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The Hamilton Financial Index:

A semi-annual report on the state of our financial services industry
February 2012 With a review of the economic impact of the Durbin Amendment
About Hamilton Place Strategies Hamilton Place Strategies is a consultancy based in Washington, DC with a focus at the intersection of business and government. HPS Insight conducts indepth analysis on public policy issues.! This report was prepared under the direction of Matt McDonald, a partner at HPS. Prior to HPS, Matt was a consultant for McKinsey & Co., an aide to President Bush and served as an advisor to senior leaders in both government and business. He received his MBA at the MIT Sloan School of Management and has a degree in economics from Dartmouth College.! Patrick Sims and Russ Grote of HPS conducted the analysis contained in this report.
Introduction
! Americas financial institutions are significantly safer and stronger than in years past. Both banks and insurance companies are well capitalized, addressing ongoing risks and are in a strong position to deliver value and support to the economy as the recovery continues. Our financial services often exist as a backdrop to our lives, with not much thought beyond the swipe of a card. We may not realize it, but financial services firms have changed significantly since 2008 and are stronger for those changes. This is not to say that todays economic climate is without challenges. U.S. financial institutions and the global economy are still recovering and there remain issues to work through. This is the first in a series of semi-annual reports to coincide with the Federal Reserve Chairmans Humphrey-Hawkins testimony before Congress. The aim of these reports is to provide a clear evaluation of the safety and soundness of the financial services sector and the value it provides to the economy during the crisis and the ongoing recovery. This report introduces the Hamilton Financial Index, a snapshot of both risk in the system and how firms are meeting the challenge. We also look at regulatory issues and the intended and unintended impact on the financial sector and the economy. The regulatory spotlight begins with a look at the outcomes of implementing the Durbin Amendment. This report has been commissioned by the Partnership for a Secure Financial Future. It was prepared independently by Hamilton Place Strategies, and the conclusions contained in this report are our own. Hamilton Place Strategies
Matt McDonald Partner
Hamilton Place Strategies | 1
CONTENTS
THE HAMILTON FINANCIAL INDEX4 A new index to measure both risk within the financial system and how firms are dealing with that risk. SAFETY AND SOUNDNESS .10 A look at how our financial services sector has rebuilt after the crisis and how they are meeting current challenges. VALUE TO THE ECONOMY 22 An examination of the everyday value that financial services bring to our lives, as well as an in-depth look at how the sector is supporting the economy during the recovery. REGULATORY SPOTLIGHT DURBIN AMENDMENT.42 An exploration of the intended and unintended consequences of the implementation of the Durbin Amendment to impose price controls on interchange fees.
2 | The State of Our Financial Services
Executive Summary
Overall, the financial sector has made remarkable changes to strengthen itself against ongoing risks. It continues to provide robust value to the economy while simultaneously addressing the exogenous economic challenges in the current environment. The key findings of the report are: The new Hamilton Financial Index, which measures the safety and soundness of the financial services industry, has risen since the crisis. It is now 15 percent above normal levels of safety and soundness. US commercial banks Tier 1 Common Capital levels are at an all-time high and the ratio of loans to deposits has declined 20 percent since 2007, pointing to a strong foundation for higher levels of lending. Insurance firms Capital and Surplus are also at all-time highs despite an increase in unexpected expenses from natural disasters in 2011. Insurance companies had record payouts to the many individuals who suffered from natural disasters in 2011. While business loans have lagged due to a slow recovery, consumer loans increased dramatically during the recession, helping individuals weather the crisis. The private sector continued to reduce outstanding debt in 2011, declining 17 percent from the highs. The total U.S. retirement market is valued at $17 trillion, an increase of 21 percent since 2008. Lastly, our regulatory spotlight found that in the first four months of the Durbin Amendments implementation, consumers have seen no decline in merchant prices and reduced account benefits from their debit cards. Foreseeable but unintended consequences of this regulation have resulted in a clear loss of value for consumers.
The Hamilton Financial Index:

What is the appropriate capital level for a financial institution to hold in order to absorb losses resulting from unexpected shocks to the system? This question comes up frequently and is heavily debated. Industry professionals ask the question from a performance standpoint what level of capital can we hold, but still remain profitable? At the same time, lawmakers look to regulations to increase industry-wide safety. It is important that both industry and regulatory leaders come together to figure out what is appropriate, and mitigate any unintended consequences. Rarely does one look at how much risk there is in the system and compare it to another metric such as capital. More often, they are viewed as separates. However, placing the two together is increasingly seen as a key measurement of the safety and soundness of the financial services industry. Therefore, the Hamilton Financial Index combines both systemic risk and capital levels into one index to provide a snapshot of the safety and soundness of the financial sector. The results show a significantly safer financial sector with an index value 15 percent above normal levels (Exhibit 1).
A Snapshot of Firm and Systemic Risk

Key Findings: The Hamilton Financial Index combines firm-level and systemic level views of risk to show an overall snapshot of risk within the Financial Services Sector The Hamilton Financial Index value exhibited normal levels around a value of 1 prior to the financial crisis At the end of 2011, the Hamilton Financial Index was at 1.15, dramatically up from crisis levels of 0.46 and 15 percent above even normal precrisis levels
!
Exhibit!1 !
HAMILTON FINANCIAL INDEX SHOWS BANKS SAFER THAN PRE-RECESSION!

