LIBOR TRANSITION: LENDING WITH ALTERNATE AND ALTERNATE-ALTERNATE RATES - June 16th, 2020 10 AM, US Eastern Daylight Time
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LIBOR TRANSITION: LENDING WITH ALTERNATE AND ALTERNATE-ALTERNATE RATES June 16th, 2020 10 AM, US Eastern Daylight Time
1
OPENING REMARKS DAN
ROSENBAUM
Partner, Retail and
Business Banking
Dan.Rosenbaum@oliverwyman.com
INDUSTRY PANELIST
Timothy J. Bowler
President of ICE Benchmark
Administration
OLIVER WYMAN HOSTS
Dan Rosenbaum Adam Schneider
Partner, Retail and Business Banking Partner, Lead LIBOR Platform
Dan.Rosenbaum@oliverwyman.com Adam.Schneider@oliverwyman.com
Umit Kaya Esther Bruegger
Partner, Finance & Risk Principal, Finance & Risk
Umit.Kaya@oliverwyman.com Esther.Bruegger@oliverwyman.com
© Oliver Wyman 3
LIBOR TRANSITION: LENDING WITH ALTERNATE AND
ALTERNATE-ALTERNATE RATES – AGENDA
1 Opening Remarks Dan Rosenbaum
2 Why Alternates to the Alternate? Adam Schneider
3 Intercontinental Exchange: USD Bank Yield Index
Timothy J. Bowler
ICE Benchmark Administration
4 The Million (Trillion?) Dollar Question: How Do We Lend?
Umit Kaya
Esther Bruegger
5 Closing Remarks Dan Rosenbaum
© Oliver Wyman 4
2
WHY ALTERNATES TO
THE ALTERNATE? ADAM
SCHNEIDER
Partner, Lead LIBOR
Platform
Adam.Schneider@oliverwyman.com
WHILE SOFR WAS RECOMMENDED BY ARRC IN 2017 TO REPLACE USD
LIBOR, ITS USE IN LENDING HAS BEEN MORE CONTROVERSIAL
2017: ARRC identifies SOFR 2019: ARRC issues guidance Mid-2020: Minimal use of SOFR in
as its recommended rate on how to use SOFR in lending lending; ARMs by end of year
2018 2020 2022
2017 2019 2021
2018: SOFR published by the 2019: ARRC Calendar 2021: lots of SOFR
NY Federal Reserve April; swaps details workings lending needed – or another
start trading; futures in May of SOFR ARMs rate to emerge?
Compounding the move to SOFR: while the ARRC recognizes the need for a term rate, it also urges
lenders to consider using a compounded or average SOFR
But while SOFR should be relatively easy to Those who are able to use SOFR should not wait for
incorporate into derivatives, participants in many the term rates in order to transition […] the ARRC
cash products may find use of an overnight rate believes it should be possible to use compound or
unfamiliar […] To address this issue, the ARRC has simple averages of SOFR and that many users will
explicitly included a goal of producing a forward- come to find it more convenient to do so once they
looking term rate for use in cash products. become more familiar with the new environment.
– ARRC Second Report, March 2018 – ARRC’s User’s Guide to SOFR, April 2019
© Oliver Wyman 6
WHY DOES SOFR HAVE WIDE ACCEPTANCE IN DERIVATIVES MARKETS
BUT LESS SO IN LENDING?
