Comerica Incorporated (CMA) Earnings Call Transcript & Summary

All right. Up next, we have Comerica, and I'll get my disclosures out of the way first. which is for important disclosures. Please see the Morgan Stanley research disclosure website at morganstanley.com/researchdisclosures. The taking of photographs and use of recording devices is not allowed. If you have any questions, please reach out to your Morgan Stanley sales representative. And with that out of the way, we're delighted to have with us today Jim Herzog, CFO of Comerica; and Peter Sefzik, Chief Banking Officer. Thank you so much for joining us.

Thank you, Manan.

Thank you, Manan.

So I want to dig -- well, maybe we'll start with Jim and Peter, if you have some opening remarks, and I want to dig straight into some of the stuff you put out in the slides.

Good. Well, great, and thank you for hosting us, Manan, and thanks for everyone's interest. We did post a deck last night after market closed, and we have our own disclosure. So I'll point everyone to Slide 2 of that deck, we have a safe harbor statement, which I, of course, highly encourage everyone to read and remind you that it does apply to the entirety of this webcast. With that said, we do have a number of mid-quarter updates in that deck. I think we'll be getting into that with a Q&A with Manan here, and we're happy to answer those questions and any implications it has for the outlook. I would like to first just take a step back from that and talk about what we're excited about at Comerica, maybe educate people that aren't assayed with us, with our business model and what we think is a great value proposition. I think some of the points for those of you that are on the webcast, not here, some of those points are made on Slide 3 of the deck. But I'll start with a solid foundation, which we really think sets the baseline for us. And we're always proud of our credit performance. We've actually outperformed on credit for a lot of years. Outperformed the industry. I think that's true in recent quarters. And I'll say even today, we can talk about credit as we get into Q&A, but feel like we're in extremely good shape right now on the credit front. And I'll just say that's not an accident that's very much by design. We do give a lot of emphasis to credit here at Comerica. We do think we have a best-in-class credit college, which not only our credit officers go through, but our future relationship managers go through also. So it's very much a part of our DNA and something that we're very proud of. In terms of foundation, I'll go to capital next. We do have very strong levels of capital. And we have found over time that a conservative approach to capital has served us very well. And then finally, liquidity. We've always valued our liquidity at Comerica. I am proud to say we actually have more liquidity today than we did a year ago at this time. And one of the really important tranches of that liquidity is our very strong noninterest-bearing balances that we have. It is expressed as a percentage of total deposits, it's really industry-leading, has been for a very long time, and we expect it to be so in the future. Now shifting to what we think is a very differentiated strategy. It starts with a very diverse and high-growth markets. That serves to not only mitigate risk, but also gives us a way to amplify growth over time. We also have a very diversified set of business units that we're very mindful not to get too concentrated in any one business unit or even any one sub business unit. And then finally, the tenure over colleagues is something we're very proud of. For example, our group managers average almost 20 years of experience that allows them to build deep industry knowledge. But even more importantly, it gives our customers a constant point of contact. And our customers tell us they value that very much. So it's something we're very proud of, and it extends to other areas of the bank. Most notably, credit also has very tenured colleagues, and it's one of the reasons why we do outperform so well in credit over the years. Now putting together both that differentiated strategy with the foundation that I talked about. You layer on to that, something we're very excited about, and that is tailwinds that we see coming over the next few years that starts with net interest income. We have a lot of maturing swaps and securities maturing over the next few years, which should be additive to higher levels of net interest income each year as we move forward. On the fee income side, we made a lot of investments in fee income, which I think Peter can talk about later, which should give us more consistent and a capital friendly way to grow income. And then finally, the health of our balance sheet. The loan-to-deposit ratio is in great shape. We think we can grow the balance sheet very responsibly from here. And we think when you add all of this together, it gives us a lot of high-performing years to look forward to. So with that, we'd be happy to answer any of your questions, Manan.

That's perfect. I'm sure we'll touch on all of those topics as we go through the Q&A. Peter, I want to bring you in here and maybe talk a little bit about the macro side of things. Inflation has been volatile, rate expectations have moved with it. What are you hearing from your clients and sentiment. And I think importantly, how has that changed over the last 3 to 4 months?