Hamilton Financial Index!
1.50!
1.25!
The Hamilton Financial Index shows banks are safer than anytime prior to the recession despite a recent dip due to stress from Europe.!
1.24! 1.15!
Index Value!
1.00!
0.75!
0.50!
0.46!
1994!
1995!
1996!
1997!
1998!
1999!
2000!
2001!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!
Source: HPS Insight, St. Louis Federal Reserve, SNL Financial!
Methodology
The Hamilton Financial Index is measured by using two commonly accepted metrics: 1. The St. Louis Federal Reserve Financial Stress Index captures 18 market indicators and is a well-established indicator of financial stress 2. Tier 1 Common Capital Ratio for commercial banks measures financial institutions ability to absorb unexpected losses in an adverse environment To get the index value, we simply subtract the quarterly average of the Financial Stress Index from the quarterly Tier 1 Common Capital Ratio for the commercial banking industry. In order to index the values, we used the first time-series data point, the first quarter of 1994, as the divisor for all periods. This set the first data point equal to one. Therefore, all data points are relative to the value of one. The value of one also happens to be the average of all time periods from the first quarter of 1994 to the fourth quarter of 2011. Observed values around one are consistent with the historical norm of a safe financial industry.
2011!
0.25!
St. Louis Fed Financial Stress Index

The first variable in the Hamilton Financial Index is the St. Louis Financial Stress Index, which combines 18 market variables segmented into three sections: interest rates, yields spreads and other indicators. Interest rates help determine the markets assessment of risk across a number of different sectors and time periods. High interest rates represent an increase in financial stress. The interest rates in this section are: Effective federal funds rate 2-year Treasury 10-year Treasury 30-year Treasury Baa-rated corporate Merrill Lynch High-Yield Corporate Master II Index Merrill Lynch Asset-Backed Master BBB-rated
Yield spreads help determine relative risk across time and space. For example, the Treasury-Eurodollar (Ted) and London Interbank Offering RateOvernight Index Swap (LIBOR-OIS) spreads capture risk not just in the U.S., but also throughout the globe. A higher yield spreads suggest greater systemic risk. The yield spreads in this section are: Yield curve: 10-year Treasury minus 3-month Treasury Corporate Baa-rated bond minus 10-year Treasury Merrill Lynch High-Yield Corporate Master II Index minus 10-year Treasury 3-month LIBOR-OIS spread 3-month (TED) spread 3-month commercial paper minus 3-month Treasury bill
Other indicators fill in important pieces not captured by interest rates or yields. The Chicago Board Options Exchange Market Volatility Index captures the markets expectation of volatility with higher volatility associated with increased stress in the financial system. The indicators in this section are: J.P. Morgan Emerging Markets Bond Index Plus Chicago Board Options Exchange Market Volatility Index (VIX) Merrill Lynch Bond Market Volatility Index (1-month) 10-year nominal Treasury yield minus 10-year Treasury Inflation Protected Security yield (breakeven inflation rate) Vanguard Financials Exchange-Traded Fund (equities)
Each indicator captures an aspect of financial stress within the system with some overlap. Collectively, they provide a snapshot of systemic risk in financial markets.
!"#$%&'()$*+,$*(-.-/(.0$!"1+))$2-,+3$ 2001 2003 2004 2005 2006 2007 2008 2009 2010 2011 0.58 0.68 -0.27 -0.68 -0.98 0.40 4.82 3.73 0.56 0.88 0.12 -0.09 -0.65 -0.82 -1.04 -1.12 0.93 0.58 0.18 -0.07 0.28 0.28 -0.44 -0.76 -1.01 -0.48 2.03 1.99 0.34 0.33
! !Tier 1 Common Capital, Risk-Weighted Assets and Tier 1 Common Ratio The second variable in the Hamilton Financial Index is the Tier 1 Common Ratio, which is calculated by taking the industrys Tier 1 Common Capital (numerator) as a proportion of its Risk-Weighted Assets (denominator). Tier 1 Common Capital acts as a cushion in case of unexpected losses. Therefore, any increase in Tier 1 Common Capital (numerator) improves safety and soundness, all else equal. Concordantly, any decreases in the holding of risky assets as measured by RiskWeighted Assets (denominator) will improve a banks capital position.
!"#$!!"#!!"##"$!!"#$%"&!!"#$! ! !"#$!!"#$%&!!"#$%"& !"#$%!!"#$!!"#$!!"#!!""#$"
High Low Average
Exhibit!2 !
CAPITAL LEVELS AND TIER 1 COMMON CAPITAL RATIO ARE AT AN ALL-TIME HIGH!
Tier 1 Common Capital and Tier 1 Common Risk-Based Ratio for US Banks! 14! Tier 1 Common Capital ($T)! Tier 1 Common Risk-Based Ratio (%)! 1.4! Tier 1 Common Capital Ratio has risen 36% since 2007 to an all-time high.! 1.2!
Tier 1 Common Risk-Based Ratio (%)!
12!
Tier 1 Common Capital ($T)!
1.0! 0.8! 0.6!
10!
8!
0.4! 2! 0!
6!
1992!
1993!
1994!
1995!
1996!
1997!
1998!
1999!
2000!
2001!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!
Source: FDIC, SNL Financial!
Tier 1 Capital is the core measure of a bank's financial strength from a regulator's point of view. It is based on core capital, which consists primarily of common stock and disclosed reserves. Tier 1 Common Capital is a more strict measurement than Tier 1 Capital in that it excludes preferred shares and minority interest, often seen by the industry as non-common elements.1
1991!
2011!
At the end of 2011, the banking industry had an aggregate Tier 1 Common Capital over $1.1 trillion and a Tier 1 Common Capital Ratio of 12.56 percent, an all-time high (Exhibit 2).2 The ratio boasts a remarkable 36 percent increase from its lowpoint in 2007, and a 51 percent increase from 1991, the first period on file. This increase follows a steady decline between mid-2006 to the crisis in the fall of 2008. Along with increases in Tier 1 Common Capital, Risk-Weighted Assets have declined. As a portion of Total Assets, Risk-Weighted Assets have decreased 11 percent since 2007, and continue to trend downward (Exhibit 3). Reduction of riskweighted assets over the past several years has lead to an overall increase to the Tier 1 Common Capital Ratio.
Exhibit!3 !
US COMMERCIAL BANKS HAVE REDUCED THEIR HOLDINGS OF RISK-WEIGHTED ASSETS!

