Zions Bancorporation, National Association (ZION) Earnings Call Transcript & Summary
November 10, 2020
Earnings Call Speaker Segments
Erika Najarian
analystGood afternoon, everybody. So before I introduce the last bank presenter of the day, I just wanted to thank all the investors for joining us, albeit virtually, at this year's Future of Financials Conference. Without further delay, I wanted to introduce our conference's last presenter. That's Zions' Chief Financial Officer, Paul Burdiss. Welcome, Paul.
Paul Burdiss
executiveThank you, Erika. Thanks for having us.
Erika Najarian
analystAbsolutely. Paul, I just wanted to kick off the fireside with a question on the health of small business. Clearly, you're well known for having major market share with small businesses in the Western United States. With the presidential election ostensibly behind us and an economic recovery potentially also underway, how does Zion see the recovery of small business in 2021?
Paul Burdiss
executiveYes. Our small business customers have proven to be, I think, very resilient. And you see that in our credit loss statistics that we've been reporting here over the course of the last several quarters. I think the government stimulus targeted to small businesses has been particularly helpful for our client base. And as a result, certainly, I like to think and believe that maybe difficulties that could have come about due to a really rapid change in the environment have been helped by the government and helped our customers to reset their businesses and really operate in the new environment, gave them time to reset the businesses to operate in the new environment and in a reasonably healthy way. That is to say that I believe that our customers largely have been able to balance the cash flows of their business into operating into what is the current environment.
Erika Najarian
analystTwo-part question coming up as a follow-up. Scott McLean has mentioned several times that most of the $7 billion in PPP proceeds are still sitting in deposit accounts. So the first question in the two-parter is, how crucial is a second round of PPP to the health of small business going forward?
Paul Burdiss
executiveWell, that's hard for me to speculate on, how particularly useful that will be. I can say that our customers seem to be in pretty good financial shape as indicated by deposits in their accounts. As you noted and has been noted previously, our customers have a lot of -- it seems like our customers have a lot of operating cash in their deposit accounts. And in fact, aside from PPP, we've seen a lot of organic growth in our deposit accounts over the course of the last couple of quarters. So from a cash flow perspective, it would appear that, in particular, our small business customers are pretty healthy. But sort of what happens from here on out, how the government reacts to get into that, I think, is a little speculative just because I don't know precisely how the economy is going to react over the course of the next 6 to 12 months. And I'm expecting that the federal government will react to that.
Erika Najarian
analystAnd given the strong liquidity position of your small business clients, how much do you think that positioning slows net loan growth going forward?
Paul Burdiss
executiveYes. Our customers seem to be in pretty good shape financially, although I will say much of small business is really around deposits as opposed to growth, right? I mean it's a deposit-rich business. So when I think about growth in small business loans, it's a portion but not our entire balance sheet. As you know, we've got -- we lend into a lot of different categories, including consumers. And so I'm hopeful our lenders, I think, are somewhat optimistic in terms of how they see loan growth evolving from here, but I am not expecting over -- certainly over the medium term that, that influx of cash will adversely impact our loan growth in a very large way.
Erika Najarian
analystSo switching topics a little bit. A major theme in this year's Investor Day, and I actually can't believe that was this year, centered around the bank's tech investments. The third release of FutureCore is now underway, and the full replacement of your online and mobile infrastructure should be complete by 2022. Can you provide us an update on how these projects are progressing?
Paul Burdiss
executiveSure. On FutureCore -- I'll start with that. On FutureCore, you may recall we are replacing all of our core systems, loan and deposit. All of the in-scope loans have been successfully converted over the course of the last couple of years to the new core system. As you correctly point out, deposits will be in play. Deposits are sort of a significant factor of complexity, far more complex than loans to deposits due to -- or loans due to the number of transactions that occur in the system on a daily basis. And so that's a much bigger conversion process that we expect to be done into 2022. So that replaces a core system. The other elements are more customer facing, as you said, sort of more of an improved digital experience for our consumer and small business customers. And again, those are progressing. We expect those to be in place, again, in 2022. I will say that the pandemic has impacted the workforce, and we think we're up and running and everything is operating as smoothly as it can be given the environment. But we have indicated that there could be some delays associated with that, sort of the longer-term knock-on effects of the pandemic on the workforce. But as of now, we are expecting to continue to have both of those operational here by the end of '22.
