is 25 to 30, and this large size distracts
from key issues and dampens meaningful discussion.
Procedures. There are few formal procedures at FRC meetings. This
allows substantial flexibility and fosters a collegial atmosphere, but it
also leads to inefficiencies. For example, some participants do not
know who is to present what material, leading to costly delays. More
importantly, the consensus-driven approach sometimes makes it
difficult for the FRC to come to a decision in a timely manner.
Feedback loops. DIR recently instituted a 360-degree review of the
FRC, which produced meaningful insights about FRC methodologies
and procedures, but there are no systematic feedback loops in place to
continuously measure the FRCs progress and guide future
Support systems and documentation. The briefing materials are
created by hand and distributed as hard copies. No central, electronic
repository exists for these briefing materials or for the detailed
minutes taken at each FRC meeting.
Currency of information. The FRC relies on a variety of
information to reach decisions about reserves, some of which changes
daily (e.g., the status of recently downgraded institutions). The
preliminary FRC meeting injects the most recent information into the
FRC process, but that meeting occurs just a few days before the final
meeting, which does not allow FRC participants much time for
Culture. The FRC has succeeded in breaking down divisional
barriers, with joint problem solving, constructive criticism, and
vigorous debate common.
Specifics of Recommendation 1.3 (Adopting a new set of FRC
The FRC will become more efficient if it adds some formal procedures and
processes. At the next FRC meeting, the FRC principals should adopt the
recommendations listed below. None of the proposals requires substantial effort to
implement, so they can be implemented immediately.
1.3.a. The FRC should adopt a clear mission statement. The example in Exhibit
1-10 will help to clarify the activities and objectives of the FRC participants and
steer their efforts toward a common goal, particularly regarding any mandate for the
FRC beyond computing the CLR and 2-year Projection.
EXAMPLE FRC MISSION STATEMENT
Consistent with FDIC.s mission to protect insured
depositors and maintain public confidence in the nation's
financial system, the FRC is responsible for producing
quarterly estimates of losses from failures in the
following four quarters (the Contingent Loss Reserve)
and for producing a 2-year loss estimate, both bounded
by confidence intervals.
These estimates will be supplemented, as appropriate,
by additional measures that provide an indication of
exposure to the insurance funds.
All estimates will reflect inputs from DIR, DSC, DOF,
and DRR, and will be based on a process that is
systematic, transparent, well-documented, and
grounded in objective analysis, and that makes use of
supervisory data and market indicators. The underlying
methodology will be approved by the GAO, and the
Contingent Loss Reserve calculation will be in
accordance with GAAP.
1.3.b. The FRC should create a standardized meeting agenda and distribute it
well in advance. Discussions at FRC meetings would be more focused if the group
worked from a detailed agenda that listed discussion topics (e.g., names of
particular institutions), along with a designated discussion leader for each item. To
ensure that all FRC principals can adequately prepare for these discussions, this
agenda should be distributed one week in advance.
1.3.c. The FRC should create standardized, synthesized briefing materials and
distribute them well in advance. The first page of the briefing materials should be
a FRC dashboard depicting the most essential facts and statistics for FRC
principals to consider (Exhibit 1-11). Immediately thereafter, DIR should include a
synthesized memorandum interpreting what the FRC dashboard and any other
relevant information imply for the FRCs decisions at the coming meeting. The
remaining briefing materials should include only those items that are relevant to
specific decisions that the FRC will make. For example, if the FRC will discuss
whether to reserve less for a particular institution, then the specifics of that
institution should be included. If the FRC will discuss whether to deviate from
historical failure rates, then materials on leading indicators of failure rates would be
appropriate. All these materials should be distributed at least 2 business days in
SAMPLE FRC DASHBOARD AT HORIZON 1
CLR 1 year
Confidence interval (90%)
CLR 2 years
Confidence interval (90%)
Insurance losses (LTM)
Banking credit information
CAMELS (re-rated banks)
** CAMELS (re-rated banks)
Average Default Probability, KMV, top-20 money center
BIF (net of CLR)
BIF Ins. Dep.
SAIF (net of CLR)
SAIF Ins. Dep
Largest contributors to reserve
Big Bank 1
Big Bank 2
Big Bank 3
Big Bank 4
Big Bank 5
* Exceptions and over limit conditions indicated in bold
** Standard deviation
1.3.d. The FRC should limit attendance at its meetings. Attendance at the FRC
decision meetings should be restricted to the eight FRC principals and one to two
supporting participants per division. The presence of five FRC principals (or their
designees) will constitute a quorum. To streamline discussions, FRC principals
should discourage other participants from speaking unless recognized by the chair.
1.3.e. A chairperson should be formally designated to manage FRC meetings. A
formal chairperson would increase efficiency of FRC meetings by keeping
discussions on point and managing the groups decision-making. DIRs Deputy
Director of Financial Risk Management and Research should formally chair each
1.3.f. The FRC should come to each decision by a vote of the FRC principals. A
formal process for reaching decisions would help the committee to restrict its
attention to areas of genuine uncertainty and disagreement. As such, for each
needed decision, the FRC chairperson should call for a quick voice vote by the FRC
principals in attendance, with the chairperson casting the deciding vote if necessary.
1.3.g. The FRC should set thresholds for when it will discuss whether to override
the CLR reserve for a given institution. One way to focus deliberations would be
to decide on override criteria in advance. For example, the FRC should set
thresholds that will automatically put an institution on an override list. The FRC
would discuss each institution and vote on whether to deviate from the failure rate
or loss rate applied to that institution under the CLR formula. The FRC should set
such thresholds based on institution size (e.g., any institution with over $750
million in assets) and the amount of reserves under the CLR formula (e.g., the
10 institutions with the largest reserve amounts). The FRC may elect to discuss
additional institutions that are nominated by FRC members because of unique
characteristics (e.g., an institution whose franchise value is so large that its loss rate
will likely be zero). In discussing overrides for failure rates, DSC has the most
relevant information, so it should lead the discussion and take primary
responsibility for informing the group. DRR should do the same for loss rates.
1.3.h. The FRC should institute formal and systematic feedback loops to assess
and improve its performance. On a regular basis (e.g., March and September) DIR
should provide the FRC with a brief assessment of the performance and
development of the FDICs reserve models (e.g., the CLR methodology, the Credit
Risk Model, etc.). Based on these briefings, the FRC should convey to DIR what
additional improvements would most benefit the FRC. In addition, the FRC should
regularly (e.g., June and December) look back on any of its departures from the
CLR methodology (e.g., altering failure probabilities within the 90 percent
confidence interval) to determine whether, in retrospect, those departures improved
the accuracy of the FRCs reserving decisions.
1.3.i. The FRC should decide systematically on next steps. At the end of each
FRC meeting, the group should discuss and approve a set of next steps, focusing on
unresolved issues that warrant further investigation and action before the next FRC
meeting. The FRC Chair should take the lead role to ensure the required execution
prior to the next meeting.
17 Interview with original participant in the FDICs Failure Projection Working Group.
18 Institutions with CAMELS ratings 4 to 5, and those designated as certain failures.
19 For example, by making the estimates correct on average (i.e., unbiased) or correct more often (e.g., with smaller
mean squared error).