JPMorgan Chase & Co. (JPM) Earnings Call Transcript & Summary

February 25, 2021

New York Stock Exchange US Financials Banks conference_presentation 39 min

Earnings Call Speaker Segments

Susan Katzke

analyst
#1

Good morning. I'm Susan Katzke. I cover the large-cap banks at Crédit Suisse. Next up for the bank's, I'm very pleased to be joined by JPMorgan Chase CFO, Jen Piepszak. It's been a while since we've had the privilege of hosting JPMorgan at this conference, and we're happy now to conflict with Investor Day this year and have you back on the agenda. So we're going to do a fireside chat this morning with a lot to cover. So we're going to get started. If there are questions from investors, please don't hesitate to e-mail me, and we will do our best posting along the way.

Susan Katzke

analyst
#2

So let's get started, Jen. And maybe we can start with your latest thinking about the macro environment. What's your take on the current state of the economy and your expectations on the path to recovery?

Jennifer Piepszak

executive
#3

Sure. Sure. Before I get started, I'll just say thank you, Susan, for the warm welcome. And I, too, am excited that this is not conflicting with Investor Day and can be here with you. So on the macro environment, I mean, portions of the economy are really very, very strong. And weakness is, at this point, concentrated in the service related COVID sectors. And GDP growth is now forecasted to be above 4Q '19 by mid-year, unemployment continues to recover. We just got a healthy year number this morning on jobless claims. But obviously, still are ways to go there and unemployment is recovering at a slower pace than later in 2020. The vaccine news has been positive, virus data improving. Just looking at consumer balance sheets, I mean, on average, quite healthy. I mean in the month of January, we saw savings rates increase yet again, while payment rates in our card portfolio improved yet again, and that was also across income bands. Retail sales, very strong. And in particular, we saw retail sales even in discretionary be very strong, all while consumer balance sheets are improving. So I mean, having said all that, obviously, we're not out of the woods just yet on the virus and sentiment indicators have been on balance improving, but still somewhat mixed. The recovery remains K shaped. We still have nearly 10 million fewer jobs than we had pre-COVID. And so net-net, optimistic, but with some caution and a lot more work ahead.

Susan Katzke

analyst
#4

Okay. And so when we think about the pace of vaccine distribution and next round stimulus, how does that factor into your thinking?

Jennifer Piepszak

executive
#5

So specifically, we're thinking about a stimulus between 1.5 trillion and 1.9 trillion to be passed later this quarter and then the vaccine being broadly available come summer. And honestly, 1 thing and their inflation has been getting a lot of talk these days. It is something that, as we think about the level of support that's out there and the possibility for an incredibly strong recovery in the second half of this year, that's the risk we're starting to really think about.

Susan Katzke

analyst
#6

Okay. So you talked about the health of the consumer a little bit. And I know you've got very unique and timely data within the bank on activity, consumer activity, in particular. So what are you seeing of late in terms of consumer spending?

Jennifer Piepszak

executive
#7

So on consumer spending, I mean, we've been talking about it across credit and debit. And I think because of the mix of consumer spending, it's important to look at it in aggregate. And the beginning of this year looks a lot like the end of last year, which is, I would say, flattish as we look at the year-over-year comparisons. Debit up because every day spend is up and credit still down as T&E is still down. Of course, we're now heading into the month of March, which will be an easier compare year-over-year given the falloff in 2020. So as we think about the first quarter, it feels like consumer spending across credit and debit for us, up single digits. I would say importantly, what we've seen recently is we are starting to see an improvement in T&E spend. And so time will tell if this is an inflection point, but it is reason to be optimistic given what we've seen over the last few weeks. Still obviously down considerably but starting to improve.

Susan Katzke

analyst
#8

Okay. So let's switch gears to loan growth a little bit. And are you seeing any signs of a pickup in loan demand? And if so, kind of as you think about how loan demand might progress throughout this year? Where there's the best chance for some loan growth and what you kind of assume to feel confident that the loan growth comes back?