Erika Najarian
analystAs you complete this project, how much, if any, cost savings could be there? And if there are cost savings that are associated with the completion of this project, does this fall to the bottom line?
Paul Burdiss
executiveCost savings are an interesting topic when you replace -- the core system is expensive, right? And we are capitalizing that. We provide updates in our 10-K and 10-Qs on the capitalized costs associated with that. The old systems for us and for, I would say, most banks have been depreciated for decades, right? Fully gone and depreciated for decades. And so the ongoing cost is really maintenance and pretty minor. In this case, because we're investing so much in this project, we will have amortization of capitalized costs over the next 10 years. And so the cost savings really would come about through operational efficiencies. As we take out the complexity of the current environment and we replace it with a new, modern core, my expectation is that we will realize operating efficiencies, but my expectation is that those operating efficiencies will be reinvested in the business. We had, last year, for example, through ongoing automation efforts, we say it's a little under 100,000 labor hours through the application of bots and other things. The new systems that we're putting in place are allowing us to be much more operationally efficient. But again, I expect those to be reinvested into the business.
Erika Najarian
analystSo Paul, maybe digging into that a little bit more. Zion has done a great job improving PPNR over time. Obviously, the rate environment hasn't been helpful for banks, but you've been able to really keep core expenses relatively stable. As you think about -- you balance those investments that you mentioned, can you discuss your ability to keep expense growth under control in the current operating environment?
Paul Burdiss
executiveYes, this gets to this operating efficiency thing. Much of the expense control has really come through operating efficiencies. We consolidated our bank charters several years ago. We are now one bank. We no longer have a holding company. So we're only a bank. So we've created, I would say, a more simple operational structure. In -- a dividend from doing that is continuously improving our operations, making them more streamlined. That's been a really big function of our ability to hold our expenses flat. Although, I will say there's a human resource element to this, too. And you may recall a year ago, almost exactly a year ago, we announced a reduction in our workforce of about 5%. And that has -- obviously, we saw that because we thought interest rates were going down and tried to maintain balance between revenues and expenses. Obviously, the environment that we foresaw was not the environment that we're living in. But I do feel good about the fact that we were really proactive in managing those expensive -- expenses late last year, which has set up -- set us up well this year for another year of controlled noninterest expense.
Erika Najarian
analystSomething that investors always point out to me favorably, a portion of Zion's executive management incentive compensation is tied to the bank achieving multiyear financial targets, the Value Sharing Plans. Can you discuss how the plan functions should the bank not meet preestablished performance targets?
Paul Burdiss
executiveYes. There's a really good -- I'm not going to get into all the intricacies. Actually, that year -- is modified just a little bit every year. But generally speaking, there's sort of an absolute performance and a relative performance aspect to those plans. And while there is sort of a discretionary element that is also attached, by and large, quantitatively, we accrue those plans in accordance with our performance. And again, its performance on both a relative and an absolute basis. Again, proxy statement is a pretty good description, I think, of how they work. But the whole idea there is that, as you correctly point out, we are trying to tie long-term compensation to long-term performance. And so particularly, the VSP plan is centered on that.
Erika Najarian
analystGot it. Switching over to revenue. Approximately $2.5 billion of the $3.5 billion in interest rate hedges are expected to mature in 2022, reducing interest income by $46 million year-over-year. Without an increase in rates -- although, clearly, the yield curve has deepened over the past couple of days. But take that aside, how does management plan to support net interest income growth going forward especially given that there seems to be a limited opportunity to reduce liability costs?
Paul Burdiss
executiveYes, the -- so net interest income -- aside from rates, net interest income really needs to be managed through balance sheet growth, and that's what we're focused on doing. As I said, we've got a real influx of deposits. We have one of the lowest-cost deposit bases in the industry. I'm certainly hopeful that we can continue to grow the balance sheet, in particular, loans, to support that noninterest income -- net interest income growth. I will say, though, the steepening of the curve is encouraging. Yes, one of the things that you really can't hedge over the medium-term is a sort of a structural change in rates, which is really what we've seen. However, I'm hopeful, as I said here, over the next couple of years, we will begin to be paid for duration again. And when that happens, we've got a lot of capacity to continue to put hedges on -- hedges, i.e., swaps on the balance sheet. A lot of our asset sensitivity growth recently has really been driven by deposit growth. And so to the extent those deposits are sticky, we can continue to add duration on the asset side of the balance sheet, again, to the extent it makes sense and we're getting paid to do that.
