UK: 2013 Banking Industry Outlook - Moving Forward In The Age Of Re-Regulation

Last Updated: 18 December 2012
Article by Deloitte Financial Services Group

Most Read Contributor in UK, August 2017


The banking environment for the coming year likely contains equal parts resolution of past challenges and introduction of new ones. The economy in the United States is showing evidence of continued recovery, with jobless rates continuing their slow decline and the housing market showing evidence of some recovery.

However, fast on the heels of the U.S. elections in November 2012 will come the need for a swift resolution to the fiscal challenges that are looming in January. The combination of the spending cuts mandated by the Budget Control Act of 2011, known as "sequestration" and the expiration of several tax cuts could severely damage that recovery if not dealt with (see Exhibit 1).

At the same time, the weakening of the European economy continues. Stopgap measures have been passed over the recent months, but a long-term resolution of the economic instability in Portugal, Ireland, Italy, Greece, and Spain is not evident. Speculation can lead one to many potential outcomes, including the potential dissolution of the European Union. But whatever the outcome is, it is not likely to be quickly implemented, nor will it come without significant pain.

China, too, has seen somewhat of a slowdown in its previously accelerated growth. Reduced economic activity, with consequential reductions in demand for commodities to fuel that output, could have a knock-on effect on many economies throughout the world.

Returning to the United States, bankers likely will continue to be challenged to find profit in an environment of low interest rates, and thus low net interest margins. Continued quantitative easing by the U.S. Treasury and Federal Reserve – the so-called QE3 – is the latest effort undertaken by the central bank to spur demand for loans and overall economic growth. We are seeing some increase in loan demand – particularly among middle-market corporate borrowers – but many consumers are continuing to deleverage their household balance sheets and so a broad-based return of consumer loan demand is unlikely in the coming year.

Finally: regulation.

The aftermath of the financial crisis spurred the creation of the most comprehensive set of new regulations in the last 70 years. During the last year in particular, bankers adopted a "wait and see" attitude about these regulations, as the detailed implementation procedures had not yet been written. 2013 looks to be a year of implementation for the U.S. banking industry as much of the regulatory uncertainty has been resolved and industry leaders assess their organizational structures and capabilities in the face of narrow margins, increased capital requirements, and consumer protection.


As we turn our attention to 2013, there are a series of interdependent issues that senior-level bankers should consider (see Exhibit 2). We have chosen to present these issues in a way that reflects the relative impact and priority of these issues specifically for the coming year. That is, while most of the items discussed are not appearing on a list of this sort for the first time, some are moving more quickly than others over the next 12 months. Therefore, executive should pay closer attention to those more rapidly evolving concerns and make plans accordingly.

These issues exhibit some regional dynamism, in that the list of priorities and their relative degree of change for the coming year will differ depending on the individual country or region. For example, bankers in growth economies in Asia or Latin America are anticipated to be more concerned with growth-oriented initiatives, while those in Europe and the U.S. are likely to be more focused on determining appropriate uses of capital as a way to drive strategic imperatives and operational restructuring.

These issues are presented below, arranged in pairs from most critical and rapidly evolving, to those that are the more evergreen challenges that bank leaders face. Starting the list are two issues that are fundamental and upon which all the other issues are based. From there, we will explore topics in four major themes: industrialized operations, asset protection, delivery transformation, and return on capital.


Making hard decisions about where to compete

Bankers in the United States put a hold on making any meaningful changes in leadership, organizational structure, and operational processes in the aftermath of the financial crisis. Certainly, they were focused on ensuring the survival of their institutions, and rightly so. They were also waiting for the process of re-regulation of the industry to progress to a point where the implications for their business operations became clearer. Rulemaking has now progressed to a point where the impacts should be well enough understood by industry leaders. This should allow bankers to shift their focus toward implementing new strategies and organizational structures that will enable them to be more competitive going forward. According to Bob Contri, vice chairman of Deloitte LLP's1 banking and securities sector, "The market is starting to get away from being frozen by regulation... and so there is likely going to be a big push to get more strategically focused around where organizations think that they have the best ability to compete and win."

At the head of the list of drivers are the new rules around capital adequacy, driven by Basel II and III mandates, as well as the living will procedures embedded in the Dodd-Frank Act. Investor demands for return on equity are not to be underestimated as well. Finally, there is some remaining uncertainty about the direction of regulatory action that is associated with the outcome of November's elections.

What's new for 2013

What may be different for banks in the coming year is the movement from analysis to action. As stated above, many initiatives were put on hold as legislative and regulatory actions were promulgated. Now that the impacts of these changes are better understood, banks are likely to begin a refresh of long-term strategic planning.