Risk-Weighted Assets as a Percent of Total Assets for US Banks! 78! 75! 72! -11%!
Percent (%)!
69! 66! 63! 60!
2001!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!
Risk-Weighted assets are the portions of assets that are assigned a higher level of credit risk as per regulatory guidelines, and are the denominator in the Tier 1 Common Capital Ratio.
The combination of increased capital levels and reduced risky assets results in less leveraged and safer financial institutions. Per the FDICs Quarterly Banking Profile (Q311), At the end of the quarter, more than 96 percent of all FDIC-insured institutions, representing more than 99 percent of total industry assets, met or exceeded the quantitative requirements for well-capitalized status.3
The combination of increased capital levels and reduced risky assets results in less leveraged and safer financial institutions.!
2011!
The Hamilton Financial Index Summary

As of the fourth quarter of 2011, the Hamilton Financial Index was valued at 1.15, 15 percent above the historical norm. This value is down from a high of 1.24 in the second quarter of 2011, though significantly higher than the index bottom of 0.46 in the third quarter of 2008. We can see the decline in safety and soundness prior to the financial crisis. In mid-2007, before both the recession and the financial crisis, the index begins to dip below one. The index value declines to 0.82 in the quarter prior to the collapse of Lehman Brothers in the third quarter of 2008.
Unlike prior to the crisis, current capital levels are at an all-time high and stress has been reduced, although not completely. The St. Louis Federal Reserve Stress Index showed higher levels of stress during the debt ceiling negotiations and the European crisis. These events caused the Hamilton Financial Index value to drop, despite high capital levels in recent quarters. If market stress subsides, we expect the index to increase back toward all-time highs. The Hamilton Financial Index weighs both the level of risk in the financial system and the amount of capital financial institutions hold to deal with that risk. Importantly, it shows that financial institutions are in a better position today than they were even in the years prior to the crisis.
Financial institutions are in a better position today than they were even in the years prior to the crisis.!
Safety and Soundness:

Foundation for Growth
Bank capital levels and systemic stress indicators provide a helpful look into how effectively financial institutions can mitigate market risk. The Hamilton Financial Index outlined in section one illustrates the achievements of the industry since the crisis. In addition to these metrics, this section outlines other important indicators that measure the safety and soundness of the financial services industry. The Loan-to-Deposit (LTD) Ratio measures a bank's liquidity. Our observations of changes in this ratio indicate that the industry is more safely funded by a higher proportion of deposits and less reliant on other borrowings than prior to the crisis. The industry is now more liquid than in years past. This section also outlines key performance measures for financial services firms, and goes on to evaluate additional metrics for the insurance industry, namely Property & Casualty (P&C) and Life & Health (Life) sectors. Observations in these industries also indicate a strong recovery, and in some cases, the data illustrates that the industry is in better shape than in pre-crisis periods.
Key Findings: Banks core funding has increased as Loan-toDeposit ratios has fallen 20 percent since 2007 Property and Casualty and Life Insurers have increased their Capital and Surplus levels 16 percent and 25 percent respectively, since 2008 US financial institutions have significantly reduced their exposure to Europes periphery during 2011, including a 34 percent reduction in exposure to Spain
!
Finally, this section details potential impediments to growth and stability, addressing the impact of catastrophic events on the insurance industry, deterioration of asset quality in bank lending and financial institution exposure to the European crisis. Overall, the current snapshot of the financial sector shows the industry moving quickly in the right direction to protect all of us from further shocks.
Loan-to-Deposit (LTD) Ratio

How banks and financial institutions receive their funding is an issue that receives constant attention, and rightly so. In the event of a liquidity crisis, the ability to fund operations bears the key to survival. Liquidity was a central challenge for firms during the 2008 crisis. A simple examination of the banking industrys LTD Ratio is a common measure of liquidity. The LTD Ratio assesses a banks liquidity. Deposits are considered the core funding of a banks operation. Therefore, a higher LTD ratio means that a bank might not have enough liquidity to cover any unforeseen fund requirements. A lower ratio may indicate that a bank is not earning as much as it could. Balance is necessary.
In regards to liquidity, banks are now in a much safer place and poised to lend at higher levels as the economy grows.!
From 2000 to 2008, the banking industry had an average LTD Ratio of 88.58. It reached its peak in 2007 at 90.65. Due to an increase in deposits and lower amount of loans, the ratio now sits at 72.53, a 20 percent decrease from pre-crisis highs (Exhibit 4). In regards to liquidity, banks are now in a much safer place and are poised to lend at higher levels as the economy grows
Exhibit!4 !
CORE FUNDING INCREASES AS LOAN-TODEPOSIT RATIO FALLS 20% SINCE 2008!

Total Loans as a Percent of Total Deposits for US Banks! 100! 95! 90! 85! -20%!
Percent (%)!
80! 75! 70! 65! 60! 55!
2000!
2001!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!
2011!
50!
Insurers Capital & Surplus (C&S)

Although the financial crisis affected banks more than most industries, the insurance industry also suffered due to the market downturn. At the time of the financial crisis, outside of insurance companies with a high degree of exposure to mortgage securities, such as AIG, the U.S. International Trade Commission considered the insurance industry one of the healthier subsectors of the financial institutions industry.4 One commonly accepted way to measure the capitalization of the insurance industry is with the metric Surplus as Regards to Policyholders, known as Capital and Surplus (C&S). The Property & Casualty Insurance sector (P&C), which includes reinsurance companies, maintains high C&S levels despite a series of catastrophic events in 2011 caused by natural disasters. As of the third quarter, the aggregate Surplus value was $535.4 billion, a 16 percent increase compared to 2008 when it was at $461.8 billion (Exhibit 5). Given the nature of the industry, the Life Insurance sector (Life) had less exposure to losses from catastrophic events in 2011. As of the third quarter of 2011, the Life Insurance sector had C&S of $313.6 billion, the highest on record. Moreover C&S as a percentage of assets bounced back rapidly during the crisis and currently stands 12.5 percent above the crisis low-point and slightly above its pre-crisis levels (Exhibit 6).
Exhibit!5 !
P&C INSURERS REBOUNDED QUICKLY FROM THE RECESSION, AND NEVER FELL BELOW 2002 LEVELS!
Surplus and Capital of P&C Insurers!
38 38!
Surplus as Regards to Policyholders ($B) ! Capital & Surplus/ Assets (%)! 600! 550! 500!
Capital and Surplus as a % of Assets (%)!
36 36! 34 34!
32! 32
30 30!
Total Surplus ($B)!
450! 400! 350! 300! 0!
28! 28
26 26! 24 24!
22! 22
2001!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!
Source: NAIC, SNL Financial!
Surplus as Regards to Policyholders represents the difference between the statutory admitted assets and the statutory liabilities. Surplus is viewed as the net financial resources available to support growth.
Exhibit!6 !
LIFE INSURERS CAPITAL AND SURPLUS HAS RISEN SINCE 2008 !