Criteria Lending Swaps
Anchored in observable transactions
Acceptable to regulators / IOSCO compliant
Sufficiently deep liquid underlying market that is sustainable
Published daily
Good representation of funding conditions Overnight funding NA
Incorporates banks’ own credit spread NA
Term rate
Available in different tenors expected 2021
NA
Inherent volatility, can be
Not highly volatile reduced through averages
NA
Complexity will be reduced by
Can be integrated into existing infrastructure availability of term rates
© Oliver Wyman 7
IN REACTION TO THESE CONCERNS, THE NY FED IS FACILITATING INDUSTRY DISCUSSION ON A CREDIT SENSITIVE SPREAD OVER SOFR REGIONAL BANKS SOUND ALARM OVER NEW INTEREST RATE BENCHMARK October 17th, 2019 Executives from 10 regional banks sent a letter to the federal banking regulators last month expressing concern that […] SOFR on a standalone basis “is not well suited to be a benchmark for lending products” • Following this letter, the Fed/FDIC/OCC met with signatories on February 25, 2020 to discuss ways to support the transition of loan products from LIBOR. This meeting led to the creation of Credit Sensitivity Group Workshops to discuss potential challenges of lending with SOFR. • On June 4th 2020, the NY Fed held a Credit Sensitivity Workshop1 which discussed adding a credit sensitive spread over SOFR 1. https://www.newyorkfed.org/medialibrary/media/newsevents/events/markets/2020/csg-first-workshop-public-agenda.pdf © Oliver Wyman 8
THE NY FED ALSO HAS INDICATED IT WILL NOT OPPOSE ALTERNATIVES
TO SOFR THAT ARE IOSCO-COMPLIANT
US FED’S LIBOR-TRANSITION POWELL: AMERIBOR ‘FULLY
PANEL WOULD BACK ANY ACTIVE APPROPRIATE’ FOR BANKS WHEN
BENCHMARK THAT’S ROBUST, IT REFLECTS COST OF FUNDING
IOSCO-COMPLIANT
June 3rd, 2020
May 18th, 2020
“We have been clear that the ARRC’s
The US Federal Reserve panel overseeing the recommendations and the use of SOFR are
transition from tarnished LIBOR said it would voluntary and that market participants should
support any active benchmark — not just the seek to transition away from LIBOR in the
Secured Overnight Financing Rate — as an manner that is most appropriate given their
alternative if the rate is robust and complies specific circumstances,” Powell said…“While
with international principles. [AMERIBOR] is a fully appropriate rate for the
banks that fund themselves through the
It said it supports rates that meet three American Financial Exchange or for other
criteria: They are robust, compliant with the similar institutions for whom AMERIBOR may
2013 [IOSCO] benchmark principles, and reflect their cost of funding, it may not be a
available for use before official support for natural fit for many market participants.”
LIBOR is to be withdrawn at the end of 2021.
© Oliver Wyman 9
THE LENDING CONTENDERS TODAY WE
Various types of SOFR using existing
LOOK AT
1 overnight rates, e.g. compounded in
arrears, in advance
2
Variation of existing floating rate
reference rates, e.g. Prime, CMT
3 ICE Bank Yield Index
4 AFX AMERIBOR ICE Bank Yield Index
5 Term SOFR
6
Potential other contenders, e.g.
outcome of Credit Sensitivity Group
© Oliver Wyman 103
ICE: USD BANK YIELD
INDEX TIMOTHY J.
BOWLER
President of ICE Benchmark
AdministrationUSD BANK YIELD INDEX ICE Benchmark Administration Timothy J. Bowler, President JUNE 2020
Background
• U.S. dollar LIBOR has been widely used in lending transactions over the past thirty years.
• Lenders and borrowers have generally expressed comfort in the economic premise behind U.S. dollar LIBOR as the
benchmark:
• Allows lenders to extend credit based upon marginal unsecured bank funding cost; while
• Facilitating competitive credit markets where the borrower does not need to take its specific lender’s, or a small group of
lenders’, cost of funds risk.
• The transition to risk free rates has raised questions on the risks related to moving away from LIBOR to overnight rates and, in
the case of U.S. dollars, secured rates for lending arrangements.
• For lenders these risks include a potential:
• Divergence between realized marginal funding cost and the yields on overnight rates; and
• Increased usage in undrawn liquidity facilities; particularly during a period of stress.
• For borrowers these risks include a potentially:
• Less competitive lending market; and
• Reduced access to undrawn lending facilities.
INTERCONTINENTAL EXCHANGE 13Credit Benchmark Rationale
Risk free rates (e.g. UST & SOFR) and marginal unsecured bank borrowing costs are different and can diverge
INTERCONTINENTAL EXCHANGE 14Bank Yield Index - Introduction
• In order to help facilitate the transition away from LIBOR and to meet the needs of lenders who want to retain
a credit sensitive benchmark and borrowers who value term settings, IBA developed the Bank Yield Index.
• The Bank Yield Index is a forward-looking, credit-sensitive benchmark designed specifically as a potential
replacement for LIBOR for U.S. dollar lending activity.
• The index uses unsecured bank debt transactions for the construction of an unsecured bank yield curve. The
input data includes:
• Bank funding transaction data (yields on deposits, CDs and CP transactions, i.e. does not require expert
judgment); and
• Yield data on bank bonds transactions sourced from TRACE (adjusted to money market basis).