Bottom line

Banks should consider the strategic repositioning of their organizations. It's one thing to say that focus has returned, and that leadership has charted a new path to growth. But without complete execution of restructuring initiatives, these efforts may result in nothing more than window-dressing.

Building the data-centric organization

Regulators are demanding greater transparency; customers are seeking a more relevant and targeted experience, and bank management is looking for growth opportunities. The common element in all of these is data. Effective data management has been elusive for the banking industry, and with good reason. Technology silos and exploding volumes of data make this a daunting effort.

Some banks are beginning to fundamentally reshape their data management capabilities, from the lowest levels of data architecture to the more sophisticated uses of analytics for customer decisioning and risk management. These initiatives are likely to continue to grow within the industry: too many forces are combining to compel bankers to move in this direction. Indeed, for many, their very survival depends on it.

What's new for 2013

"Big data" has been the most popular new trend in financial services technology over the last 12 to 18 months. More than ever, look for bank leaders increasingly to embrace the massive effort involved in restructuring their ability to manage and utilize data. Master data management, data hygiene, and the application of increasingly more sophisticated analytical tools should continue to be important initiatives for leading banks in the coming year.

Bottom line

The financial services industry is becoming a technology business, whether leaders care to admit it or not. As such, the effective and creative utilization of the massive amounts of data that banks have could become a characteristic of future winners and losers in the industry.


Earning back the trust

The economic environment has spurred the elimination of "free" checking products as well as limits on debit card fees imposed by the Durbin Amendment, the creation of more standardized mortgage products, and a massive effort to resolve bad debt and reduce loan loss provisions. Many of these efforts have helped banks improve their profitability, but have done nothing good with respect to their reputation in the minds of their clients. To compensate, banks have increased their push to improve service as a way to recapture the public's trust. This is not a new strategy, but there are new forces emerging that bring the need for attention to service into high relief.

What's new for 2013

With the advent of the Consumer Financial Protection Bureau's (CFPB) complaints database, good customer service is not just good business, it's also become essentially a regulatory mandate. The attention to fee-based products and services, which services and products to offer, the creation of the concept of a "qualified" mortgage, and the continued use of social platforms as a very public outlet for client dissatisfaction are forcing bankers to raise their game. The coming year likely will see increased efforts around the development and delivery of clear disclosures, streamlined and consistent processes, and development of training and compensation to reinforce proper sales behaviors.

Bottom line

Banking executives should deal with the current reality that their product set is commoditized, and most of the low-hanging fruit related to cost containment has been captured. As such, bank leaders should focus on driving differentiation – and excellence – in servicing clients in 2013. This will not only support bankers' need to comply with consumer protection regulations, but also can help retain and grow their customer base on a zero-sum market.

Investing in improved operations at reduced cost

As with previous economic downturns, executives have doubled down on cost reduction to protect margins. Unfortunately for them, previous attempts to streamline through reengineering and outsourcing have virtually eliminated many of the more obvious opportunities to reduce cost.

That said, technology-based strategies are gaining favor not only to improve margins, but also to improve overall performance. For example, analytic and workflow technologies are being applied in commercial and mortgage lending operations to reduce manual handling. Case management tools allow client-service staff to more efficiently serve a larger number of inquiries. And new technology platforms are gaining favor as a way to enable new capabilities quickly at lower cost.

It's not as if bank executives haven't thought about this issue. In Deloitte & Touche LLP partner Carol Larson's view, "They are stuck with an IT nightmare. It is just so costly both in dollars and process disruption to make a big change, and by the time you have done it, there is something new and different and better. And so long-term, they should consider how their IT strategy enables or obstructs the enterprise's strategic vision, how much are they willing to spend, how important is it to get to that vision and how will they go about doing that?" Additionally, bankers likely need to pay attention to risk management as it pertains to its technology vendors, as this has also come under some scrutiny from regulators.

What's new for 2013

Cloud computing is increasingly becoming accepted as a platform for delivery of services within the banking industry. As senior bank technology leaders consider their platforms within the context of business strategy, they will make decisions regarding those solutions that are key differentiators for their business, and retain those in-house. Meanwhile, technology platforms that support important, but not strategic, capabilities are expected to be delivered by third parties through software as a service (SaaS) and other cloud-based delivery platforms.

Bottom line

Irate customers, aggressive regulators, and the realities of their own bottom line could likely drive bank executives to reenergize efforts around performance improvement. Investments will be required to meet compliance mandates, repair damaged reputations, and intelligently restructure.


Compliance: A business as usual approach

As the implications of the passage of Dodd-Frank and its attendant focus on bank safety and soundness become more clear, banks will look to move to compliance as a "business as usual" activity, rather than a series of isolated regulatory responses. This is part of a larger effort to improve business and operational performance that has been an ongoing initiative for at least the past few decades.