Erika Najarian
analystAnd just as a follow-up here, I think the answer is most of it, but how much of the deposit growth that you realized have been in operating accounts?
Paul Burdiss
executiveYes. I don't have the specific proportion, although I do say, and as you know I've been following this for a long time, that we monitor that very closely. And this does appear to be a very operating account sort of intensive growth, so I feel very encouraged about that.
Erika Najarian
analystAnd just as a follow-up here. It seems that the market consensus is lower for longer, similar to how, in 2010, we thought the Fed was going to raise rates soon and we awaited for 5 years. It seems like you hinted to the view that you do think that there could be elements that could lead to more sustained curve steepening from here. Is that -- did I take that away correctly?
Paul Burdiss
executiveWell, look, I'm not an economist, but I do look at sort of the fundamental aspects of what's going on with the money supply, what's going on with the federal debt and deficit. And the laws of supply and demand, as far as I know, have not yet been repealed. It's hard for me to imagine that while the Fed will maintain a very sort of stimulus-oriented stance over the course of the next several years, they've been talking about that, that does not necessarily mean that the curve is going to remain extremely flat. We're planning for that, a reasonable chance that there's the outcome of that. But I also believe that there's a chance that we will see curve steepening. And when we think about our balance sheet and the profitability of our balance sheet, we're not only tied to short-term rates, but we've got exposure sort of added to the medium part of the curve. And so to the extent the curve does steepen, that certainly will be helpful for our net interest income.
Erika Najarian
analystAnd Paul, I asked you earlier about small business, and you alluded to overall loan growth also earlier. Maybe I'll be more specific in this question. In terms of your larger commercial clients, what has their sentiment been? And how does the election outcome and potential quicker resolutions to the pandemic impact switching from a defensive stance to an offensive stance in terms of growth?
Paul Burdiss
executiveWell, I don't know that the election outcome has a really big effect certainly over the near-term on loan growth, although I will say uncertainty. Nobody likes uncertainty, including our borrowers. But to the extent that, that outcome becomes more certain over time, I am, I think, much more interested in the potential for the relief on the pandemic, that of a vaccine or herd immunity or some other thing they create. I'm certainly hopeful that as we get into the -- and I'm, it's me speculating, certainly hopeful by the time we get into the middle of next year, certainly, we'll have a much more certain path in terms of our economy largely due to, hopefully, a positive resolution to the COVID-19 pandemic. And so when I think about sort of where we're sitting and the things that could happen over the next 6 to 12 months, I'm certainly more optimistic than pessimistic of the outcome.
Erika Najarian
analystOn the municipal credit book, which has seen really nice growth over the -- recently, I think it was up 24% year-over-year, and James will correct me if that number is wrong. But could you discuss how much more opportunity or runway for growth is there in the muni book?
Paul Burdiss
executiveThis is, I think, a nifty little business for us. An artifact of our model is that we're very local, and we get to know our communities very, very well. This municipal book, a lot of it is, I would say, very granular secured loans to very small municipalities. Over time, we have had an excellent, knock on wood, excellent credit performance in that portfolio. Oftentimes -- again, these are not sort of heavy bid situations against the global banks. These are often, I would say, either very limited bid situations or, sometimes, just negotiated transactions where we are the only bank at the table. This has proven to be a very, very good business for us. And we are mindful of pricing. It is a little thinner spread than our typical loan, right, because the risk is so low. So we do internally establish minimums below which we won't do business. But the business itself on a risk-adjusted basis is a really strong business. And we do have concentration limits, credit and otherwise, that were not -- we're not close to those concentration limits. So we could continue to see that growth -- that type of growth for the next couple of years pretty easily, again, to the extent the risk and return dynamics remain positive for us.