Jennifer Piepszak

executive
#9

Yes. So on the wholesale side, loan growth remains tepid given the amount of support that is there in the capital markets. AWM is a bright spot. We saw loan growth -- strong loan growth there even in 2020, but we continue to see that. So I would say that's a bright spot. And then as we look at consumer, starting with Card, we obviously need to see spend continue to recover. And as I mentioned earlier, we are seeing payment rates looking even stronger than we thought they would be when we last spoke at earnings. So we expect that will normalize. So spend will continue to recover, payment rates will normalize, and we should start to see loan growth in Card later this year. And then in-Home Lending, Home Lending is obviously not only a function of activity but a function of prepays as well. And every loan that we originate, of course, we put through our best execution approach, which given the level of demand right now on mortgage-backed securities in the market, it's difficult for our portfolio actually to compete with the market bid for the loans that we're originating. So volumes are still quite strong, but it is true that most are getting securitized. And so we're not seeing that loan growth on our balance sheet despite the strong volumes.

Susan Katzke

analyst
#10

Okay. So let's take a quick detour, if you don't mind, and discuss the wholesale side of loan growth a little bit more. As I think about it, following the year really unprecedented capital markets issuance activity. And at the same time, the anemic bank loan growth. Do you think we've seen a permanent shift to even more corporate borrowing done via the capital markets? And maybe put it also in the context, not just at the capital markets, but when you think about the economics of DCM versus C&I lending in a world where we have CECL, we have G-SIB, we have the SCP, all working against those economics.

Jennifer Piepszak

executive
#11

Right. So I'll come -- I'll start with the economics and then come back to them. So I mean, we don't think about the economics between DCM and bank lending because we're there for our clients, and we're going to do what we think is in their best interests. So we don't necessarily think about that in this context, but it is a good point I'll come back to. It is true, of course, that it is a longer-term trend that we've been seeing as capital markets generally, globally have become wider and deeper. And -- but 2020 was actually interesting because, first, what we saw was corporates draw on revolvers. And then in the second quarter, later in the second, third quarter, access capital markets to repay the revolvers and shore up additional liquidity. So 2020 felt like not only were banks there for clients when the capital markets weren't open, but there is a place in the capital structure for both, loans offer prepayable debt but -- at a floating rate. Typically, bonds have call protection but offer fixed coupons. So there is room for both in the capital structure. And as I said, we're going to do what's in the best interests of our clients, and we're obviously there in both bank lending as well as in capital markets. But just to come back to the point on G-SIB and SCP because it is a good one, just more broadly, not necessarily when we think about corporates. But more broadly, it is evidence that the nonbank lending sector has grown, obviously, significantly, and that is no doubt in part to the increasing cost of capital in the banking sector.

Susan Katzke

analyst
#12

Okay. So let's shift gears a little bit to some of the updated 10-K guidance. You filed your 10-K 2 days ago, I think, and it include a couple of updates to your guidance. So I want to ask you about some of these items in more detail. But before we go there, maybe give us the bigger picture between revenue and expenses, if you will?

Jennifer Piepszak

executive
#13

Okay. Sure. So bigger picture, just on NII, that is because of lower balances that we're seeing in Card and Home Lending, and that has a positive offset in credit. So the -- just giving the NII guidance, of course, doesn't tell the whole story. So there is a positive offset there. And it is also true that we did not change the guidance for the exit rate in terms of NII for 2021. So while we got it down, it's temporary, and it is because of healthier metrics we're actually seeing on the consumer side in terms of balances. And then on expenses, it was really twofold. One was we had an opportunity to donate some equity shares to the foundation in a tax-efficient way that had the effects of accelerating donation or donation into the foundation. So that was a onetime item that you'll see this quarter. And then revenue-related expense, which, of course, has a positive offset in revenue.

Susan Katzke

analyst
#14

Well, we'll take those expenses any day of the week. On the NII, in particular, with the guide from 55.5 down to 55 in the endpoint, the same. What are your assumptions for interest rates and balance sheet growth and mix? Just I'm going to that.

Jennifer Piepszak

executive
#15

So there, we always use the latest infights. So that guidance was based on the latest infights, and we will update that each time that we talk to you based on what we're seeing. So of course, there was tailwinds from a steeper yield curve that we've experienced over the last several weeks. But without loan growth, of course, that has a positive impact in the securities portfolio, but it's difficult to fully realize the benefit of that steeper yield curve with that loan growth. So that was more than offset by, as I said, lower balances in Card and Home Lending. So -- but again, we expect those to normalize throughout the course of the year.

