Welcome To
The Bottom Line

I’m delighted that Sievewright & Associates (S&A) is now a part of SRM!

The acquisition comes after five straight years of solid growth in the S&A business, where we served more than 100 credit unions across the country ranging from $400 million to $53 billion of assets. The opportunity to join forces with an organization of SRM’s caliber, scale the business, and broaden support for credit unions all presented compelling reasons to sell.

This year’s edition of Money20/20 was back in full force. It was a well-attended event by all players in the ecosystem, a definitive difference from last year when lingering COVID-19 travel restrictions kept many would-be attendees on the sideline.

The conversation among the 13,000 registered attendees in Las Vegas, and countless others working the periphery, expanded beyond last year’s darling – cryptocurrency – to encompass other issues financial institutions will face as they head into a potentially turbulent 2023. This year’s top themes included safety and security, innovation, and evolving regulation.

Here are a few recurring observations from our time there...

Budgeting season for 2023 is slowly wrapping up as banks and credit unions forecast revenue opportunities and looming expenses.

Financial institutions are considering future interest rate hikes, regulatory oversight, and increasing personnel and operational costs, among other things. The bigger picture is that client retention and recruitment will be critical to long-term success – invest now to ensure you’re ready to compete. 

At SRM, we urge banks and credit unions to take a hard look at third-party contracts as they plan for the new year. There are also other considerations that should be made as you prepare for the future.

This year, we polled some of our experts, asking them to highlight areas that merit extra attention. Here are some highlights from their responses.

Professionals focused on the strategic and operational aspects of digital assets such as cryptocurrency have learned to disregard the media cycles.

Last year’s breathless hype – driven almost entirely by a retail investor frenzy – has given way to a “crypto is dead” storyline that emphasizes volatility and fraudulent applications. Lost in the noise is the fact that Bitcoin’s price has been relatively stable over the past four months.

Federal regulators continue to advise on how banks and credit unions conduct due diligence for digital assets solution providers.

A lapse in vetting could expose FIs to an array of risks, ranging from reputational impact to non-compliance with government sanctions and BSA requirements.

Branch networks require significant investment, real estate is getting more expensive, and utilities and security costs are spiking. Offices can also be labour-intensive, assuming financial institutions can attract and retain the right frontline staff.

At the same time, branch traffic is declining, limiting opportunities for locations to generate revenue. If ROI is a primary consideration, it’s getting harder for banks and credit unions to justify having large branch networks.

It has been almost a year and a half since the Fed had requested public comment on a “non-substantive” proposed amendment to Regulation II that would 1.) specify that the prohibition on network exclusivity applies to card-not-present debit card transactions, 2.) clarify the responsibility of the issuer to enable at least two unaffiliated networks to comply with the prohibition on network exclusivity, and 3.) standardize and explain the use of certain terminology. The proposal was anything but non-substantive and would have fundamentally altered issuers’ compliance obligations under Durbin. The Fed received more than 2,750 comments, and it has taken nearly a year since the comment period was completed to receive a final ruling. The ruling has finally arrived.

We're beginning to get some clarity from the White House regarding its approach to digital assets, including the potential development of a Central Bank Digital Currency (CBDC).

With the release of a wide-ranging report, the White House appears to be embracing digital assets and their potential for transparent, cost-efficient, and inclusive financial services. A background press call provided even more insight into the Biden Administration's thinking.

Banks and credit unions interested in offering Buy Now, Pay Later (BNPL) services should be pleased with the latest report from the Consumer Financial Protection Bureau (CFPB).

Many FIs have been reluctant to dive into the popular consumer offering, largely due to uncertainty over the regulatory environment. SRM asserted in a recent report that banks and credit unions have the experience and tools necessary to handle regulatory scrutiny.

The Biden Administration's March executive order seeking information on digital assets' usage and security set a flurry of activity into motion. This included a mandate for the Treasury Department to deliver a report on the future of money and payments systems. The agency issued a public request for comment in July, and SRM quickly responded, drawing from our detailed and ongoing coverage of cryptocurrency and other digital assets.

You can read our complete submission here; however, the condensed version below highlights the key points we believe every financial institution should consider as policies toward digital assets take shape.