Erika Najarian
analystTying back to the conversation you were having earlier about the yield curve and the nature of the deposit growth that's been coming in, you noted in the third quarter call that the surplus cash is -- had gone to paying down debt and increasing short-term investments. You mentioned there's going to be a time to take on some duration risk. What do you need to see in the marketplace and with the rate market before more meaningfully deploying your excess cash.
Paul Burdiss
executiveYes. So we're talking about our balance sheet, of course, and we have taken this influx of deposits and paid down more expensive wholesale borrowings. One of the artifacts of our net interest margin is that we've got more in cash on reserve at the Fed earning kind of 10 basis points, which I think is the IOER rate. So I feel good about the deposits, the stability of those deposits. That feels good over time to the extent the yield curve steepens. As I said, we have not, over the last 6 months, really been paid at all for duration. And so to the extent, the curve steepens a little bit, and we feel like we are being paid for that duration. It will certainly make me and, I think, our ALCO more comfortable going a little further out the curve. So it's really a combination, Erika, of sort of ensuring that the deposits are stable and then also sort of matching up the cash flows on the asset side of the balance sheet with the potential cash flows on the liability side. Hopefully, that makes sense. It's really -- so it's really a function of the stability of deposits and the interest rate environment.
Erika Najarian
analystIn your 10-Q filing, you -- I'm going to read this off verbatim. It read, "Yields on new loans have been only modestly lower than yields on maturing loans." Can you discuss how loan pricing is evolving in the current environment and where you're seeing some spread widening?
Paul Burdiss
executiveSure. So this is a topic that, as you know, from listening to the call, I didn't get into a lot of detail on this. And the reason is that in any given month or quarter, the -- sort of the average credit quality of loans coming on or going off could be highly variable. And so I don't want to make a lot of speculative comments around sort of what that net number looks like. However, it is factual to say that -- and as we said in the Q, in the third quarter, the yield of the loans coming off was relatively close to the yields coming on. And so as we think about that over time, what's happened is we saw a lot of, I would say, generally, either coupon or spread compression over the course of the last 18 to 24 months. It feels like that has really stabilized and even turned around a little bit, interestingly, in the last 3 to 6 months. And so that comment is just meant to be indicative of the fact that there is not a massive difference right now in the coupons of loans coming off versus those coming on. So to the extent we are growing loans and replacing loans, right now, it is not a really big negative on the average loan yield and, therefore, the net interest margin.
Erika Najarian
analystPaul, you and the rest of your management team have talked a lot about your success administering the PPP program. And you noted that you developed 14,000-plus new-to-bank customer relationships with PPP.
Paul Burdiss
executiveYes. Very proud of that. Yes.
Erika Najarian
analystMaybe talk a little bit more about how you plan to retain and deepen these new relationships.
Paul Burdiss
executiveRight. So we've got -- as you can imagine, we have the data on all these folks, a lot of data on all these folks, and we are very actively creating call lists and going out and aggressively calling on these new customers. Although I will say, because they're small business customers, as noted earlier, small business -- an artifact of small business is it's very deposit intensive, not always loan intensive. And so we're looking to sort of integrate them into the bank. That doesn't necessarily mean we're going to see a spike in loan growth because a lot of small business customers are really deposit oriented.
Erika Najarian
analystAnd is the Treasury Select offering relevant to this cohort of small businesses?
Paul Burdiss
executiveYes. So it's interesting that you called that out. So one of the things that we have been doing is looking at -- as we are a commercial bank largely, we have some pretty sophisticated commercial banking product offerings, particularly around treasury management, managing deposits and activity for our commercial customers. One of the things we've been working on for the last kind of year to 18 months is creating kind of a slimmed-down version of those sophisticated treasury management products that would be cheaper to deliver, could be priced maybe a little more aggressively, doesn't offer the depth of service the larger commercial customer would need but would really fit well with our small business customers. So it's that product offering which we refer to, Treasury Select, that we are marketing into our small business customers with some success.
Erika Najarian
analystIn a -- this question is very relevant in a tough spread environment. You previously noted that you're working to leverage focus on accelerating sales of capital markets products, treasury management, wealth advisory services, to your broader commercial base. Can you provide an update on how you're doing? And have you established any financial targets for this business that are internal? And could we potentially see these targets over the next 2 years?
