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Defensibility

Financial institutions are beholden to several groups of stakeholders including examiners, auditors and board members, all of whom require transparency into the institution’s performance and policies. As a result, defensibility can become a challenge for bank and credit union executives as they determine how to best communicate to each of these groups.

Defensibility can be especially challenging for processes that are spread across multiple groups in the institution. For example, underwriting includes responsibilities from loan officers, analysts, credit operations and executives for approvals. There may be subtle differences in the process or documentation, person to person. To increase defensibility of underwriting decisions, the institution can implement business process management alongside strong internal controls.

The allowance for loan and lease losses (ALLL) calculation is another area that often draws scrutiny because of the complexity of the calculation and assumptions that may be used. Here, technology can aid in the consistent application and documentation of methodologies and assumptions to increase transparency into the model and defensibility of its results.