Yes, Manan, thanks. I would say when you go around the country, and I've been in just about all of our markets in the last few weeks, I mean the activity levels pretty good. Customers are performing well. When you ask them questions about how business is going, they continue to say things are really good for them. That said, there's a lot of mixed economic news coming out, obviously. I would say the last 40, 45 days has probably been a little bit more challenged than maybe even it was 60, 90 days ago. I think that as the year has gone on, the likelihood of interest rates coming down is starting to weigh on folks. It probably is delaying decisions. I continue to believe in an election year that business owners sort of wait to make decisions. And so we'll see kind of how that unfolds. But I think you put it all together, I mean, the -- when I go to the different markets, it feels like things are pretty good. The way I tend to say it is the -- they're not as good as they were a few years ago. Folks are still making good money, but they're not making great money like they probably were there for a while, but they're performing really well. And the activity level for many of them has been really good and consistent. So we'll see how that continues throughout the year. And I do think a little interest rate relief will help all of them kind of speed things up a little bit.

So what does that mean for pipelines? I think in 1Q, utilization rates moved higher, pipelines were increasing steadily -- I'm sorry, utilization rates move lower in 1Q, but pipelines were increasing. What have you seen so far in the second quarter?

Yes. So separating those 2. I think utilization continues to be pretty low. I don't think you're seeing a big uptick in utilization. Really, if you go business by business, you might see different results across our portfolio. A lot of the utilization, for example, that we see in commercial real estate is stuff that we booked a long time ago, and we brought commitments down in that space. But if you just talk kind of middle market in general or across the board, I think utilization is kind of candidly at historic lows. Now that said, I feel like our teams are doing a great job on pipeline opportunities. We're very, very focused on new client acquisition, and that's where we're fortunate to be in markets like Texas and California. We feel like we've got fantastic market share in a market like Michigan, where we really are the #1 bank in that state, and that economy is doing very well. Detroit has seen population growth for the first time in a long, long time. And so we're excited about what we see there. But in Texas and California, we just have a tremendous amount of room to run and -- and so the new to new opportunities for us continue to be really good. And so what that translates into for the rest of the year, we'll have to see. But answering your question about pipeline, I mean, we feel like it's pretty good. It's not back to kind of pre banking crisis last year, but it is definitely up from where we were a year ago.

So it sounds like a strong environment for the medium term. Jim, I want to bring you in here in the slide deck, I think you mentioned end of period loans are up about $300 million quarter-to-date. There's no change in the average loan growth guide, but you mentioned that end of period loans for the year could be on a little bit of pressure. Can you talk a little bit more about how you see loans coming through this year?

Yes. Maybe I'll defer Peter on the loan.

Yes. Yes. I would say, Manan, so probably the change a little bit of what we've seen is sort of in some of our businesses, our equity fund services businesses, dealer, entertainment, middle market California or sort of the 4 major ones where that pressure that we're talking a little bit on point to point. Now that said, across the board, we still feel like our point-to-point loan growth is going to be good. I don't know that it will maybe be what we felt like 60 days ago, but our outlook is still really positive, because of what I said. And some of the businesses where we've seen the pressure, EFS, I think fund formation has kind of started to decline there. I think some of these deploying of capital has slowed down in our dealer business. Floor plan is not necessarily produced the way we thought that it would. But part of that is our own choice around rationalization and pricing expectations there. And then in entertainment, where we've seen a little bit is just I think film production isn't quite what we thought. So those are sort of the businesses that we feel like we've adjusted. But absent that, the rest of the portfolio, we feel pretty good about point to point. As you said, average year-over-year, we don't have any changes to that. But all in all, we feel still really good about achieving point-to-point loan growth.

Got it. And is a slightly weaker outlook for point-to-point just based on the fact that rates are staying higher for longer. Is it part of your own rationalization processes. Can you talk about what's driving that?

I can't tell if the higher for interest rates higher for longer is why there's less fund formation in EFS. I don't know if that's necessarily the direct correlation or not. Again, I think some of our businesses that hire for longer is impacting loan demand. Some of it, I think there's a lot of other external factors. Again, part of the in dealer not seeing the outstandings as we bank certain brands that still have a ton of demand, and so the cars are kind of flying off a lot still in some of those verticals. So I think it's a little of both. I think higher for longer is probably part of it, but I think there's some other external factors in any one of these businesses that might be driving. And we said on one of our slides that we've seen some decreases in our private banking loan balances, that's certainly interest rate sensitivity, I think, and you see in that vertical. So it depends on business by business.