Paul Burdiss
executiveCould you potentially see them? Yes. Have we established targets? Yes. But they're internal targets right now, not external. We are seeing success in capital market sales and, particularly, wealth management and wealth advisory sales. It's a little masked in our noninterest income because of the outsized performance of mortgage banking this year due to the -- we have a revised and much more streamlined digital process for applications. And also, of course, the yield curve environment has impacted that. But I think what you'll see over the course of time, particularly around wealth advisory and capital markets, is a pretty sustained growth there. What we have organizationally is that we've got a lot -- a very, I would say, relatively large, unserved, untapped client base. And so one of the measures we're developing internally is the degree to which we are penetrated with some of these core product offerings. And I'm hopeful that we'll be in a position to start talking about those metrics and targets on a more public basis here, hopefully, in the near-to-medium term.
Erika Najarian
analystAnd maybe give us an update on how fee income categories that were impacted by COVID-19 are recovering. The third quarter saw a nice rebound in activity levels.
Paul Burdiss
executiveYes. Third quarter did -- it was -- there was a good rebound in the third quarter. And it's important to note that this gets back to the -- sort of the first question we discussed, and that is our ability of our customers to sort of rebalance their business to manage in the current environment. So I think all of us have sort of sorted out a different way to interact with businesses and other -- and service providers. And so you're seeing -- therefore, as that is rebalanced, you're seeing that resurgence in activity. And I'm certainly hopeful that will continue, in my optimistic view of the world that the economic recovery continues.
Erika Najarian
analyst[Operator Instructions] Onto credit quality, just given some takeaways that we've learned from the conference so far, Paul, there seems to be 2 interesting takeaways that we've learned. One is management teams seem to be okay with essentially saying that the peak in net charge-offs in 2021 may be less than we've seen in previous recessions. And also, what surprised me a little bit is, when asked to define normalized reserves, they referred back to the day 1 CECL reserve-to-loan ratio, which was unexpected. But before we get into that, loan balances on deferral declined notably to 60 basis points in the third quarter, and I think only 1% are delinquent by 30-plus days. How would you characterize then the financial health of your average commercial customer?
Paul Burdiss
executiveYes, I would say that our -- I will say that average commercial customer has proven to be remarkably resilient. We have discussed in the past these sort of deep dives we're doing. We've identified a set of customers which we call sort of enhanced risk to the COVID-19 pandemic. We're monitoring those very closely. We're reporting on those in our 10-Q and on our earnings presentations. And we do deep dives in these categories. And I would say that these customers, by and large, have found a way to sort of remain profitable even in a very difficult environment. And so what you're seeing is -- I would say, in terms of variations on deferrals, it feels a little more like sort of normal variation as your numerator and denominator changes that can cause differences as opposed to some sort of very obvious trend that we're monitoring. And so I see that, frankly, as pretty good news. It feels like the operating environment. Just it isn't that abnormal considering the environment that we're all living in.
Erika Najarian
analystIf the economic recovery is a little slower than we would like, what is the process or method for potentially extending a second deferral if a business gets in trouble again?
Paul Burdiss
executiveWell, as we did at the outset, to the extent our customers contact us and need additional assistance, we will work with them. And we have a track record of working with our customers to the extent they need that additional assistance. So I would not expect any sort of blanket deferral program or anything to happen. This will be on a case-by-case, one-by-one basis that we have a long history of working with our customers, and I would expect that to continue.
Erika Najarian
analystSo typically, this word is misused, but I think it's appropriate to describe the government programs. They've truly been awesome in terms of how -- the speed and the size of support. Do you think that the government programs have effectively redefined what peak charge-offs are in the cycle lower than they would have been? Or are we just kicking the losses down the road?
Paul Burdiss
executiveSo this -- that's a thoughtful question, and I would have to refer back to our stress testing and, frankly, our CECL modeling, right, our loss -- for credit loss modeling. We have models that create outcomes, and those models are trained on data sets. Our models are largely -- the biggest variable in our model and many models is the unemployment rate, right? And when you think about the government stimulus, they -- I can't think of a statistic, but basically, the average wage earners' revenue -- or earnings went up after the pandemic struck because of the government assistance and stimulus programs. What that's created is a set of modeled outcomes where these models were trained on a data set that unemployment never exceeded 10%. The modeled outcomes are not matching realized outcomes. And now we have 6 months of data we can kind of go back and back test what our models would have predicted and what actually happened. All of that is a long way of saying, yes, I absolutely think that the government programs have impacted in a positive way credit performance. And I don't think that's a temporary shift. I actually think that there have been a lot of losses mitigated due to the existence of those government programs.