Susan Katzke

analyst
#16

Okay. And just as a point of clarification. Because you do generate a significant amount of net interest revenue in the trading businesses. So how is the impact of trading related NII and its contribution factor into the guidance? Is it more closely tied to activity to short-term interest rates? What's the driver here?

Jennifer Piepszak

executive
#17

Sure. So the way you can think about markets NII is that over time, it will be more closely related to activity. In particular, our financing business. So it should grow over time with activity growing in our financing businesses. But in any shorter period of time, it's going to be more sensitive to the overall level of rates, short interest rates, as you say. Because the business is typically long securities that we hedge with derivatives. So when you have rates move down, you have a funding benefit against the securities, which is recognized in markets related NII. But that, of course, that duration is hedged in derivative form. And so the offset to that is on the derivative, which is recognized in noninterest revenue.

Susan Katzke

analyst
#18

Okay. Fair enough. So let's stick with trading for a minute and market-related activity overall. And relative to really record levels of markets revenue and IBCs in 2020. You would think that the comparisons for 2021 could be a little bit challenging. But I think the question remains, how much normalization we actually see this year. So let's start maybe with an update on trading and investment banking activity first quarter to date?

Jennifer Piepszak

executive
#19

Sure. So we gave an update on IBCs in the K, expect them to be flat relative to the fourth quarter. There, we continue to see a lot of strength in ECM. So that's, I would say, the biggest driver. So think about IBCs flat year -- not year-over-year, quarter-over-quarter. And then markets revenue, we are off to a very strong start here in quarter-to-date. So were up meaningfully quarter-to-date, but we are headed into -- unlike card spending, we're heading into a much more challenging year-over-year compare in the month of March. And so I don't want to extrapolate our performance quarter-to-date to the full quarter because the compares for the month of March are going to be a lot tougher. But having said that, we're off to a strong start and up meaningfully quarter-to-date in markets.

Susan Katzke

analyst
#20

Okay. And just for clarification, you're flat against the fourth quarter, but you had a very strong fourth quarter for investment banking fees.

Jennifer Piepszak

executive
#21

Which is, therefore, up meaningfully, I think it's 30-something percent year-over-year, that would imply. Yes, yes. And the market's performance is year-over-year when I say up meaningfully quarter-to-date.

Susan Katzke

analyst
#22

Okay. Equal between fixed income and equities or equity is a little bit stronger?

Jennifer Piepszak

executive
#23

Equity is a little bit stronger just in terms of the compare.

Susan Katzke

analyst
#24

Okay. Okay. So can we talk a little bit about some of the secular shifts that are at play here working against this consensus fuel normalization to 2019 levels. And maybe where you're seeing growth of the revenue pools in the market's businesses?

Jennifer Piepszak

executive
#25

So I mean, in terms of secular shifts, as we think about markets revenue, we've probably seen the wallet's bottom out as changes in market structure have largely run their course. So over the long-term, while it should generally grow in line with GDP and/or financial assets. But of course, in any shorter period, markets are unpredictable.

Susan Katzke

analyst
#26

Okay. Okay. So let's talk about longer growth opportunities. And the decision, which is pretty consistent for JPMorgan, then you'll double down on investment spend. And I think this year, the number is an increase from $10 billion last year to $12.5 billion in -- or approximately, $12.5 billion in 2021. Can you talk about some of the most material growth opportunities across the company, where that money is going?