And the other side of that is, of course, the deposits. And I think as we got through the last quarter, you were already nearing pretty much 2023 deposit balances. Can you talk a little bit more about what's going on in the deposit side here?

Yes, happy to. Deposits overall at a total level continue to be a very strong story. They were relatively stable from the first quarter through the mid-quarter update that we just gave. And I think that's very notable on the core deposit side because you might recall that in the first quarter, we felt like we outperformed even our own expectations for deposits. They came through really probably in the strongest shape that I recall in the first quarter. Since then, we have been very successful in paying down a large amount of brokered deposits, and that accounted for most of the overall decline that you saw from the first quarter, paid down about $1.5 billion on average of brokered deposits. And we think that's really a good step towards curing the overall balance sheet because it puts us down at a much more manageable level, really a more modest level of brokered deposits, and it gives us capacity to pull that lever if we have to in the future. Now core deposits, as I mentioned, relatively stable, which is a good sign. We did see a decline in noninterest-bearing deposits. And conversely, we did see interest-bearing deposits really step up. And I'll talk about some of those drivers of the noninterest-bearing deposits. They were down about $800 million relative to the mid-quarter update. I will say that as we stand at the end of May, they are about $1 billion, maybe a tad more down from where we had expected in our previous guide. And so we have seen a little bit of pressure there. And as we look into where that pressure is taking place, use of funds is really the primary reason, and I'll break use of funds into a couple of different categories. The first is more legacy or traditional. Being a commercial bank, we've always had some lumpier inflows and outflows of deposits depending on what's going on with our customers' businesses. We did see a bit more outflows during the month of May. The second use of funds is probably a little bit more of a newer driver that we hadn't seen as much of in the past, and we'll have to see if it's a single data point in time or if it continues. And that is we did see more customers drawn on their deposits. And in this case, it happened to be noninterest-bearing deposits, to either pay down their loans or to -- in lieu of borrowing. So that's something we have not seen as much of in the past, and we'll wait and monitor and see if that's a trend that continues. But I do think it's a symptom of a high rate environment where customers are having to make that deliberate decision, do they bring down their deposits or do they actually borrow. Now to a much lesser extent, we did see some latent seasonality during the month of May. So we look at the specific outflows that we saw. And that's not totally unusual. We're usually mostly done with the seasonality by May. In March, it looked like we had actually gotten through it early, but we did see a little bit of that latent seasonality. And then finally, we did see a minor amount of mix shift for individual customers. But as we look at customer by customer, we really didn't see a lot of that. So that was not a primary driver. On the other hand, we have had a lot of success with bringing in interest-bearing deposits, and that would be for both new customers and existing customers, which is a good sign. In terms of where we go from here, we look out at the rest of the year, there are a couple of things to consider. I mean, certainly, the hire for longer has the propensity or the potential to put a little bit more pressure on. On the other hand, one month is not necessarily a trend. So it's something we're going to have to monitor. I will say that as many of you know, we often get seasonal deposits, both total deposits as well as noninterest bearing in the second half of the year. So I think we have some potential tailwinds there. And I look at overall just nominal growth in the economy, including inflation. And that should ultimately translate into higher working capital requirements for our commercial customers and that typically comes with higher noninterest-bearing deposits. So we'll monitor this. You do have different forces going in different directions between now and the end of the year. You saw in the guide that we are sticking with our overall deposit guide. Our pipeline for interest-bearing deposits is probably the strongest that we have ever seen, a very healthy pipeline, and this would be both existing customers, bringing new deposits in as well as new customers. So we are quite bullish on our interest-bearing deposits. On the noninterest-bearing side, again, we have different variables going in different directions. So we'll see where it nets out, but we think it will be largely stable but it's something we'll have to continue to monitor. There's probably a larger big picture point that I want to make for the audience, and that is we are in this hire for longer. And we're probably at the absolute apex of this interest rate cycle. And so if there's a point in the cycle where you would expect the most extreme pressure on noninterest-bearing deposits, you're kind of seeing it right now, I think, and that's perhaps what we're seeing a little bit of. We all know that rate cuts are projected to supposedly come later this year. And throughout our history, as we get rate cuts, Comerica typically gets more than insured deposits, including noninterest-bearing deposits. And conversely, when rates are higher for longer, we tend to get a little bit more pressure. So this is not altogether surprising, and I wouldn't want anyone to overreact to a single month or a very short period of time. We think the overall business model would suggest that -- the fact that we have such a great base of noninterest-bearing deposits, you take some of this pressure with the good that is being industry-leading in noninterest-bearing deposits. And by the way, even after this pressure, we expect to be pure leading on that ratio. So it is a little bit of a moment in time. We are a little bit at the peak of the cycle here in terms of that pressure, but we see good days ahead with our noninterest-bearing deposits and really do think it's more of a passing moment.

