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Publications by Type: Survey of Credit Underwriting Practices, September 2004
The Office of the Comptroller of the Currency (OCC) conducted its tenth annual survey of credit underwriting practices during the first quarter of 2004. The survey identified trends in lending standards and credit risk for the most common types of commercial and retail credit offered by national banks.
The 2004 survey included the 72 largest national banks and covered the 12-month period ending March 31, 2004. Although mergers and acquisitions have altered the survey population somewhat, the surveys for the last nine years have covered substantially the same group of banks. All companies in the 2004 survey have assets of $2 billion or greater. The aggregate loan portfolio of banks included in the 2004 survey was approximately $2.3 trillion as of December 31, 2003. This represents 91 percent of all outstanding loans in national banks.
The OCC examiners-in-charge of the surveyed banks were asked a series of questions concerning overall credit trends for 18 types of commercial and retail credit. Commercial credit for purposes of this survey included 10 categories of loans: syndicated/national loans, structured finance (leveraged finance), asset-based loans, middle market loans, small business loans, international credits, agricultural loans, residential construction, commercial construction, and other commercial real estate. Retail credit consisted of eight categories of loans: residential real estate mortgages, affordable housing, credit cards, other direct consumer loans, indirect consumer paper (loans originated by others, such as car dealers), consumer leasing, conventional home equity, and high loan-to-value (HLTV) home equity loans.
The term "underwriting standards," as used in this report, refers to requirements, such as ones related to collateral, loan maturities, pricing, and covenants, that banks establish when originating and structuring loans. Conclusions about "easing" or "tightening" of underwriting standards are drawn from OCC examiners' observations since the 2003 survey. A conclusion that the underwriting standards for a particular loan category have eased or tightened does not indicate that all the standards for that particular category have been adjusted. It indicates that the adjustments that did occur had the net effect of easing or tightening such underwriting criteria.
Part 1 of this report discusses the overall results of the survey. Part II depicts the survey results in graphs and tables.
Part I - Overall Results
Commercial Underwriting Standards
In 2004, slightly more banks eased credit underwriting standards than tightened them. Examiners reported that 13 percent of banks eased, 12 percent tightened, and 75 percent did not change their commercial underwriting standards. In 2003, by contrast, many more banks tightened than eased: examiners reported that 47 percent of the banks tightened and only 5 percent eased standards. In 2002, no banks were reported to have eased commercial underwriting standards, two-thirds tightened, and one-third made no change. In summary, banks have shifted toward easing over the past few years. In 2002, the net change in standards favored tightening by 62 percent. In 2003, the net difference in favor of tightening slackened to 42 percent. By 2004, net change favored easing by 1 percent.
Commercial underwriting trends at the product level confirm this shift toward easing. The two commercial products that experienced the greatest amount of tightening during the last four years - structured finance and syndicated/national loans - are the front-runners in the swing toward easing. Structured finance provides the most conspicuous example of this shift. In 2004, examiners reported that 15 percent of the banks eased and no bank tightened underwriting for structured finance, compared with no easing and 96 percent tightening four years ago. Examiners also reported a return to net easing for middle market and asset-based loans. While tightening was slightly more prevalent than easing for the remaining commercial products, the percent of banks reported to have tightened in 2004 was much lower than in 2003. Large banks made more adjustments in underwriting standards than smaller banks, and most of their adjustments eased standards.
Examiners cited stronger competition as the primary reason why banks eased commercial standards, followed by an improving economic outlook and risk appetite. When easing standards, banks commonly lowered pricing, lengthened maturity, increased the amount of the credit line, and adjusted covenants. For banks that tightened commercial underwriting standards, the primary reasons cited were risk appetite and the economic outlook. When tightening standards, banks commonly adjusted covenants, lowered the amount of the credit line, and increased collateral requirements.