Jennifer Piepszak

executive
#27

Sure. So our growth opportunities are largely consistent with the themes that we've been talking about for a number of years now. Market expansion here in the U.S. has been so far an enormous success. And perhaps we don't talk enough about the benefit of market expansion across the company. The commercial bank benefits every time we enter a new state by opening up 1 branch in a new state that opens up opportunity for state and local business that we couldn't have earned before having a branch in the state. And then the private bank also benefits considerably when we open up new branches in new states. So as we've said, we expect to be in the lower 48 -- all lower 48 soon, and we're super excited about that. Wealth Management, another area that we've been talking about in terms of just being a huge opportunity for us. We bank 50% of households between $1 million and $10 million in net worth, but only 5% of them invest with us. So Wealth Management just continues to be an opportunity for us given that we're relatively underpenetrated there. On payments. Wholesale payments continues to be an opportunity as well, consumer payments. And there, I would just add travel. We just acquired cxLoyalty in the fourth quarter. And so that might not be an area that would be intuitive to think about for us, but that's also an exciting area of opportunity. The Commercial Bank international expansion. There, of course, we're leveraging the existing rails of the Corporate & Investment Bank to build out that expansion in a very efficient way. And then in the Corporate & Investment Bank, you can double-click on sectors, products, geographies, and there remains opportunity for us. And then, of course, China, which is a long game, but an opportunity for us across the wholesale franchise.

Susan Katzke

analyst
#28

And just to be clear, in terms of this decision to step up, so materially the pace of investment spend this year. We all know what Jamie's philosophy is on this. But timing-wise, is it a function of a changing competitive landscape or changing consumer behavior, a healthier macro? What's driving that?

Jennifer Piepszak

executive
#29

Yes. It's probably a little of all of that, I would say. I mean when you look at the year-over-year from '20 to '21, some of it is just normalization. So marketing investments, front-office hiring, things that were naturally slowed down during COVID in 2020. Some of it opportunistic. So acquiring cxLoyalty. Obviously, they come with a run rate of expenses, which is new in 2021. And then you have some investments just ramping up. So market expansion is a perfect example of that. We opened about 87 branches in 2020. I think we'll open about 150 in 2021, so that's ramping up. Of course, that will eventually ramp back down. The path forward to the $30 billion commitment that we made to racial equality that comes with expenses. And then in technology, so customer client-facing capabilities as well as infrastructure modernization. I mean, we are acutely aware, perhaps even more so than a year ago of that -- of the need to move fast and innovate quickly, and we need more modern infrastructure to be able to do that. So that's a part of it as well.

Susan Katzke

analyst
#30

Okay. So let's switch gears a little bit to M&A. And you've obviously been very vocal about M&A since really long before the pandemic. But has the development of your balance sheet over the last 12 months or so, whether with regards to the amount of excess capital above the 12% CET1 target that you're carrying, the distribution limitations or leverage becoming more binding. Does it change the way you think about M&A, including really your areas of focus or interest as well?

Jennifer Piepszak

executive
#31

So it doesn't fundamentally change the way we think about M&A, although it was interesting with the distribution restrictions that we were able to buy someone else's stock but not our own stock. But that was just a quirkiness of the limitation. So -- and it's also -- yes, we have excess capital. That is true. Except for -- remember, we generate an enormous amount of capital in any given quarter. And so the fact that we actually have excess capital right now, I wouldn't say, is driving a change in our thinking. I think what it is, is perhaps a greater sense of urgency. There are businesses like Asset Management, where scale matters even more than it did a year ago. And then other businesses, like I said, where the need to move quickly and to innovate quickly to keep up with competition is certainly accelerating. And so it is possible that the changes that we know we need to be perhaps more aggressive about how we think about buy versus build because of the need to move quickly. But it's all innovation and customer-related and market related, not necessarily because of the change in our balance sheet.

Susan Katzke

analyst
#32

Okay. And we're going to get to a discussion of the balance sheet in a minute. But let's detrek to credit now, if you would. And at the end of the fourth quarter, I think I know you took -- me by surprise with the magnitude of the loan loss reserve release and it was about $3 billion, $2 billion in wholesale, $1 billion in Home Lending. But you were a little bit cautious at that point in time on credit card. Can you give us an update on what you're seeing across the wholesale consumer portfolios?

Jennifer Piepszak

executive
#33

Sure. So I would say things are certainly more positive than we even would have thought at fourth quarter earnings. Looking at C&I, I would say, broadly stable to improving downgrades there. As you know, peaked in the second quarter of 2020 and have been coming down steadily since then. CRE, commercial real estate, that's, of course, an area that we're watching closely. Everyone is watching closely. But rents have held up. The book is well structured. It's primarily investment grade. We run a significant stress analysis on that portfolio all the time and feel good about our ability to manage that. And then on the consumer side, Card, it's really interesting. I mean what you would typically see in Card is a seasonal uptick in delinquencies in the first quarter relative to the fourth quarter. And what we're seeing right now is actually the opposite. We're seeing delinquencies improve year in the first quarter relative to the fourth quarter. And then Home Lending with HPI continuing to improve low rates, that's very supportive of the credit environment there as well.