Got it. And you mentioned rising pay rates is a key risk at one point. Can you just talk a little bit more about what you're seeing there?

Yes, I see pay rates is a good story. As we go through the month of May and probably through the month of June, I think what we're going to see is deposit pay rates in total have taken a step backwards. I think our cumulative beta that we published in the second quarter has a good chance of being slightly lower than it had been in the first quarter. And I will say that's largely driven by lower levels of broker deposits. I think that's important to differentiate to be totally transparent. But even on core deposits, when you exclude the impact of brokered deposits, they continue to be very well controlled. We actually saw no increase, in fact, maybe a slight decrease in February and March. We did see a little bit of a tick up in April and May, more so in May, but nothing material. And so I think what you'll see is the overall pay rates, even if you exclude the brokered deposits continue to come down materially, and that has really flattened out. So I would consider them to be very controlled and you're going to have some onesie-twosies here and there where customers ask for an exception rate, but nothing that's going to move down a lot.

And the further way we move from rate hikes, I think the less pressure there is on those pay rates and they can come down for us?

I think so. We see that month-to-month and quarter-to-quarter. It just continues to flatten out and I think many of the customers that we're going to ask for an exception rate or pressures for higher rates. We've kind of moved past that at this point. There's probably a little bit of fatigue setting in on both the bank side and the customer side. Some of the optics of these higher rates are to wear off at some point. It's not quite the shock and awe that it was maybe 6 months ago or a year ago. So I think pay rates overall look very controlled to me and they continue to slow up and shouldn't be a major factor going forward.

Got it. And then maybe you can bring it back to NII. I know you mentioned in the slide deck that this entire mix shift in NIB could put some pressure on the NII guide. Can you talk a little bit more about that?

Yes. I've said for some time now that noninterest-bearing deposits are really the big X factor when it comes to net interest income for Comerica. And so I do think it's going to pressure the previous guide. I would expect second quarter to come in about 1% lower than what we had in the previous guidance. We'll wait and see how the month of June goes, because noninterest-bearing can be a little volatile. And for the full year, likely to be up to or at 2% in terms of lower than the previous guidance that we had on a full year to full year basis. Now again that's something we'll have to continue to monitor. But at this point in time, that's really our base case.

So just to clarify that, I think your prior guide was for NII to be down 1% in the second quarter. So your stake in the range of about down 2%. And then for the full year, the product guide was down 11%. Now you're saying about down 13%. Is that correct?

That's right. That's right. And I think we had some BSBY exclusions factor into that prior guidance that I would point where it went back to.

All right. Perfect. That's great. And then let's talk about the interest rate sensitivity. I think you've mentioned before as well that you're fairly neutral on your interest rate sensitivity. Is the biggest driver for NII in the back half? Is that basically loan growth? Or is there also some swaps and securities run off? And can you talk about the dynamics of all of those?

Yes. A number of tailwinds coming up in the second half of the year and some of these tailwinds become much more significant even next year and the years following. But I would say for the second half of this year, the biggest factor, if I quantify it out, is probably the swaps and securities maturing and the tailwind that we pick up from that. I would say the loan demand that Peter is generating and the banks generating would be kind of a close second. We obviously have a little bit of liability sensitivity that could contribute a minor amount, but I wouldn't want to overplay that given how late in the year we make it some of these rate cuts. And of course, there will be some technical factors like days in the quarter and so on to a lesser extent. But I think the swaps and securities are really going to be the larger story, and they'll continue to be a great tailwind, not just for the second half of this year, but I think in future years also. So a lot of great income to look forward to there.