• IBA determines term settings from the unsecured bank yield curve similar to the term settings that are found
in LIBOR today (e.g. one month, three months).
• IBA is currently testing the concept with funding data inputs from fourteen USD LIBOR Panel Banks.
INTERCONTINENTAL EXCHANGE 15Bank Yield Index - Methodology
IBA collates bank funding transaction data and secondary market transaction data, and calculates the Bank Yield
Index. This involves:
1. Aggregation of eligible transactions over initial five day window; increasing the window if necessary to meet minimum
aggregate trade count and volume thresholds (currently $15B and 100 discrete transactions 1);
o IBA chose a five day window to ensure a diverse and robust data set that reflects average bank yields
o Minimum funding volumes and transaction counts are set to ensure a representative benchmark
2. Calculation of a fitted unsecured bank yield curve using a regression analysis across all eligible data points;
3. Review of transaction data points against fitted curve to identify extreme outliers for exclusion (currently any trades over
200bps above or below the curve are excluded), and the curve fitting is repeated using the remaining transactions; and
4. Determination of 1M, 3M and 6M Index rates from the fitted bank yield curve.
1IBA also uses minimum trade count thresholds for various maturity buckets across the yield curve. Further detail can be found on the IBA website here:
https://www.theice.com/publicdocs/IBA_US_Dollar_ICE_Bank_Yield_Index_Fourth_Update.pdf
INTERCONTINENTAL EXCHANGE 16Bank Yield Index – Example calculation from May 14
Yield
Days
The dots in the chart are transaction data points sourced over 5 business days (May 7 to May 14) which are
used to derive a best-fit bank yield curve. From this yield curve “average” one-month, three-month and six-
month points can be determined (red circles) and used as the Index settings.
INTERCONTINENTAL EXCHANGE 17Bank Yield Index – Correlation With Other Indexes
Comparison of test results to U.S. dollar LIBOR and Treasury Yields : 1 Month
INTERCONTINENTAL EXCHANGE 18Bank Yield Index – Correlation With Other Indexes
Comparison of test results to U.S. dollar LIBOR and Treasury Yields : 3 Month
INTERCONTINENTAL EXCHANGE 19Bank Yield Index – Input Data Over The Testing Period
Review of data sourced to build the Bank Yield Index test rates from December 2017
INTERCONTINENTAL EXCHANGE 20Bank Yield Index – Input Data Over The Testing Period
Review of data sourced to build the Bank Yield Index test rates from December 2017
INTERCONTINENTAL EXCHANGE 21Bank Yield Index – Supplement to SOFR
The Bank Yield Index can also be calculated as a spread to SOFR rates
• Collate the transactions over a rolling collection window, as
in the preliminary methodology.
• Determine a Transaction Credit Spread for each transaction
by subtracting the contemporaneous risk free market rate
(e.g. Term SOFR for the same day) from the unsecured
bank debt yields observed (i.e. determine the credit spread).
• Create a fitted credit spread curve to the data points. (Blue
line on chart)
• Determine Bank Yield Credit Spreads from the fitted yield
curve. (Red circles on the chart)
• Add the Credit Spreads to the current term risk free rate
(e.g. Term SOFR today) to determine the Bank Yield Index.
• This realized spread to risk free rates can also be
added to compounded and in arrears SOFR
calculations.
INTERCONTINENTAL EXCHANGE 22Bank Yield Index - Next Steps
1. Engage with members of the Credit Sensitivity Group (GSG) hosted by the New York Fed to seek advice on key
aspects of the Bank Yield Index, including:
• Input data used, including:
• how to best create a nexus to SOFR rates, and
• should funding and bond data be used or only funding data;
• Time period used to calculate the rates (i.e. is the rolling 5-day window appropriate or should a shorter or longer
window be used).
2. Update the Bank Yield Index methodology based upon feedback received from the CSG.
3. Obtain commitments from banks to provide their funding data to IBA on a daily basis to build the Index.
4. Once steps 1-3 are complete, establish a U.S. domicile from which the Bank Yield Index would be produced on
an on-going basis.
INTERCONTINENTAL EXCHANGE 23About Intercontinental Exchange
Intercontinental Exchange (NYSE: ICE) is a Fortune 500 company formed in the year 2000 to modernize markets. ICE serves
customers by operating the exchanges, clearing houses and information services they rely upon to invest, trade and manage
risk across global financial and commodity markets. A leader in market data, ICE Data Services serves the information and
connectivity needs across virtually all asset classes. As the parent company of the New York Stock Exchange, the company is
the premier venue for raising capital in the world, driving economic growth and transforming markets.