Capital and Surplus Levels and Ratio for Life Insurers! 10! 9! 8! Surplus as Regards Policyholders ($B)! Capital & Surplus/ Assets (%)! 325! 325 300! 300 275! 275
Percent (%)!
2011!
20 20!
Dollars ($B)!
250! 250 7!
225 225!
6! 5! 200! 200 175! 175
2001!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!
2011!
150 150!
Rebound in Performance
Beyond capital levels, commercial banks and insurance companies market performance is critical to ongoing safety and soundness. Improved performance allows banks to raise more equity. And, if a financial institution can more easily raise capital, it will be able to provide more lending to businesses and consumers. Bank Net Income, Return on Average Assets (ROAA) and Equity (ROAE) The banking and insurance industries are not only well capitalized, but their ability to increase net income provides extra cushion in the event of an unexpected crisis.
! For banks, 2008 and 2009 were frightful times. Bank Net Income took a nosedive in 2008, going from $97.5 billion in 2007 to just $15.1 billion in 2008. While still profitable in 2008, the industry eventually took on the full-effect of the financial crisis and saw red in 2009 with a Net Income of negative $11.7 billion. Since then, the industrys recovery is well underway. Bank Net Income in 2010 was $77.6 billion and $109.6 billion in 2011, just shy of its 2005 level (Exhibit 7).
Exhibit!7 !
Improved performance allows banks to raise more equity. And, if a financial institution can more easily raise capital, it will be able to provide more lending to businesses and consumers.
PERFORMANCE MEASURES BOUNCED BACK QUICKLY FROM 2009 LOWS!

Return on Average Assets and Equity for US Banks! 16! 14! 12! ROAA (%)! ROAE (%)! Net Income ($B)! 150! 125! 100!
Percent (%)!
10! 8! 6! 4! 2! 0!
Dollars ($B)!
75! 50! 25! 0!
2000!
2001!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!
2011!
-2!
-25!
Insurance Net Income, Return on Average Assets (ROAA) and Equity (ROAE) P&C Insurance Net Income also took a major hit in 2008. As previously discussed, the insurance industrys operations differ from that of banking (lending), and therefore the P&C industry did not experience a Net Income loss from the financial crisis. The industry did, however, see Net Income plummet from $63.6 billion in 2007 to just $3.7 billion in 2008 due to losses in investment holdings. The industry began to recover in 2009 and 2010, with Net Income of $32.2 and $37.2 billion, respectively. Following that, 2011 was a year filled with catastrophic events on a historic and global scale that eroded insurers earnings. While still profitable and above crisis levels, 2011 Net Income is well below pre-crisis levels (Exhibit 8).
Exhibit!8 !
DESPITE A STRONG REBOUND, DISASTERS IN 2011 REDUCED PROFITABILITY FOR P&C INSURERS!
Net Income and Return on Average Assets and Equity for Insurers! ROAE (C&S) (%)! ROAA (%)! Net Income ($B)! 80! 80
15!
12!
60! 60
Percent (%)!
9! 40! 40 6! 20! 20
Dollars ($B)!
3!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!
2011!
0!
0! 0
While the P&C sectors income remained positive in 2008, the Life sector did not. Industry Net Income dropped to a negative $52.3 billion in 2008 from a positive $31.6 billion in 2007. The recovery took place in 2009 with Net Income roaring back to $21.5 billion and again to $28.0 billion in 2010 (Exhibit 9). Volatility in the markets contributed to lower earnings in 2011, but the industry is expected to stay profitable and stable based on strong balance sheet fundamentals cited above.5
Exhibit!9 !
RETURNS AND NET INCOME HAVE IMPROVED SINCE 2008 FOR LIFE INSURERS!
ROAA, ROAE and Net Income for Life Insurers! 20! 15! 10! ROAE (C&S) (%)! ROAA (%)! Net Income ($B)! 60! 40! 40
Percent (%)!
5! 0! -5! -10! -15! -20!
20 20!
Dollars ($B)!
0! 0
-20 -20! -40 -40! -60 -60!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!
Potential Roadblocks to Growth and Stability