So as you think about the NII number, do you see kind of like bottoming in the second quarter and then rising from there? Or how do you think about the trajectory of NII?

Yes. We previously said trough in the second quarter, and that's still our base case. We'll wait and see again how the noninterest-bearings perform. But certainly relative to my previous comments, the second quarter is still expected to be the trough.

All right. Perfect. And then as you think about the swaps and securities roll off beyond 2024, can you help us size what kind of benefit do you expect in 2025.

Yes, 2025, there will be a little variability because it depends on what happens with the rate curve and how the liability sensitivity factors might offset some of the pickup from maturities, the swaps and securities if rates do go lower. But our base case right now is that we will be all things equal, about $100 million higher in 2024 -- or 2025 compared to 2024, just from the maturing swaps and securities alone and we'll continue to have additional pickup in the years following, too. So I do think there's a lot to look forward to as we continue to build up our net interest income.

All right. Perfect. And then maybe I want to dig in a little bit more on regulation and some of the regulatory factors there. But Jim, I think one of the questions we got was that many of the larger banks and your peers have been added to the standing repo facilities counterparty list. You guys have chosen not to participate. Can you talk a little bit more about why that is?

Yes. I think some of those banks that talked about that just recently entered the program. It takes several months to actually set up the infrastructure for that program. So we've actually been working on that, and we expect to be in before the end of the year. So we're working on this in parallel, just like many of our peers have been. I think some of the other banks maybe jumped on a little bit sooner because we have no hold to maturity in our portfolio. And the regulators have been giving some hints that to the extent you have hold to maturity, and you want to be able to prove that as liquidity. It helps to have that reverse repo. The rules are likely to be friendly in that regard. So again, we have such a clean portfolio in terms of keeping everything from AFS. We didn't feel quite the same time pressure to jump on it, but there are other advantages in terms of overall collateral value. So it is something we're moving on and have been, and we expect to be on it before the end of the year.

All right. Perfect. And then I want to talk about capital. You mentioned it in your opening remarks as well. You're well above the [indiscernible] at 11.5%, which kind of makes sense right now given the volatility around AOCI. But as we think about the medium term, how do you think about deploying all of this capital and what capital levels do you think you can run at in the medium term?

Yes. Our first priority, of course, is always to use our capital for our customers. And as Peter mentioned, we are somewhat bullish on loan growth. And hopefully, that goes even beyond 2024. So that will certainly be where we place the capital first. Beyond that, I do think it's important we look at capital from a number of different angles. And certainly, we're very cognitive of the fact that Category 4 rules could include the AOCI. And so our eyes very much on making sure that we can comply with those rules by the time the final phase-in was in relative to the maturity and burn off of our AOCI. We feel like we're in very good shape there. But we are cognizant of the fact that we've seen interest curve shift up and down a couple of times each direction, it feels like in the last 9 months or so. And so we want to be a little cautious there and make sure we don't see some type of permanent shift up that can create an AOCI challenge for us. So that's the reason we're being cautious on capital. We still have our official target of CET1 of 10%, and we'd want to achieve that target even if AOCI gets pulled into the calculation, and again, we don't think we'll have any problem achieving that we'll be comfortably at that level or above for the final phase in. I just want to make sure interest rates don't throw us a curve ball there. And of course, getting some finality on the Basel III end game rules would be very helpful also. But overall, we have not changed our target of CET1 of 10%, but we are looking at it from a number of angles, not the least of which is the Basel III end game rules. And then we do continue to be cognitive of the fact that the rating agencies measure capital in their own different ways and include AOCI in different portions there. So trying to triangulate all the different constituents out there. But as I mentioned in my opening remarks, we've found over that a conservative approach there has served us very well, and I want to make sure we're in very good standing there.

And also from the outside, it feels like listening to the speeches of Michael [indiscernible] and what the regulators have been saying. It feels like the bar for regulation has been increasing for banks of your size, whether it's capital or its liquidity or is there anything else. How does that impact how you manage your business on a day-to-day perspective?