Trademarks of ICE and/or its affiliates include Intercontinental Exchange, ICE, ICE block design, NYSE and New York Stock
Exchange. Information regarding additional trademarks and intellectual property rights of Intercontinental Exchange, Inc. and/or
its affiliates is located at http://www.intercontinentalexchange.com/terms-of-use. Key Information Documents for certain
products covered by the EU Packaged Retail and Insurance-based Investment Products Regulation can be accessed on the
relevant exchange website under the heading “Key Information Documents (KIDS).”
Safe Harbor Statement under the Private Securities Litigation Reform Act of 1995 -- Statements in this press release regarding
ICE's business that are not historical facts are "forward-looking statements" that involve risks and uncertainties. For a discussion
of additional risks and uncertainties, which could cause actual results to differ from those contained in the forward-looking
statements, see ICE's Securities and Exchange Commission (SEC) filings, including, but not limited to, the risk factors in ICE's
Annual Report on Form 10-K for the year ended December 31, 2019, as filed with the SEC on February 6, 2020.
INTERCONTINENTAL EXCHANGE 24Important Information and Disclaimers
ICE Benchmark Administration Limited (IBA) is authorised and regulated by the Financial Conduct Authority for the regulated activity of administering a
benchmark, and is authorised as a benchmark administrator under the EU Benchmarks Regulation (Regulation (EU) 2016/1011 of 8 June 2016). ICE, LIBOR,
ICE LIBOR, ICE Swap Rate and ICE Benchmark Administration are trademarks of Intercontinental Exchange, Inc. (ICE) and/or its affiliates. All rights in these
trademarks are reserved and none of these rights may be used without a written license from ICE and/or its affiliates, as applicable.
The contents of this presentation, all associated data and information and all discussions in connection with it should not be disclosed, transmitted, distributed or
disseminated, either directly or indirectly through any third parties, to any person or entity without the express written consent of IBA. Any person receiving this
presentation in error should inform IBA immediately, destroy and disregard this presentation and not disclose, share, use or rely on it in any way. The
information and data contained herein constitutes valuable information and property owned by IBA, its affiliates, licensors and/or other relevant third parties.
ICE and IBA reserve all rights in the methodologies (patent pending) and information and data disclosed in this presentation, and in the copyright in this
presentation. None of these rights may be used without a written licence from ICE and/or its affiliates, as applicable.
This presentation is not, and should not be taken as or relied upon as constituting, financial, investment, legal, tax, regulatory or any other form of advice,
recommendation or assurance. Data and outputs relating to the ICE bank yield index are provided for information and illustration purposes only, might not be
accurate or reliable and may not be used for any other purpose. In particular, they are not currently intended for use as, and IBA expressly prohibits their use as,
an index by reference to which the amount payable under a financial instrument or a financial contract, or the value of a financial instrument, is determined, or
as an index that is used to measure the performance of an investment fund with the purpose of tracking the return of such index or of defining the asset
allocation of a portfolio or of computing the performance fees. Such outputs should not be used as a benchmark within the meaning of the EU Benchmarks
Regulation or otherwise.
The ICE bank yield index methodologies disclosed in this presentation are subject to changes in response to feedback from market participants and other
stakeholders and IBA's further development work, which might alter the information and data shown in this presentation. There is no guarantee that IBA will
continue to test the ICE bank yield index, be able to source data to derive the index or publish the index in the future. Users of LIBOR should not rely on the
potential publication of the ICE bank yield index when developing and executing transition or fallback plans.
None of IBA, ICE, or any of its or their affiliates accepts any responsibility or will be liable in contract or tort (including negligence), for breach of statutory duty or
nuisance, for misrepresentation or under antitrust laws or otherwise, or in respect of any damage, expense or other loss you may suffer arising out of or in
connection with the information and data contained in or related to this presentation or any use that you may make of it or any reliance you may place upon it.
All implied terms, conditions and warranties and liabilities in relation to the information and data are hereby excluded to the fullest extent permitted by law. None
of IBA, ICE or any of its or their affiliates excludes or limits liability for fraud or fraudulent misrepresentation or death or personal injury caused by negligence.