Erika Najarian
analystI want to clarify a point that management said during its first quarter earnings call regarding losses. You mentioned that given that, obviously, you've significantly improved the credit risk profile -- I think the quote is the loss rate will be 30% lower today using global financial crisis, or GFC, rates on today's portfolio mix. And I just wanted to clarify that that's just an exercise of how the mix changed, that the GFC is still pretty far comparison from where you think your portfolio will trend in 2021.
Paul Burdiss
executiveYes. We were not at all predicting a GFC-like outcome. You're exactly right, Erika. What we're trying to demonstrate is, algebraically, if you apply the losses that we realized 10 to 15 years ago to the current portfolio mix, overall losses would be much lower because of the change in concentrations and the change in sort of portfolio distribution between now and then.
Erika Najarian
analystYes. But you were making -- and just again to clarify very specifically, you were making a comment on the loss content themselves in each of the portfolios.
Paul Burdiss
executiveWe were only saying that the portfolio mix has changed, and all of the things equal would have created a lower level of loss with the loss rates then applied to now. But that was not talking about expected loss rates in the current book.
Erika Najarian
analystGot it. You noted that growth in term CRE loans primarily reflected converted construction. CRE retail and CRE hotel/motel composed the majority of the COVID-sensitive sectors. Could you discuss the loss expectation within these portfolios? And how does the pandemic shift your appetite long term to originate loans within certain classes of CRE?
Paul Burdiss
executiveWell, in terms of loss expectations, I could really only point back to the allowance for credit loss. We've got -- we do provide some breakout on how that allowance for current losses is distributed among our asset classes. And that's probably the best information to utilize as it relates to any sort of forward-looking thoughts on how that might materialize. But as it relates to commercial real estate, generally, this is an asset class that we feel comfortable with. We know it really well. We've got a very large stable of highly qualified and experienced lenders and credit people. We've also got, I'd say, a reasonably sophisticated concentration risk management framework that lays on top of that portfolio. So the fact that we are in an environment that is creating stress in CRE is not causing us to go back and, I would say, have a reaction, maybe a knee-jerk reaction to changing the portfolio composition because we have built a sustainable portfolio that is meant to weather cycles, and we need to be consistent sources of capital for our borrowers. And I think we'll be able to achieve that.
Erika Najarian
analyst1/5 of your nonaccrual loans and 1/3 of your gross charge-offs were within the energy sector as of the third quarter. When do you expect the pain points associated with this portfolio to subside?
Paul Burdiss
executiveReally hard to predict, obviously. There's a lot of variables. Economic activity and the price of energy are really important ones there. I think we are hopeful that as we're working through those problem credits now, all of the things equal, as we get into next year and further into next year, we'll see the -- sort of the balance of those businesses return, and we won't see as much in terms of charge-offs. I would also point out, if I could, we went through an energy cycle here about 5 years ago. We had some pretty significant charge-offs at that time. But then we had some really significant recoveries in the ensuing 2 to 3 years. So the way we underwrite is really important. Our sponsors and our borrowers, our portfolio looks different. Every bank's portfolio is different. But I certainly like to think that we have demonstrated a track record of, even where we've seen stress, we've been able to do our underwriting, go back and generate recoveries to the extent that's possible.
Erika Najarian
analystAnd in an environment where investors are more focused on normalized returns than trying to call the trough in earnings, help us think about the "normalized" reserve levels. What is an appropriate reference point? Obviously, we've only been in a CECL world for 11 months. Where could reserves normalize too relative to loans? And how quickly can one bank get there, let's say, relative to the peak in quarterly net charge-offs? And how impactful is it for us to look at the R&S, or reasonable and supportable, period when thinking about that speed to normalize?