With that as the backdrop, there are more current and pressing challenges. Chief among these is the establishment of the CFPB. This agency will compel banks to spend a great deal of time and resources in the coming year on all aspects of consumer protection: that product disclosures are clearly worded, that customer complaints are addressed in a fair and expeditious manner, and that employees are empowered to make decisions in the best interest of the customer.

What's new for 2013

In conversations with bank leaders, we have found that the CFPB is one of their chief concerns heading into 2013. Already, civil money penalties and customer restitution requirements have been assessed on lenders, and the establishment of the Consumer Complaints Database will likely spur an increase in activity over the next year. "The CFPB is going to drastically affect the processes by which products are sold, the service of inquiries is handled, and by which punishment is extended... and I think it's going to be pretty radical," says Adam Schneider, principal, Deloitte Consulting LLP and chief advisor to the Deloitte Center for Financial Services.

Bottom line

The combination of the enforcement actions coming from the CFPB and the "operationalizing" of compliance in general should be viewed by banks as an opportunity to gather more voice-of-the-customer input, redesign processes to improve client experience, and reduce the "fire drill" aspects of regulatory compliance.

Securing the foundation to move forward

Market realities and regulation is expected to continue to force banks to address weaknesses in their risk management capabilities. This is being driven now by ongoing regulatory initiatives regarding stress testing and the development of recovery and resolution plans – so-called "living wills." Alongside regulatory compliance mandates, recent fraud incidents that are internal to the bank require increased focus on three-tiered risk management approaches.

Loss or theft of customer data continues to challenge bank leadership. Measures to combat identity theft have a shelf life of weeks until a new attack vector has been identified. On the credit risk front, slow but steady increases in demand for consumer loans mandate improved credit underwriting capabilities, hopefully building upon lessons learned from the past. With regard to counterparty risk, the search for broader, more profitable relationships with corporate customers entails a more holistic view of the client's stability. Risk management will therefore continue to be a major program for investment in the coming year.

What's new for 2013

The need for more effective management of technology-based risk is becoming apparent. On the back end, banks continue to operate fragile, undocumented legacy systems that are increasingly prone to operational failure. On the front end, bank websites have experienced a rash of service interruptions due to a variety of attacks, whether motivated by political agendas or the more typical theft of customer data. Bank technology and business leaders should take action to secure the operational stability of their operating platforms in the face of these risks.

Bottom line

Bank leadership should take appropriate steps to embed and operationalize a more risk-intelligent culture throughout their organizations. "In light of everything that's happened, most organizations now, at least culturally, understand that risk management is not solely the responsibility of the risk management function, it is a bank-wide responsibility," says Scott Baret, partner at Deloitte & Touche LLP.


Dealing with disruptors in the payments business

Processing of payment transactions for both corporate and retail customers has increasingly become electronic over the past several years. This has reduced margins while increasing operational and fraud risk. At the same time, new competitors – both large firms like Apple and Google, as well as smaller startups like Square and Dwolla – are looking to disrupt the status quo. For defensive reasons, if not in search of new markets, more banks are likely to invest in emerging electronic payment platforms such as person-to-person (P2P) payments, supply chain finance, and mobile POS payment technologies.

What's new for 2013

While not new per se, bankers' interest in the potential for mobile payments is expected to continue to grow in 2013. We have seen a number of initiatives develop between banks, mobile network operators, technology firms, and even emerging innovators. Banks are therefore anticipated to increase the level of investment in mobile payments in many of its form factors: P2P, near-field communications-based payments at the point of sale, mobile wallet technologies, mobile remote deposit capture, and bill pay applications.

Bottom line

Mobile payments have the potential to disrupt the traditional triumvirate of card issuers, payment networks, and merchant acquirers that has long been dominated by the banks. This should increase the need for banks to forge partnerships with a new kind of third party, quite different from the traditional outsourcers with whom they have become used to dealing.

Creating the digital bank

No discussion of operational transformation and data governance is complete without the accompanying effort to rationalize and streamline the overall technology infrastructure. Many large banks have ignored the reality that they are supporting a combination of redundant applications, aging technologies, and systems that support a declining level of usage (think: check reader/sorters) that are the result of incomplete merger acquisitions and a prevailing "if it isn't broken, don't fix it" mentality.

These inefficiencies should be rationalized, not only in recognition of the narrower margins in the business, but also because these systems in many cases do not support the kinds of front-office digital services that their customers are demanding from them.