Trace Reporting and Compliance Engine and TRACE are trademarks of Financial Industry Regulatory Authority, Inc. (FINRA), in the US and/or other countries.
All rights reserved. See http://www.finra.org/industry/trace for further details regarding TRACE. The U.S. Dollar ICE Bank Yield Index is not associated with, or
endorsed or sponsored by, FINRA.
SOFR is published by the Federal Reserve Bank of New York (New York Fed) and is used in this presentation subject to New York Fed Terms of Use for Select
Rate Data (available at https://www.newyorkfed.org/markets/reference-rates-terms-of-use). New York Fed has no liability for your use of the data contained in
this presentation. The ICE bank yield index is not associated with, endorsed or sponsored by the New York Fed.
INTERCONTINENTAL EXCHANGE 254 UMIT KAYA
THE MILLION Partner, Finance & Risk
Umit.Kaya@oliverwyman.com
(TRILLION?) DOLLAR
QUESTION: HOW DO
WE LEND? ESTHER
BRUGGER
Principal, Finance & Risk
Esther.Bruegger@oliverwyman.comWITH ~$350BN OF REVENUES TIED TO LIBOR IN 2019, THE INDUSTRY
IS FACING A COMPLEX PRICING PROBLEM FRAUGHT WITH RISK
Outstanding USD LIBOR balances year end 2019
$5.9 TN
~$8.5TN
LIBOR balances for loans &
FRNs
~$350BN
$1.5 TN
$1.2 TN
Estimate of interest revenue
tied to LIBOR loans and FRNs
Commercial Loans Consumer Loans FRNs
Source: BIS, Bloomberg, FRB: Z.1 Release, Bank 10-K 2019 Financial Statements, Oliver Wyman Analysis
© Oliver Wyman 28ALTHOUGH SOFR HAS BEEN THE MOST VISIBLE ALTERNATIVE, OTHER
OPTIONS HAVE EMERGED WITH VARYING CHARACTERISTICS
SOFR1 ICE Bank Yield Index2 AMERIBOR3,4,5,6,7,8
Anchored in observable transactions
Acceptable to regulators / Fed (in statement on IOSCO
TBD
IOSCO compliant compliant rates)
Sufficiently deep liquid underlying +$15BN of transactions
+$1TN of daily transactions ~$2.5BN of daily transactions
market that is sustainable over 5 days
Under development,
Published daily
expected late 2020
Good representation of funding Marginal funding cost Marginal funding cost of
Overnight funding
conditions of large banks regional and community banks
Incorporates banks’ own credit spread
Term rate Under development,
Available in different tenors Under development
expected 2021 expected late 2020
Inherent volatility, can be
Not highly volatile Less volatile than SOFR Less volatile than SOFR
reduced through averages
Can be integrated into existing
Complexity will be reduced by availability of term rates
infrastructure
Active derivatives market Currently active TBD Under development
1. ARRC: https://www.newyorkfed.org/arrc; 2. U.S. Dollar ICE Bank Yield Index Test Rates: https://www.theice.com/iba/Bank-Yield-Index-Test-Rates; 3: AMERIBOR Methodology: https://ameribor.net/; 4
AMERIBOR In the News, AFX Press Release - Federal Reserve Chairman Powell Statement re AMERIBOR as a Replacement for LIBOR: https://ameribor.net/; 5. AMERIBOR in the News, AFX Press Release - AFX
Announces Record AFX Monthly Volume: : https://ameribor.net/; 6. AFP Report on AMERIBOR: https://www.afponline.org/docs/default-source/default-document-library/afpex-summer-f2-libor.pdf?sfvrsn=0;
7. CBOE AMERIBOR Futures: https://www.cboe.com/products/futures/ameribor-futures; 8. HISTORICAL OVERNIGHT AMERIBOR® RATES: https://ameribor.net/
© Oliver Wyman 29LIBOR DECOUPLES FROM THE RISK-FREE RATE DURING CRISES
Spread of 1-month LIBOR to 1-month SOFR compounded in arrears
4.5%
4.0%
3.5%
3.0%
2.5%
2.0%
1.5%
1.0%
0.5%
0.0%
1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
Source: Bloomberg, Oliver Wyman analysis
© Oliver Wyman 30USING ALTERNATIVE RATES FOR LENDING PRESENTS NEW DYNAMIC
PRICING CHALLENGES
Implied margins to keep interest revenues equal for a 1M LIBOR +200 bps loan
Financial crisis: Post Crisis: Expansion: Pandemic: Forward-Looking