Paul Burdiss
executiveThere's a lot in that question. So in terms of return to normal, that's really, really hard to predict because it's an artifact largely of the economic forecast that you're using. In our case, we have a 12-month reasonable and supportable period and a 12-month reversion period, after which we revert to sort of longer-term loss rates in the calculation for our reserve. So to the extent that economic forecasts are changing rapidly, that economic -- reasonable supportable period probably becomes a little more important. Ours is on the shorter end. I think peer banks are sort of between 12 and 36 months. Ours is on the shorter end, which is -- which I think reflects the relatively short nature of our loan portfolio. But to the extent that macroeconomic forecast changes, you will see that change in the allowance. And then you asked about charge-offs. Interestingly, charge-offs, in my mind at least, could become a little disassociated with the allowance because the allowance is all forward looking, right? And so to the extent you've got a sort of rapidly changing macroeconomic environment, that, in my opinion, will be the key driver of changes in the allowance for credit losses as opposed to backward-looking credit performance.
Erika Najarian
analystSo switching to capital. Following very strong levels of capital but also a clear, strong desire to stay above peer in terms of capital levels as we come out of this downturn, how do you balance that desire to maintain a capital level above peers versus taking advantage of buying back your stock at current valuations?
Paul Burdiss
executiveYes, current valuation is better today than it was 2 days ago, right, which I'm very happy about, and I hope our investors are, too. As it relates to the -- our philosophy around capital. So the idea, as you may recall, going back a year ago, we said our intention is to enter the next financial downturn with kind of lower-than-average risk and better-than-average capital. Little did we know that, that was -- we're going to have the opportunity to demonstrate that kind of within 6 months of those statements. So I feel really good about our balance sheet positioning on an absolute and on a relative basis. Over time, as the risk profile changes, our capitalization will change to reflect the risk profile. We are absolutely interested in managing our capital through buyback when that makes sense. And when that makes sense, I think we'll be, as we start to see a path to normalcy, as we begin to see -- you may have heard me talk about the cone of uncertainty. [ Our working ] forecasting, right, has this large cone of uncertainty. To the extent that cone of macroeconomic outlook narrows, we will become more comfortable actively managing our capital, and that would include through share repurchases.
Erika Najarian
analystAnd Paul, many on the line know this, but I just want to emphasize the point, since most of the banks I cover are part of the DFAST, it -- your fate in terms of your ability to buy back stock is based on your judgment of economic certainty or uncertainty. And there's no formal process upon which you have to start to start the buyback program.
Paul Burdiss
executiveIt's not 100% accurate to say there's not a formal process. Because we are a national bank, we are regulated by the OCC. The OCC are absolutely interested in the way we manage capital. And so we do go through a process with the OCC in terms of coming up with their agreement with our capital management plans. Now I will say, you're right, we're not part of CCAR. And as a result, there's probably a little more flexibility in our process with them because there's not sort of one time a year when we can make these requests. So it's just -- it's important to note that it's there is a formal process. And the formal process, though, is a little different from other banks because we are a national bank with no bank holding company.
Erika Najarian
analystIf the Fed is more conservative about extending restrictions to the CCAR participants and your outlook on the economy is -- has improved, does it matter that your larger peers are still under restriction in terms of your -- how you're thinking about timing the start of a buyback?
Paul Burdiss
executiveI think it matters. But I think that the risks that we face as sort of a midsized bank are very different than the risks than -- that the large sort of CCAR banks face. And so as a result, there's probably a little flexibility in the way that we are being judged versus the way that they are being judged. But I am not the judge. And so that's a little bit speculative on my part.
Erika Najarian
analystGot it. And I actually don't see any questions in the webcast portal for you, Paul. It seems like you've covered all the topics. Any final words for your current and prospective investors before we sign off?
Paul Burdiss
executiveOnly to reiterate the fact that I think that we are a unique organization, a unique franchise in the Western United States. I think that over time, you will see, as an investor, our risk and return profile changing, becoming more positive as it has over the last 5 years. We appreciate our investors' interest and look forward to providing very solid returns in the future.
Erika Najarian
analystGreat. Paul, thank you so much for joining us today.
Paul Burdiss
executiveThank you. Have a great day.
Erika Najarian
analystYou, too. Bye.
Paul Burdiss
executiveBye.
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