This blog is reposted from James Dempsey’s website.
Last week two new reports appeared on the Royal Bank of Scotland, this time focusing on its activity since the financial crisis. Both, in their own ways, raise new versions of concerns that have been around since the crisis and before – (1) that penalties imposed on banks target the wrong people; and (2) that banks are still failing in one of their primary responsibilities, the good management of risk.
The more serious accusations appear in the Tomlinson Report compiled by the ‘Entrepreneur in Residence at the Department for Business, Innovation and Skills’. Tomlinson says that:
‘The experiences of many businesses across the country suggests that, at least within RBS, there are circumstances in which the banks are unnecessarily engineering a default to move the business out of local management and into their turnaround divisions, generating revenue through fees, increased margins and devalued assets.’
Whether these accusations should be upheld will be determined by the Financial Conduct Authority and the Prudential Regulation Authority, to which Vince Cable has handed the report. If they are, however, and penalties follow as a result, who will those penalties hit?
If they are financial penalties they will, primarily, hit shareholders, or in other words tax payers (who own 81% of the bank). This is a crazy state of affairs. Those who have allegedly done wrong are the employees who directed and engaged in the activity in question, not the public who are reluctant owners of the bank as a result of rescuing it from previous irresponsible activity.
The second report, by Sir Andrew Large, focuses on RBS’s SME lending operation. Some reasons it identifies why RBS failed to meet its lending targets are as follows:
- ‘RBS’s SME lending objectives were not consistent with its tougher credit standards, and limits on certain types of lending (especially to the Commercial Real Estate sector) introduced to manage portfolio risks
- ‘Internal restructuring had a negative impact by fragmenting responsibility for SME lending
- ‘The ongoing SME business has had difficulty in finding the best way to deploy its people and investment budget to originate and win the lending opportunities that are available to it
- ‘Although risk management policies are in line with good prudential standards, customer-facing staff and Credit Officers are risk averse in their behavior
- ‘RBS lending process is time consuming and loan applications take longer than at other banks
- ‘Credit skills of customer-facing staff that were neglected in the run up to the financial crisis have improved, but remain variable
- ‘Until relatively recently, deposit gathering was prioritised over lending’
One way of summarising these points is that RBS is not managing risk well, since internal structures and procedures are inefficient, and behaviour is overly risk averse. Banks have rightly been criticised for helping precipitate the crisis through poor risk management, by taking on too many high risks. Now, it appears, things have gone the other way.
Banks have an obligation to manage risk well and this involves striking the right balance between recklessness and extreme risk aversion. It appears that this obligation is still not being met, although for different reasons than before.