Falling rates Flat rates Rising rates Falling rates (Present–2025)
(2008–2009) (2010–2014) (2018–2019) (Mar ‘20-Present)
1M LIBOR +200 bps +200 bps +200 bps +200 bps +200 bps
1M SOFR
compounded in +270 bps +211 bps +210 bps +259 bps +215 bps
arrears
1M AMERIBOR
compounded in Not available Not available +201 bps +250 bps Not available
arrears
1M Bank Yield
Not available Not available +198 bps +196 bps Not available
Index
Source: Blomberg, ICE, AFX, Oliver Wyman analysis using LIBORITHMICSTM
© Oliver Wyman 31ON A FORWARD-LOOKING BASIS, THE UNCERTAINTY AROUND THE
RATE ENVIRONMENT WILL HAVE AN IMPACT ON SPREADS
Implied margin over SOFR for a LIBOR+200 bps floating rate loan
repricing monthly
Margin to keep interest revenues
constant under forward rates + 215 bps
Margin to keep interest revenues
constant with simulated rate uncertainty + 232 bps
Source: Bloomberg, Oliver Wyman Analysis
© Oliver Wyman 32PRODUCT FEATURES SUCH AS FLOORS CAN PARTIALLY REPLACE
HAVING TO CHARGE HIGHER MARGINS
Implied margin over SOFR for a LIBOR+200 bps floating rate loan
repricing monthly
Margin to keep interest revenues
constant under forward rates + 215 bps
Margin to keep interest revenues
constant with simulated rate uncertainty + 232 bps
Margin to keep interest revenues
constant with simulated rate uncertainty + 211 bps
and 75 bps SOFR floor
Source: Bloomberg, Oliver Wyman Analysis
© Oliver Wyman 33HOWEVER, FLOORS DO NOT WORK AS WELL IN ALL RATE
ENVIRONMENTS AND OTHER FEATURES SHOULD ALSO BE CONSIDERED
Illustrative analysis under different rate environments: Impact of Commentary
floors and spread adjustments for SOFR pricing of a term loan
50 • The gap between LIBOR
25 and SOFR can be
0 substantial and sustained in
-25
crisis situations
-50 • Spread adjustments and
rate floors can address
-75
some of the shortfall
-100
• Floors work well in low rate
-125
environments, but are less
-150
effective under high rates
2004
2012
2020
1999
2000
2001
2002
2003
2005
2006
2007
2008
2009
2010
2011
2013
2014
2015
2016
2017
2018
2019
• For lines of credit, the
problem is exacerbated due
Difference between LIBOR and SOFR to the embedded
drawdown optionality
Difference between LIBOR and SOFR with 100 bps floors
Source: Bloomberg, Oliver Wyman Analysis
© Oliver Wyman 34LOAN PRICING NEEDS TO DEAL WITH MULTIPLE RATE STRUCTURES – A
COMPLEX UNDERTAKING; WE HIGHLIGHT 5 KEY ACTIONS
There are good reasons to Product design will have to Product development will need
use most of these rates for incorporate client and bank to carefully consider multi-rate
particular types of lending strategy offerings and monitor risks
Collect client perspectives
Compounded Product development
• Understand client preferences,
SOFR in advance including operational constraints • Develop multi-rate offering as
• Understand market dynamics and needed
Compounded client price sensitivity • Assess downstream implications
SOFR in arrears
• Address analytics needs in a timely
Develop bank strategy fashion
Prime 5 Key
CMT • Determine FTP methodology and
Actions IRRBB strategy
• Release product design guidelines for
AMERIBOR businesses as needed
Monitor risks
• Assess and manage financial
Term SOFR Assess market environment implications
• Collect regulatory expectations and • Involve risk management across all
guidelines stages of product development
Bank Yield Index
• Review peer and industry
developments and innovation
© Oliver Wyman 355
CLOSING REMARKS DAN
ROSENBAUM
Partner, Retail and
Business Banking
Dan.Rosenbaum@oliverwyman.comCONTACT US
Dan Rosenbaum Adam Schneider
Dan.Rosenbaum@oliverwyman.com Adam.Schneider@oliverwyman.com
Umit Kaya Esther Bruegger
Umit.Kaya@oliverwyman.com Esther.Bruegger@oliverwyman.com
© Oliver Wyman 38You can also read