Based on the Hamilton Financial Index and the supplementary metrics outlined in this section, the financial services sector has improved its balance sheet and is in a significantly better position to absorb any unexpected shocks. While these indicators are useful in providing a high-level view of systemic risk, we can also look more closely at the performance of assets on a banks books and gauge the amount of risk still in the system. Outlined below is an examination of the potential impact of catastrophic events, noncurrent loans, specifically in real estate, and the European debt crisis on the financial industry. While these risks are important to monitor, as discussed above, financial institutions ability to handle shocks has never been better.
2011!
Catastrophic Events Losses associated with tornados in the South and Midwest were labeled by the Insurance Information Institute as the fifth-costliest catastrophic event in U.S. history. Hurricane Irene and several other natural catastrophes across the globe, such as the Japanese earthquakes, also contributed to the highest combined losses in While these risks are industry history. Industry losses were relatively offset by the large amount of premiums being written, but it was nonetheless a tumultuous year of natural disasters.
important to monitor, as discussed above, financial institutions ability to handle shocks has never been better.!
A year-end industry report by Fitch Ratings, a global credit ratings agency, stated that events in 2011 led to the highest loss experienced since 2005, the year of Hurricanes Katrina, Rita and Wilma. Still, the industry is expected to recover in 2012 through a return to underwriting discipline and improved earnings. Fitch assigned the P&C industry a stable outlook.6 Asset Quality Noncurrent Loans & Charge-offs At the beginning of the 2008 financial crisis, loans with poor credit quality began to default, and banks began to face liquidity and solvency issues. While the Troubled Asset Relief Program (TARP) has turned a profit for taxpayers and helped rid banks of many risky assets, the sluggish recovery has continued to take a toll on the quality of loans. More specifically, as housing prices continue to fall wiping out home equity, unemployment and stagnant wages make it difficult for individuals to pay debts. Therefore, a continued concern is whether a significant amount of these loans may still be on banks books. We can look at some aggregates to partially gauge banks success in cleaning up their balance sheets. The industry measures the amount of loans at risk of defaulting by calculating the amount of Noncurrent Loans as a percent of Total Loans. Noncurrent Loans are loans that are behind on the payment schedule and are at greater risk for default. As a portion of Total Loans, Noncurrent Loans were at a low of 0.75 percent in 2005. In 2008 the industry reached a point where the ratio was closing in on three percent, a level not seen since the early 1990s when the banking industry was recovering from the Savings and Loan Crisis of the late 1980s (Exhibit 10).
Exhibit!10 !
NONCURRENT LOANS AS A PERCENT OF ALL LOANS ARE IMPROVING ACROSS THE BOARD!
Noncurrent Loans as a Percent of Total Loans for US Banks! 8! 7! 6! Total Real Estate Loans! -12%! Total Real Estate Loans (%)! "Total Loans & Leases (%)! Total Non-Real Estate Loans (%)!
Percent (%)!
5! 4! 3! 2! 1!
Total Loans!
-27%!
Total ! Non-Real Estate! Loans!
-55%!
2001!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!
!"#$"%&!!"!!"#$%&&'#(!!"#$% !
!"#$% ! !"!!"#$!!"#$!!"# ! !"#$%%&'$(!!"#$% !"#$%!!!"#$
2009 was the peak of distress and Noncurrent Loans represented 5.6 percent of Total Loans outstanding. As banks began to work through these loans by restructuring and charge-offs, the industry began to recover. As of the end of 2011, the percent of Noncurrent Loans sits at 4.1 percent, a 27 percent decrease from the 2009 high. Although the level of Real Estate Loans that are Noncurrent is also below the 2009 highs, the overall level still remains above industry norms. These loans have only been reduced by 12 percent from their peak and still stand well above pre-crisis levels at 6.8 percent. Moreover, Charge-offs on these types of loans never reached the level of Non-Real Estate Loans. These aggregates suggest that banks, while making progress, are still exposed to risks in this market (Exhibit 11).
2011!
0!
Exhibit!11 !
TOTAL CHARGEOFFS AS A PERCENT OF TOTAL LOANS PEAKED IN 2010!

Net Charge-offs as a Percent of Total Loans for! US Banks! Net Charge-offs/Avg Loans: Real Estate (%)! Net Charge-offs/Avg Loans Non-Real Estate (%)!
4 4!
3! 3
Percent (%)!
2! 2
1 1!
2000!
2001!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!
Net Charge-offs (NCOs) are the dollar amount representing the difference between gross charge-offs and any subsequent recoveries of delinquent debt. !"#$"%&!!"!!"#!!!!"#$!!""# ! !"#!!!!"#$!!""#!!"!!"#$% !"#$%&#!!"#$%
In sum, the aggregates suggest that banks have worked through some of the bad loans on their books, but high levels of Noncurrent Real Estate loans show there is still exposure. European Distress U.S. Exposure to Europe Although U.S. financial institutions have begun to pave a path to recovery, it is possible that over-exposure to European debt could lead to financial contagion in the event of a significant crisis. Beginning in 2010, Greeces sovereign credit rating was downgraded by several ratings agencies. Sovereign credit ratings of several other European countries were also downgraded, namely those of Portugal, Ireland, Italy and Spain. Other countries around the globe also saw their sovereign credit rating downgraded, including the U.S.
U.S. banks have altered their portfolios to reduce their exposure to Europes risky assets.!
2011!
0 0!
A number of actions have been taken place in recent periods to reduce both the likelihood and magnitude of a potential contagion event. While the European Central Bank and the International Monetary Fund have extended liquidity to help calm markets and avoid bank runs, U.S. banks have also altered their portfolios to reduce their exposure to Europes risky assets. While U.S. banks have increased their exposure to European countries by nearly 5.6 percent over the past quarter and nearly 10 percent since the start of 2011, U.S. banks have decreased exposure to the troubled periphery (Exhibit 12). The increase in exposure is focused on a few targeted countries, particularly Germany and Switzerland. Decreases occurred in Portugal (3.8 percent), Italy (3.8 percent), Ireland (8.7 percent), Greece (19.7 percent) and Spain (34.2 percent), among a host of others. Exposure to Spain saw the largest percentage decrease as of the third quarter of 2011.7
Exhibit!12 !
US FINANCIAL INSTITUTIONS HAVE REDUCED EXPOSURE TO THE EUROPEAN PERIPHERY!

Percent Change of Country Risk Claims from Q211 to Q311! 20! 10! 0! US nancial institutions have reduced their exposure to European periphery signicantly in 2011!
Percent (%)!
-10! -20! -30! -40!
Germany! United Kingdom!
France!
Italy!
Portugal!
Ireland!
Greece!
Spain!
Europe Total!
Source: FFIEC, HPSInsight!
Switzerland and Germany are seen as Europes safe havens. A flight to safety occurred over the last quarter as banks increased their exposure to these countries by 61.2 percent and 18 percent, respectively. The United Kingdom also saw a positive change of 8 percent (Exhibit 13). Overall, exposure to Greece is small. U.S. commercial banks have roughly 100 times less exposure to Greek risk claims than they do the United Kingdom. In fact, of total U.S. bank exposure to European claims; Germany, France and the United Kingdom account for 68 percent, while Greece accounts for less than 1 percent.
Exhibit!13 !
US BANKS HAVE LESS EXPOSURE TO THE EUROPEAN PERIPHERY THAN CORE!