Susan Katzke

analyst
#34

So how does this then impact the trajectory of net charge-offs and reserve release?

Jennifer Piepszak

executive
#35

Right. So on net charge-offs, I would say -- well, first of all, wholesale is a bit more episodic given what we are looking at right now. We don't see significant meaningful increases on the wholesale side but it's episodic. So always more difficult to forecast. On the consumer side, it's a bit more straightforward to forecast the near-term because, of course, you fill up the delinquency buckets before you actually realize the charge-offs. And so we're just not seeing that. And so on the consumer side, it's perhaps more straightforward to say that we don't anticipate a meaningful uptick in charge-offs this year. And then as it relates to reserves, we are just starting our process for the first quarter. There's a lot of time to go and a lot of work to do, so things could change. But as I said, things do look better than we even thought at the fourth quarter when we had a reserve release then. So more work to do, but things look better than we thought, trending positive, I would say, on reserves.

Susan Katzke

analyst
#36

Well, we like that trend. So if you think about the credit experience over the course of the last year, over the course of the crisis, is it indicative of how banks risk profile has permanently changed as a result of really post-crisis -- post-financial crisis, regulation and then kind of government and fiscal support in here. Is your risk profile changing? How we put this in perspective over the course of the last decade?

Jennifer Piepszak

executive
#37

Well, I think it is certainly true that what we saw in 2020 was a banking system that looked much healthier than, of course, in the great financial crisis. And so increased capital, increased liquidity, resolution planning, all of those things clearly worked as we came into this crisis. And so I think it is indicative of a permanently changed and healthier capital structure for the banks. But I think also many of the banks, I certainly know, it is true for us. The overall portfolio, credit quality of our portfolios were stronger coming into this crisis as well.

Susan Katzke

analyst
#38

Okay. So when we think about the other side of this crisis and where the allowance coverage ratios go at the end of this cycle relative to where they were on CECL day 1. How are you thinking about that today?

Jennifer Piepszak

executive
#39

Yes. It's -- well, it's a bit easier to talk about where we should land. It's harder to talk about the path to get there. So if we go back to CECL day 1, which was only a little more than a year ago, but certainly feels a lot longer ago than that. It was still a very benign credit environment. I mean we knew that we were still over-earning on credit. And so you would think -- and even in our credit portfolio -- credit card portfolio, we were still seasoning on some vintages where we had expanded the credit box. And so even then we thought we were at an allowance coverage ratio that was possibly lower than where you would land in a more normal environment. So I do think, eventually, we should get back to a place where a more normal environment is higher than where we were on CECL day 1. But of course, the path to get there at this point is unclear. We could end up in a healthier place before we get back to what feels more normal. It's unclear.

Susan Katzke

analyst
#40

Okay. So let's switch gears again. Now we're going to talk about Capital Management, the context of G-SIB and CCAR. And let's talk about the challenge of holding JPMorgan CET1 target at the 12% level. And maybe we start with G-SIB surcharge management in the current environment with deposit flows really still quite strong. Let's discuss what you can actually manage at JPMorgan and maybe touch on whether or not there's any constructive discussion around G-SIB surcharge recalibration?

Jennifer Piepszak

executive
#41

Okay. Sure. So I'll talk about G-SIB. But I'll just start by saying that the overall 12% there, of course, it's possible that there are puts and takes in that number. So we'll talk about G-SIB, but of course, it's possible that there could be an offset in SCB. But on G-SIB given the enormous expansion of the system that we saw in 2020, we do expect to be in the 4% bucket as we end even 2021 without recalibration. And given the size of the system and the fact that the system is going to continue to expand here in 2021. It would be very, very difficult for us to get back to 3.5% without recalibration. So we do expect to be in the 4% bucket. I would say whatever we need to do to even manage to stay in the 4% bucket we'll be very thoughtful about. And we have time to think through that, of course, because remember, even as we end at 4% at the end of 2020, that's not effective, of course, until the first quarter of 2023. And then if we end 2021, even in a higher bucket, that then puts you out yet another year, which then gives some time for that recalibration, which we, at this point, expect to be part of the Basel III end game. That is the latest that we're hearing from the Fed that all of this would be considered in 1 package as part of the Basel III end game. So we remain hopeful that comments that have been made through time about the level of capital in the system being about right will be reflected in what we see in the Basel III end game, and we'll get that much needed and long overdue recalibration on G-SIB.