Examiners reported that credit risk trends in commercial portfolios have moderated. They reported that the percentage of banks with decreased commercial credit risk slightly exceeded those banks with increased risk. While the difference between increased and decreased risk is small, the shift is significant - this is the first time that survey results indicate that more banks experienced a net decrease of credit risk in the commercial portfolio. The shift in risk is attributed to improvements in portfolio quality, external conditions, and portfolio management practices. Structured finance and syndicated/national loans were perceived to have the greatest decrease in risk. Examiners also reported that banks expect credit risk to decline during the next 12 months.
Retail credit tends to be less volatile than commercial credit and, accordingly, retail underwriting standards tend to be more stable. For retail portfolios, although the number of banks easing (13 percent), tightening (13 percent), or making no change (74 percent) is remarkably similar to that reported for commercial credit, the change from tightening to easing has been far more gradual. At the product level, there was only a modest change in underwriting standards from the prior year. For most products, tightening exceeded easing, but the amount of tightening has moderated. Examiners reported that easing outweighed tightening for home equity products; credit cards also experienced easing.
According to examiners, banks eased retail standards primarily because of increased competition and changes in market strategy. When easing, banks reduced debt service requirements, extended amortization schedules and lowered collateral requirements. Sixty-five percent of banks cited risk appetite as the primary reason for tightening, followed by product performance and a change in market strategy. Banks adjusted score-card cutoffs and increased debt service requirements to tighten underwriting standards.
Examiners reported that 75 percent of the banks surveyed reported no change in the overall level of retail credit risk for the past 12 months, and 69 percent of banks expect retail credit risk will remain stable for the next 12 months. At the product level, only three of eight retail products were reported to have a net increase in credit risk in the past 12 months - credit cards and the two home equity products. Examiners cited a decline in the quality of credit card portfolios and concern about external conditions for credit cards and the two home equity loan products as the reasons for the increased risk.
Much has changed in ten years, and banks are in a better position to evaluate and manage the risk associated with easing underwriting standards. Advancements in credit risk management have given banks better tools to differentiate risk and understand the implications of underwriting changes. Additionally, the condition of the banking industry is sound with strong capitalization and record profits. A favorable interest rate environment and an economy that is gradually gaining strength also contribute to the positive credit outlook.
At this phase in the credit cycle, some adjustments to underwriting criteria are to be expected. After several years of sluggish demand for commercial loans, banks are anxious to make deals. However, ambitious growth goals in a highly competitive market can create an environment that fosters imprudent credit decisions. It is now that banks need to be disciplined and adhere to the enhanced credit risk management practices they implemented during the past few years. Exceptions to underwriting standards need to be carefully controlled and monitored and relationship managers must be held accountable for both the quality and the quantity of their deals.
Although many factors contributed to the weakness in commercial credit portfolios during the last cycle, certainly excessive leverage was one of the primary causes. Many observers have commented on how quickly creditors' tolerance for higher leverage has rebounded. Bankers are urged to maintain prudent limits on leverage in their underwriting criteria and should refer to OCC Bulletin 2001-18, "Leveraged Finance - Sound Risk Management Practices," for guidance.
While demand for commercial credit has been lackluster, demand for retail credit has been robust. Many banks have grown their retail portfolios in recent years, largely because of strong consumer demand for residential mortgages and home equity products. Low interest rates, appreciation in home values, and innovative products have sparked the demand. Because of the wave of refinancings, many banks have relatively unseasoned mortgage and home equity portfolios. Additionally, the growing component of adjustable-rate mortgages and the protracted interest-only period associated with many home equity lines of credit mean that many borrowers could be exposed to much higher payments when interest rates rise and principal amortization begins. Banks are encouraged to make sure that risk management practices keep pace with the changing risk characteristics of their retail portfolios brought about by changes in underwriting practices.
The OCC will continue to focus supervisory attention and resources to ensure that credit risk in national banks is appropriately identified and that credit risk management practices are commensurate with risk levels.