Risk Claims ($B)! 0.229 - 206! 206 - 411.7! 411.7 617.4! 617.4 - 824!
Source: FFIEC, HPSInsight!
Data on non-U.S. exposures are reported on the Country Exposure Report (FFIEC 009). All data are on a fully consolidated basis and cover 71 U.S. banking organizations (including U.S. holding companies owned by foreign banks, but excluding U.S. branches of foreign banks). Respondents may file information on a bank only or consolidated bank holding company basis. The group of institutions responding to the quarterly survey consists of a panel of 71 U.S. banking organizations each holding $30 million or more in claims on residents of foreign countries.
Safety and Soundness Summary

Our analysis shows that while people may not be aware of the changes that have taken place, banks as well as insurance companies are significantly safer than in the years leading up to the crisis. The Hamilton Financial Index shows significant improvement. Loans and deposits have returned to healthier levels. Insurance companies, which were strong throughout the crisis, now have historically high C&S ratios despite record payouts for P&C insurers. The financial services sector is still working through troubled loans, and the European crisis continues to threaten recovery. While these concerns should be noted, the industry is clearly moving in the right direction and is stronger than any time in recent history.
Value to the Economy:

Safe Haven During the Recession
! The value of financial services is so integrated into our everyday lives that we often forget how highly developed and beneficial our system has become. In 1995, only 17.7 percent of households owned a debit card. Today, over 76 percent of households have cards8. Online banking was negligible ten years ago. Now, consumers have the ability to check balances and deposit checks on their smart phones. Weve come a long way in a short amount of time. Beyond consumer banking, the financial services sector contributes in a host of ways. Apples global supply chain needs banks to manage their foreign exchange. Our favorite time-waster, Zynga (gaming), requires an investment bank to underwrite its IPO so that it can raise more capital for a better version of Words with Friends. Insurance products are widespread and can protect our homes, cars and loved ones from unexpected tragedies. Retirement security has increased dramatically with the rise of new fund types, better life insurance and accessibility to expert advisory services.
Key Findings: Deposit accounts acted as a shelter during the recession as total deposits increased 25 percent from 2008 to 2011 Property & Casualty Insurers paid a record $350 billion annualized in claims through the third quarter of 2011, helping people cope with disasters The total U.S. retirement market reached $17 trillion by the third quarter of 2011, 21 percent above 2008 levels
! Covering all the benefits of modern financial services would take a library to explore. For this report, we will focus on the core functions of financial services: Serving as a financial shelter Extending credit to businesses and individuals Insuring against risks Saving for the future
Financial Shelters
The primary function of a bank is lending. In order to lend, banks take deposits; and in times of economic distress, these deposits are a shield from market volatility for individuals. Our analysis of the volume, composition and growth rates in deposits shows that U.S. bank deposits are seen as a safe haven in volatile times. Deposits as a Flight to Safety In the fall of 2008 the FDIC took steps to shore up the safety of consumer deposits by temporarily increasing insurance coverage up to $250,000 per depositor. In the spring of 2009, Congress extended the $250,000 insurance coverage through 2013; and in the summer of 2010, the extension became permanent. Even further, the Dodd-Frank Deposit Insurance Provision states that the FDIC will insure unlimited deposit amounts in non-interest bearing accounts until the end of 2012. Although the crisis has been quelled and strengthening the recovery is now the foremost issue, bank deposits are still increasing. Per 2011 year-end filings, bank deposits grew 8.5 percent to roughly $9.04 trillion from 2009 to 2011(Exhibit 14).
Exhibit!14 !
DEPOSITS CONTINUED TO CLIMB THROUGHOUT THE RECESSION AND RECOVERY!

Total Deposits and Total Core Deposits ! as a Percent of Total for US Commercial Banks! Core Deposits/Total Deposits (%)! Total Deposits ($T)! 10! 9! 90! 90 80! 80 8! 7! 6! +25%! 5! 4! 3! 2!
100 100!
Percent (%)!
Dollars ($T)!
70! 70 60! 60
50 50! 40 40!
2000! 2001! 2002! 2003! 2004! 2005! 2006! 2007! 2008! 2009! 2010! 2011!
30! 30
1! 0!
Many industry observers attribute the rise in deposits to a reaction to stock-market volatility, and see the increase in U.S. bank deposits as a flight to safety. There are several types of deposits that make up the total composition of deposits. The bulk of the deposit base is known as core deposits. These deposits are made up of accounts holding $250,000 or less, excluding brokered deposits. These deposits are
seen as highly liquid. Clients can add or withdraw with ease, and they cost little for a bank to hold. Core deposits are the basis for lending. The ratio of core deposits to total deposits was at a decade low of 61.4 percent in both 2007 and 2008. Core deposits at 2011 year-end now represent nearly 76.8 percent of the total amount for U.S. banks. There is no question that economic volatility and the increase in FDIC insurance coverage have influenced these values.
The market is giving the financial services industry a vote of confidence with regard to safety.
Although the increase in core deposits is a sign that individuals and businesses are taking less risk, it speaks well of U.S. banks, as the market is giving the financial services industry a vote of confidence with regard to safety. Deposit and Loan Growth Rates The dynamics between loan and deposit growth rates further illustrate the role deposits played during the crisis. The negative loan growth rate for 2009 and continued growth of deposits reflects the U.S. economic contraction. Loan growth was strong in the years leading up to the crisis, topping out at 16.98 percent in 2006 and 16.26 percent in 2007. In fact, loan growth outpaced deposit growth in both years (Exhibit 15).
Exhibit!15 !
LOAN AND DEPOSIT GROWTH RATES BOUNCE BACK POST-RECESSION !