Susan Katzke

analyst
#42

We want to ask you how you really feel about that, I think here. And that's a fairly optimistic outlook with respect to recalibration. In the very near-term, I know that the growth in the balance sheet would roll in several years out, so this may not be an issue. But you uphold at the 4% level, will you take more aggressive action in the near-term vis-à-vis deposits?

Jennifer Piepszak

executive
#43

Well, I mean, we had -- as it relates to deposits, and as I said, we do expect deposit growth to continue in 2021 given the Fed balance sheet expansion. We will be thoughtful, but we'll have not only the G-SIB impact, but the SLR impact, which we can talk about in more detail. But we may -- it's a little bit different for G-SIB than it is for SLR. But we may have to do things like issued preferreds, and pass that cost on, which is not something we want to do or turn away deposits. But that -- we'll be thoughtful. But there's no doubt we're going to have to manage this just like we manage all of our scarce resources.

Susan Katzke

analyst
#44

So you touched on the implications of the world without SLR release at the end of March when that expires. And just remind us, thinking back to the 2015, 2016 period, where you took specific action at JPMorgan to ship not operating deposits off the balance sheet. And how you think about doing that? And how you effected that process 5, 6 years ago?

Jennifer Piepszak

executive
#45

Yes. So I would say broadly similar themes, obviously, but some differences in the detail. So back then, we were managing to a new LCR requirement. And so it was about non-op deposits, not all deposits. Whereas now, given that we are in a very low rate environment with very little loan growth, the liquidity value of the marginal deposit, whether it's -- even if it's an operating deposit, it's very, very low. And so right now, what we're talking about is, in a lot of ways, more complicated because it's all deposits and the issue is an issue for all of the major banks. But yes, we will have to think about how we can manage deposits. We have a couple of choices. Unlike back then, we do have a couple of choices in the sense that we could issue preferreds to cure the SLR issue, but we -- or we could hold more common. That's another avenue for us or we could turn away deposits.

Susan Katzke

analyst
#46

Okay. So let's switch gears. None of those options are terribly good, but you'll manage them. So what's your take on the 2021 CCAR scenarios? Because you did mention some potential offset to G-SIB, to SCB management. So your take on the scenarios as well as the actions that JPMorgan is taking to reduce stress loss content relative to, I think, it was at 3.3% SCB in 2020?

Jennifer Piepszak

executive
#47

So I mean, the scenarios were broadly in line with what you would expect, more stress in CRE, less stress in unemployment. So I think they were broadly in line with what we would have expected. As far as the actions that we've been talking about that we could take in SCB, we have completed those. And so that includes transferring securities from AFS to held to maturity. We did that for other reasons, but it has the benefit of helping on SCB. And then loan reclassification on the balance sheet out of trading into loans, that also helps SCB, and there's a few other mechanical things. Of course, the SCB is scenario dependent. So what I can say is relative to the scenario that resulted in the 3.3%. We do think that there's opportunity for us, but it's scenario dependent and, of course, based upon Fed modeling.

Susan Katzke

analyst
#48

Sure. So when I think about CCAR as well, it's increasingly clear that CECL and CCAR are almost in conflict with each other. And let's talk about this for a second because when you think about the round 2 scenarios and the benefit to loss content of having the loan loss reserves on your balance sheet after the second quarter of last year, in particular. Does this conflict with how you think about or impact how you think about loan loss reserve relief?

Jennifer Piepszak

executive
#49

Well, it's a really good question because structurally, it's sort of a very obvious point. I think it's more obvious at this point in time because we are coming through a period of stress where we built reserves. And of course, now heading into a period of recovery. So I think it's a very good question at this moment in time. I think it will be less of an issue going forward when you're in more of a benign BAU environment. Having said all that, no. It's not the way we think about it, of course, because our reserves are at any given point in time are our best estimate of future losses and they're compliant with GAAP. And so it's not something that we do or should consider as we think about the level of reserves. But it is a good question given how the stress is constructed.