What's new for 2013

According to Max Bercum, a principal at Deloitte Consulting LLP, "20 million new customers are expected to be entering the system over the next three to four years, looking to establish banking relationships. These customers use their mobile devices (smart phones and tablets) constantly to text, browse, and navigate their worlds." Unfortunately, many executives are expected to favor adoption of a "wait and see" approach to many digital services. However, some leading institutions are making meaningful investments in this area, and may begin to reap the benefits in the coming year.

There are banks that are beginning to utilize Facebook in a number of different ways, even to the point of allowing their customers to check balances, make transfers, and pay bills via a banking plug-in to their Facebook account.

Bottom line

Bankers should think about how to intelligently rationalize their technology costs so that they can build the bank of the future while maintaining an efficient bank of the present.


Remodeling business structures

A careful assessment of the impact of regulation, combined with strategic repositioning, may drive a variety of mergers and divestitures across the banking asset scale. A number of banks have spent the last decade acquiring assets, and entire businesses, that are now being re-evaluated for their long-term attractiveness. Now it is possible that many of these acquisitions will be deemed non-core and thus the pace of divestitures – and acquisitions – likely will reshape the competitive landscape as a result. Larger, more complex firms are thus anticipated to become more streamlined and focused, while mid-tier institutions may add products and/or geographies to build scale. Deborah Bailey, banking and securities regulatory managing director at Deloitte & Touche LLP, notes, "I am more convinced about strategic dominance in certain areas by financial institutions. In the foreseeable future, banks may move away from the strategy of being everything to everybody."

But remodeling is not limited to the choices pertaining to lines of business or geographies. Already there have been leadership changes at the top of many banks, and this trend may continue in 2013. The resulting emergence of new perspectives may allow these new leaders to reenergize their organizations, engage with regulators and clients, and set the longer-term strategy for growth.

What's new for 2013

At the lower end of the market, the pressures of increased capital requirements and costs of compliance may drive community banks to sell out, thereby resulting in an unintended consequence of new regulations. According to Brian Johnston, banking and securities consulting lead and principal, Deloitte Consulting LLP, "As the cost of regulatory compliance continues to take its toll, some community banks and smaller regional banks may decide to consolidate or sell out." Additionally, the equity markets have indicated their opinions as to the value of individual banks, as some institutions are still trading far below book value. These valuations may also contribute to consolidation.

Bottom line

A return of focus within the banking industry will necessarily result in some level of self-inflicted disruption. But institutions that have a clear strategy and a strong balance sheet may be able to take advantage of market disruption to separate themselves from the competition.

Desperately seeking growth

The opportunities for growth are likely to remain constrained for the coming year. However, some bright spots may emerge. As the economy improves, the corporate and institutional markets may provide some opportunity for revenue growth. For example, growth in demand for middle-market commercial lending and corporate transaction services continue to be a bright spot.

In the retail segment, banks continue to focus on their best customers – the mass affluent – with a variety of high-touch and self-service products and tools. The caution here is that many banks are turning their focus to the top 20 percent of the retail client base, the competition for which likely will drive down margins for everyone.

What's new for 2013

An emerging rebound in the real estate market could also drive some growth in residential mortgage lending. However, there is a concern among bankers that in the push to simplify mortgage products, the establishment of a "qualified" mortgage by the CFPB might, in fact, compel some lenders to exit the business. Kevin Blakely, senior advisor to Deloitte & Touche LLP, sees that "there is extreme nervousness within the industry about the definition of a qualified mortgage, which I think is going to have a significant impact on consumer borrowing in 2013 and beyond."

Bottom line

Growth is likely to be hard to come by in 2013. Much depends on the state of the U.S. economy and the prospects for a resolution to the European economic situation. Absent a more broad-based recovery, then, banks should continue their efforts in understanding their clients better and developing combined offerings to capture a greater share of the relationship. Unfortunately, this is a zero-sum game and thus significant movement may be unlikely to occur.


Not one of the actions listed above is new, with the possible exception of the disruptive challenges of new innovators in the mobility sector. For many banks, the coming year may see merely a re-attempt at old strategies that were used during previous economic downturns: cost cutting, a focus on more profitable customers, and investments in compliance. Jim Reichbach, Deloitte Touche Tohmatsu Limited global banking and securities leader and a principal at Deloitte Consulting LLP, puts it this way: "I think the banks have to decide, is this cyclical or is this structural, and if you think that it is structural based on their unique business mix, then act like it. Do something, be more dramatic."

We will be able to discern the emergence of a few institutions that really do take on the hard work of legitimate restructuring, repositioning, and rebranding – perhaps not in all areas, nor all at once. Those few may by their actions and resulting competitive success, lead the more conservative fast-followers.


1 As used in this document, "Deloitte" means Deloitte LLP and its subsidiaries. Please see for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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