Loan and Deposit Growth Rates for US Banks! 18! 18 Loan Growth Rate (%)! Deposit Growth Rate (%)!
16 16! 14 14!
12! 12
The economic slowdown in 2011 resulted in less demand for loans and more deposit growth.!
Percent (%)!
10 10! 8 8! 6 6! 4 4!
2! 2 0! 0
2000!
2001!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!
2011!
-2 -2!
During the financial crisis, this relationship reversed. Loan growth slowed to 6.23 percent in 2008, and then collapsed in 2009 to negative 0.83 percent. After an increase in 2010, loan growth dipped slightly throughout 2011. Meanwhile, the deposit growth rate increased over 14 percent in 2008 and stayed positive through 2011. As the economy continues to recover and loan demand increases, the rise in deposits will position U.S. banks to increase lending at growth rates seen in the years prior to the crisis.
Providing Credit
While banks safeguard money through deposits, which are insured up to $250,000, their primary purpose is to route savings into investments. By collecting small pools of idle money and lending to consumers and businesses for investment, banks solve a major coordination problem in economies. On the consumer side, loans are available for buying homes, purchasing automobiles and obtaining the necessary funds for education. Businesses use loans to aid in growth and expansion. Acting as boosts when the economy is growing, credit can also be a lifeline when the economy is faltering. An existing company may request a loan for the necessary funds to weather a crisis. Individuals may draw on credit to bridge financing gaps for essential needs. However, as credit helps to support an economy, high debt levels can endanger an economy. Prior to the recession, the U.S. private sector built up tremendous debt levels that left families and businesses underwater when the economy collapsed. This section will examine both the levels of credit provided to businesses and consumers, as well as private sector debt levels to evaluate the overall health of commercial banks credit provision.
Total Loans Total loans and leases for 2011 year-end were over $6.6 trillion, just below $6.84 trillion in 2008 but above 2009 levels.
Exhibit!16 !
REAL ESTATE LOANS HAVE CONTINUED TO FALL WHILE OTHER LOANS HAVE GROWN !
Total Loans from US Commercial Banks! 7! 6! 5! Total Real Estate Loans ($T)! Total Non-Real Estate Loans ($T)!
Dollars ($T)!
4! 3! 2! 1!
2000!
2001!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!
Loans outlined in Exhibit 16 are broken down into two main categories: Real Estate and Non-Real Estate. Given the weakness of the housing market, Real Estate loans have continued to decline. Meanwhile, Non-Real Estate loans rebounded quickly and are now above pre-recession highs. At the end of 2011, commercial banks held $3.1 trillion of Non-Real Estate loans, up from $2.7 trillion in 2009 and the prerecession peak of $3 trillion in 2008. A deeper examination of Non-Real Estate loans shows that consumer loans have been the main driver of growth (Exhibit 17). The two main categories of Non-Real Estate loans are Commercial and Industrial loans and Consumer loans. Consumer loans increased above pre-recession highs in 2010 and have slightly dipped in 2011. This trend within consumer loans is explained by the rise in credit card loans (Exhibit 18).
2011!
0!
Exhibit!17 !
CONSUMER LOAN GROWTH HAS DRIVEN NONREAL ESTATE LOANS TO NEW HIGHS !
Consumer Loans and Commercial and Industrial Loans ! for US Banks! 2.5! Commercial & Industrial Loans ($T)! Consumer Loans ($T)!
2.0!
Dollars ($T)!
1.5!
1.0!
0.5!
2000!
2001!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010! 2010!
Exhibit!18 !
CONSUMER CREDIT WAS EXTENDED TO AN ALLTIME HIGH DURING THE RECESSION!

Consumer Loans and Credit Cards Loans for US Banks! 1.5! Consumer Loans ($T)! Credit Card Loans ($T)!
1.0!
Dollars ($T)!
0.5!
2001!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
Source: FDIC, SNL FInancial!
2011!
0!
2011!
0!
This breakdown shows the role U.S. commercial banks play during a recession. Individuals still have bills to pay and families to feed. With reduced income, individuals require credit to get over the hump in bad times, and data shows U.S. commercial banks have dramatically increased credit to those in need. In fact, credit card loans rose to an all-time high over 2009 and have decreased as the economy slowly recovers. Business Loans As detailed above, a recession followed by a slow recovery will reduce the demand for business loans. Total business loans are trending up but have not quite reached their pre-recession peak (Exhibit 19).
Exhibit!19 !
TOTAL DOMESTIC BUSINESS LOANS HAVE INCREASED IN 2011 TO $1.9 TRILLION!

