ABA Banking Journal - July/August 2016 - (Page 30)
It's all a matter of perspective, control-
and a good amount of confidence
BY KERRY o'LEARY
anks approaching the $10 billion asset threshold
face a daunting compliance challenge-not just a
first examination with a higher level of scrutiny, and
not just an entirely new supervisory agency (the
Consumer Financial Protection Bureau), but also a
necessary transformation of both personnel and operations.
However, bankers whose $10 billion mark is now in the
rearview mirror agree: when you manage the timing and the
approach, crossing the threshold becomes less about growing
pains and more about slow and steady gains.
for managing the new compliance requirements and
relationships with their regulator were at the ready when
the bank hit $10 billion in the second quarter of 2014. (Old
National today has $11.9 billion in assets.)
With the risk committee in place, the group covered a much
broader agenda, rewriting its charter to more extensively cover
regulatory issues and procedures. The committee had board
oversight and quickly got the support of the directors. "Starting
[the charter approval process] early was key," Jones says. "And
getting it right required deep commitment from our board."
Bob Jones, president and CEO of Old National Bancorp,
Evansville, Ind., began thinking about crossing the threshold
right after Dodd-Frank took effect. The bank was on a natural
progression toward $10 billion in assets, so its leaders knew
they had to work a tactical approach into their strategic plan.
Part of that plan included a new risk committee assigned to
lay out a roadmap for crossing into $10 billion territory.
Within the bank, getting the right people in the right roles as
Old National's compliance function evolved both in weight and
specificity became a priority. Specialized employees, which
Jones calls the "best in their breeds" in areas like stress testing
and other quantitative capacities became fixtures in the bank's
examination review team. This expertise came in the form of
new hires and broad employee training.
The road map-an extensive document the bank aptly titled
its "10 Billion Readiness Plan"-was in place three years
before the need for it became a reality. For Old National, that
meant fee structures, predictive models and recommendations
In terms of procedures, stress testing preparation was the
priority and Jones hired permanent staff in this area, too. "We
had to ensure we raised the bar within the bank, as stress
testing is an incredible tool."
Bankers whose $10 billion mark is now in the rearview mirror agree: when
you manage the timing and the approach, crossing the threshold becomes
less about growing pains and more about slow and steady gains.
ABA BANKING JOURNAL | JULY/AUGUST 2016
Table of Contents for the Digital Edition of ABA Banking Journal - July/August 2016
HOW BANK STARTUPS BUILD LEADERS
LEADERSHIP LESSONS FROM THE WORST JOB I EVER HAD
BREAKING THROUGH $10 BILLION
PLATFORMS AND PARTNERS
EXCEEDING CUSTOMER EXPECTATIONS STARTS AT THE CORE
ABA COMPLIANCE CENTER INBOX
FROM THE STATES
CORPORATE SOCIAL RESPONSIBILITY
INDEX OF ADVERTISERS
ABA Banking Journal - July/August 2016