Susan Katzke

analyst
#50

And so when we -- we've touched about on some of this in terms of the discussion around capital management. But in terms of the regulatory outlook, what do you think changes in the Fed's approach to CCAR considering the last year with the pandemic, the drawdowns, the loss realization, the market activity, what changes?

Jennifer Piepszak

executive
#51

Well, I can touch on what I think should be considered. Of course, like I don't know what put -- what will be changed. But I do think that there were a lot of really important learnings in 2020. And they include the extraordinary system expansion that has put pressure on size-based measures. Obviously, we've spent enough time talking about G-SIB and SLR, but there's a very real lesson there in how we need to think about and sort of future-proof these size-based measures that were never meant to be finding constraints. They were meant to be a backstop. So -- and then they stress test themselves. I think we were -- we learned that they don't necessarily reflect reality. So the SCB is an enormous buffer. And of course, it is a buffer, but it is treated like a minimum. And in that world, when we build reserves, we then replenish that capital. And so as we build reserves and replenish the capital to meet our SCB minimums, we have now increased the loss absorbing capacity in the system pretty significantly. So that should, I think, be considered as well. So I think there's a number of learnings. We're certainly hopeful that they'll be taken into account in the future. And I certainly hope that we can believe in the SCB framework, such that next time we go through a crisis. This time was unique, obviously. We had CECL. We had a new accounting framework. We had a new capital framework, so it was understandable that the Fed wanted to do what they did in terms of pausing on distributions. But I'd like to think that in a future crisis, we can have confidence in the SCB framework and not have to introduce capital distributions of that.

Susan Katzke

analyst
#52

Fair enough. And in what other areas do you expect the new administration to possibly drive regulatory change as it pertains to your businesses?

Jennifer Piepszak

executive
#53

So I mean, it seems pretty obvious that the priorities at this point are the COVID recovery, climate and racial equality initiatives, and we are ready to be helpful and look forward to being a great resource and partner with the new administration on all of it. And obviously, you're familiar with the path forward announcement that we made, $30 billion commitment. It includes commitments to promote affordable housing and homeownership in underserved communities. Growing Black and Latinx businesses, including announcements we've made over the last few days about support for minority depository institutions, improving financial health, and access to banking in underserved communities. So we are really committed and excited about what we can do in the path forward initiative. And then the Paris-Aligned announcement that we made recently as well as other historical commitments that we've made, whether it be $200 billion of a commitment to financing, green, social, and economic development, to be carbon neutral in our own operations. Towards the end of last year, we issued our first green bond. This year, our first social bond. So we're incredibly committed to all of these initiatives. And I said, look forward to being a great resource for the new administration.

Susan Katzke

analyst
#54

Wonderful. We do have 1-minute left. So I'm going to take a question that's come in a couple of times with respect to the 10-K disclosure and the meaningful increase in interest rate sensitivity, asset sensitivity that was reported. And I know there was a bit of a change in the earnings at risk model. But can you just clarify what changed?

Jennifer Piepszak

executive
#55

So we updated the rates paid or the betas in the consumer deposit model. It just was really important for us to do that now that we're back at the 0 bound. So there, I would just remind everyone that, of course, there's convexity there. So it is not linear. So the impact of the 100 basis points from this level is not the same as the impact of the next 100 basis points. But that was really a function of us thinking about the experience in the '15 through '19 rate cycle and now that we're back at the 0-bound updating for that experience.

Susan Katzke

analyst
#56

Okay. Fair enough. Well, I think we all look forward to continuing to see this economy recover and interest rates move in a direction consistent with that recovery, which would allow you to realize the benefits of that rate sensitivity. And so to end this on that high note, I want to thank you so much, Jen, for being with us today for skipping an Investor Day or going to an every other year schedule here to join us at this conference. Thank you so much.

Jennifer Piepszak

executive
#57

That's Great. Thank you. Thanks for having me. Okay. Bye-bye.

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