Well, we are cognitive of those demands and some of them are more formal. Some are more informal as we maybe approach Category 4. We feel really good about our strategy. So first and foremost, we're not trying to navigate around what could be regulatory rules that have some degree of finality or not finality to them. We know that the net regulator rules can be a little bit fickle with political administrations. And we don't want to make a misstep trying to overreact to any one environment. So we are sticking to our strategy. We don't want to suppress growth just for the sake of staying under $100 billion. We don't want to have very responsible high growth just because we think we need to be much higher than $100 billion. And I think in terms of some of the components of the regulation, whether it be capital or liquidity or the minimum debt requirements, we feel like we're in very good shape there and have proven we have the capacity to step up there. Having said all that, there is this also just general, as I've talked about many times, is general rising risk framework bar that the regulators have set, and that's something that we're very focused on, and we feel like we're meeting it, but it's something that has not stopped going up. So we do continue to invest there and stay very cognitive of the overall risk framework environment.

And while we are on that topic, a few weeks ago, there was an OCC action announced on your small cross subsidiary. I know there was some initial confusion around the trust subsidiary and the bank. And can you help clarify some of that?

Yes. Thanks, Manan we love the opportunity to clarify that. First and foremost, very important to say, we are very dedicated to resolving this issue in a way that's very satisfactory to the OCC. Having said that it's really important to understand what this is not. So this does not apply to Comerica in its entirety. It is not applied to the larger Comerica Bank. It applies to Comerica Bank & Trust, which is an important but very small percentage of our overall revenue. And so it is something that we're focused on resolving, but there should be no confusion about the fact this is not the larger bank. This is the smaller Comerica Bank & Trust entity.

Is there a risk that this issue bleeds into the bank?

Well, we never talk about specific regulatory issues, but I will say that it's important to keep in mind, we have a different regulator for Comerica Bank & Trust than we do for Comerica Bank. And different regulators have different points of emphasis, whether it be formal or informal. And so the fact that there is that division there, you can draw your own conclusions. Now having said that, not necessarily tied to this OCC issue. Again, there is that rising bar for risk framework, and I think all regulators are focused on that. And so I think every bank out there in the industry is focused on risk framework. And certainly, our larger bank is focused on that also.

And the other question I got after the headlines a few weeks ago was -- is there a cost to remediate the actions outlined in the agreement? And does that pressure any of the guidance you've provided on expenses?

Yes, there is an impact there. Keeping in mind, some of the investment that we have to do, first of all, if you read the letter of agreement, there is a general increase in overall controls and again, risk framework that we need to make for that Comerica Bank & Trust entity. Another point of emphasis in the letter was, as you can imagine, running a Comerica Bank and the Comerica Bank & Trust, there are certain formalities that we've operated with as a company for many, many, many years, where maybe the lines became blurred between those 2 entities. And the OCC would like to see a little bit more separation between the 2 and let Comerica Bank & Trust stand more on its own. And so there will be some governance changes there that could result in a modest amount of expenses. And then also from a risk framework and just overall risk standpoint, we do want to make some investments in our trust systems. And Comerica Bank & Trust is largely a third-party provider to other brokerage firms out there, broker-dealers. But we do have some trust customers in the bank also. And so we do want to make some investments in that trust system, which would probably benefit both Comerica Bank & Trust and Comerica Bank. When we add all that together, we probably are looking at another 1% of expense growth this year for total Comerica relative to previous guidance. So that previous guidance had been, as you know, 3% up year-over-year. So that would result in a 4% guidance number.

And you've had some success in offsetting some of these investments over the years through branch and headcount reduction. Is that something you can continue to do from here?

I always say that expense reduction and efficiency is a journey, not a destination. We very much feel that way today. We are very committed to getting down to a very competitive efficiency ratio. That starts with positive operating leverage going forward each year. So that's something we're focused on for 2025. Certainly, expenses will be a very large piece of that. So we continue to work on opportunities to be more efficient at Comerica. Certainly, revenue is going to be a big piece of it also. And again, we have these very significant tailwinds that I talked about earlier that I think will also contribute to a better efficiency ratio. But it really takes work on both sides of the ledger. We need to keep working on expenses and efficiencies, and there are short-term things we can do there. But more importantly, there are longer-term things we can do just from an overall infrastructure standpoint. But again, the revenue piece will be very important also. So you have to work on it from both ends, and that's something we're very committed to doing.

All right. Perfect. And while we're on this topic of investments, Peter, I want to bring you in. You've spoken about making strategic investments in payments, capital markets, wealth. How do you see this evolving into your revenues and returns over time? And what are your goals with respect to these investments?

Yes. Thanks, Manan. So yes, I think payments, wealth management, capital markets, those are our 3 main noninterest income drivers. And each of those, payments is one. We've got new leadership in that business. We're hiring new product people. We're making investments in technology. As a leading bank for business, we think we can be the leading payments bank for businesses across the country. And so we're very, very focused on that, and we've changed the way we support our loan teams with treasury management salespeople and I feel like we've got a great opportunity to grow noninterest income and payments. Wealth Management. We are a full-service wealth management bank. As Jim alluded, we've got a great trust business. We've got great private banking offering. Comerica Financial Advisors is our brokerage business that we have in the market. So we feel like we can continue to add teams. We've added teams in Southern California. We've got more to do in Texas, the Southeast. So -- that continues to be a great opportunity for us. And then capital markets is one where we feel like we play above our weight in that business. We're great at leading syndicated deals. We've got great FX, energy trading, and we added our M&A folks about a year ago, and they're starting to get some traction, and so we're encouraged about that outlook. So those 3 together, I mean, growing noninterest income is terribly important for us, and it's something we're really, really focused on. That's where you're going to see us continue to lead in.

All right, perfect. I have a couple of questions in the Direct Express program, and then I'm just going to see if there's any questions in the room. The Direct Express program has been a successful generator of NIB for a number of years. The contract expires in 2025. You've won the bid 3x before, but can you provide us an update on the status of that rebid process?

Yes. So we're in the middle of that bid right now. And hopefully, we will sort of find out in the next quarter maybe whether or not we've won it again. I would tell you that, we're very proud of how we've managed that program, and it is a large program that we do for the fiscal service and are very, very proud of the customers that we support in that space and we've put everything we can forward to try to win the bid again. If that didn't work out, then we're prepared for that direction as well. And we believe that, that would be an overtime type migration where it not to stay with us. But regardless, we feel encouraged about our ability to navigate it one way or another. So it's certainly an important part of the bank. It's something we would love to retain and keep doing, but it's not something that, over time, we're worried that we would be able to navigate without those deposits. And I think Jim alluding to what he did earlier on deposit growth, we've got other avenues to grow deposits besides just that business.

So can you dig in a little bit on that? What is the worst case scenario if you did not win the business? What happens to that $3 billion? I think you mentioned that it comes out over time, it's not immediate. What are the offsets that you might consider...

Yes, there could be a few ways that, that plays out. It could be that we retain what we have and another player takes on new cardholders on a go-forward basis. It could be a migration over a period of time. It's going to be a large migration that would take at least we think, a few years for that to occur. But regardless, our focus continues to be on growing our small business deposit base. We feel like that's a great opportunity for us. And some of our other businesses that we have that we can grow business. Direct Express is one of the government business, but we do state bin sponsorships as well where we provide support to state programs, which is something that we're viewing that we could continue to grow regardless of kind of what happens with Direct Express. That's where we feel like there's opportunities to continue to grow the deposit base absent Direct Express.

Right. Very helpful. Are there any questions in the room? And if not, maybe I'll just wrap up -- oh, there is.

Jim, I just wanted to ask on the swap comment and securities comment you made. Was that using the forward curve?

Yes. Thanks for clarifying that. No, that was rates -- the starting point for that is rates as they stand today. However, if we do insert the forward curve, while you might give up a little bit on the maturing side, you probably more than gain that much back. The fact that we're liability sensitive and the overall rest of the balance sheet will respond in a positive way. So short answer is, I think, one way or another. We get at least that $100 million, if not more.

Right. With that, we're out of time. We'll end it there. Thanks so much for your time, Jim and Peter.

Thank you.

Thank you.