Total Domestic Business Loans for US Banks! 2.5! Total Domestic Business Loans ($T)!
2.0!
1.9!
Dollars ($T)!
1.5!
1.0!
2004!
2005!
2006!
2007!
2008!
2009!
2010!
2001!
2000!
2002!
This lag is a function of the economy. For medium and large firms, loan officers reported less demand for loans throughout the crisis (Exhibit 20). Meanwhile, more loan officers reported that lending standards remained eased prior to the collapse and before the rise in demand. These measures suggest that while U.S. commercial banks responsibly tightened lending during the economic recession, lending standards tightened after demand fell and eased before demand rose. Thus, U.S. commercial banks remained supportive to U.S. business borrowing needs.
2003!
2011!
0.5!
Exhibit!20 !
BANKS HAVE EASED LENDING STANDARDS FOR BUSINESSES AS DEMAND HAS INCREASED!
Net Percent of Loan Ofcers Reporting Increased Demand and Easing of Lending Standards! Lending! Standards! Banks began easing lending standards to businesses prior to businesses demanding loans during the recovery.! Loan! Demand!
Net increase in loan ! demand and ! easing of supply !
50!
Net decrease in loan ! demand and ! tightening of supply !
0!
-50!
-100! 2000! 2001! 2002! 2003! 2004! 2005! 2006! 2007! 2008! 2009! 2010! 2011! 2012!
Source: Federal Reserve Senior Loan Ofcer Survey!
Spotlight: Support for St. Paul Stamp Works Americas small businesses rely on the financial sector for support, regularly seeking loans they need to grow and hire. Consider St. Paul Stamp Works, a fifth generation small business in Minnesota that locals go to for their stamping, embossing and printing needs. St. Paul Stamp Works current President is 62-year-old Ed Mellgren, a direct descendent of the Scandinavian immigrant who founded the company 140 years ago. Im convinced you need to have a good relationship with your bank, he says, referring to his lender, U.S. Bank, a subsidiary of Minneapolis-based U.S. Bancorp. They have always been there and always provided financing for us, even in 2008 and 2009. Recently, Mellgren used a U.S. Bank loan to purchase a laser cutter and high-tech digital printer that has helped the company cut costs and hire three new workers. He says that although profitable and financially sound, the company sometimes needs loans when its cash is not in a readily available form. Mellgrens relationship with U.S. Bank proved fruitful, as his business was able to receive loans during the economic downturn. Mellgren also offers high praise for Milwaukee-based Northwestern Mutual Life Insurance Corp. Securing life insurance has given Mellgren and others peace of mind that the family business will have the necessary funding to continue in the event of an unexpected illness or death. The comfort in knowing that future events will not bankrupt the business allows St. Paul Stamp Works to focus on enhancing their products and growing its customer base.!
Small Business Lending In the fourth quarter of 2011, the Thomson Reuters/Paynet Small Business Lending Index jumped to levels not seen since the beginning of 2008. Similar to medium and large firm lending, small business lending increased slowly during the recession. But, like large and medium firms, our analysis of the Federal Reserves latest Senior Loan Officer Survey shows that lending standards have eased faster than loan demand has increased. Surveys of small business owners also report greater levels of borrower satisfaction and loan availability as the economy has recovered (Exhibit 21).
Exhibit!21 !
SMALL BUSINESSES LOAN AVAILABILITY AND BORROWER SATISFACTION ARE TRENDING UP!
Net Small Business Owners Responding Loan Availability is Increasing vs. Decreasing and That Borrowing Needs Are Satised! 0! -2! -4! Borrowers Needs Satised! 45! 40! 35! 30!
Percent (%)!
-6! -8!
Percent (%)!
25! 20! -10! -12! -14! -16! 2006! 2007! 2008! 2009! 2010! 2011! Loan Availability! 15! 10! 5! 0!
Source: NFIB Small Business Optimism Survey!
Private Sector Debt Level As detailed above, while overall lending is still down from pre-recession levels due to reduced demand in the housing market, U.S. commercial banks are still providing credit in the form of business and consumer loans. The extension of consumer credit has been remarkable The U.S. private sector during the recession. However, recent continues to deleverage experience shows that while lending albeit at a slower pace over and credit can finance booms, too much can make for painful busts. Prior the past year.! to 2008, private sector debt levels rose to unsustainable levels. Therefore, rather than just tracking the level of credit provision, it is important to monitor private sector debt levels to see the overall health of this sector. Our analysis shows that the U.S. private sector continues to deleverage, albeit at a slower pace over the past year (Exhibit 22).
Exhibit!22 !
PRIVATE SECTOR DEBT HAS DECLINED SIGNIFICANTLY SINCE ITS 2009 PEAK!
Outstanding Debt as a Percent of GDP! 300! 250! 200! 150! 100! 50! 0! 2000! Financial! Business! Credit! Mortgage!
Percent (%)!
2001!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!
2011!
Source: Federal Reserve Flow of Funds!
Outstanding debt in the financial and non-financial business sectors is down 26 percent and eight percent since their respective 2009 peaks. On a consumer level, total outstanding debt is down 11 percent from its peak in 2008, according to the New York Federal Reserve Consumer Credit Conditions.
Moreover, this decline extends throughout various loan types such as auto, home equity and credit card (Exhibit 23). Mortgage and home equity outstanding debt are down 10 percent from their peak, credit card debt is down 20 percent, auto loan debt is down 10 percent and other non-student loan categories are down 22 percent from their respective peaks. These numbers suggest that individual balance sheets are stronger on the liability side. While an estimated 60 percent of this reduction is due to defaults, the scope and magnitude of deleveraging are promising. In fact, a McKinsey Global Institute study recently found that the United States has reduced its overall debt burden (including federal government debt) more than Germany, France and the United Kingdom.9
Exhibit!23 !
PRIVATE SECTOR CONTINUES TO SHED NONMORTGAGE DEBT SINCE RECESSION!

Total Consumer Outstanding Debt! 1.0! Credit Card! Auto Loan! Home Equity! Revolving! Other!
0.8!
-20%! -10%!
Dollars ($T)!
0.6!
-10%!
0.4!
-22%!
0.2!
0! 1999! 2000! 2001! 2000! 2003! 2004! 2005! 2006! 2007! 2008! 2009! 2010! 2011!
Source: NY Federal Reserve!
While debt is down, unemployment is up and wages are stagnant. These dynamics may have counteracted individuals debt reduction over the past several years. Yet, there is a third variable: interest rates. Interest rates have plummeted during the recession and the subsequent stagnant recovery. Individuals have been able to refinance into lower rates across a number of debt instruments. The ability to refinance lowers monthly payments. In fact, on average, individuals now face the lowest monthly payments as a percentage of their income since the early 1990s (Exhibit 24).
Exhibit!24 !
MONTHLY DEBT AND FINANCIAL OBLIGATIONS ARE AT EARLY 1990 LEVELS!

Debt Service and Financial Obligation Ratio! 20%! Debt Service Ratio! Financial Obligations Ratio!
Percent of Disposable Income (%)!
15%!
10%!
5%!
Source: Federal Reserve!
The debt service ratio is the amount of monthly debt service as a percentage of personal disposable income. The financial obligations ratio adds rent, homeowners insurance, property tax and auto payments. Both are down to 1994 levels as of the third quarter of 2011. These trends suggest that the private sector has adjusted since the recession. Debt levels are falling and monthly debt burdens are at historic lows. Healthier household balance sheets improve the safety and soundness of the financial sector as well as lay the foundation for future credit provision in two ways: 1) Outstanding loans are less likely to default as these levels continue to decline; 2) As economic growth returns, individuals will be in a stronger position to afford new loans to invest in real estate or make purchases. Examining trends in lending shows the role of financial services extension of credit during the recession. While businesses required less in loans, individuals needing to finance essential purchases received record levels of credit. Moreover, in the most recent quarters in which business demand increased, loan officers reported easing lending standards, and small businesses access to credit and borrower satisfaction increased.
2011Q3!
0%!
1980!
1982!
1984!
1986!
1988!
1990!
1992!
1994!
1996!
1998!
2000!
2002!
2004!
2006!
2008!
2010!
Protection from Loss

While banks act as financial shelters, insurance companies act to hedge risk, compensating the insured party in the event of loss. Insurance companies pool clients' risks to make payments more affordable for the insured. The P&C insurance industry insures homes, automobiles, individuals and businesses in case of loss, injury or legal claims. There are a host of other insurance products for both personal (individual) and commercial (business) lines. Premiums are the dollar value paid to the insurance company in exchange for coverage. As of the third quarter of 2011 year-to-date, net premiums written for the P&C industry totaled $335.7 billion. On an annualized basis, 2011 year-end premiums are roughly $447.6 billion. Industry totals have not reached that mark since 2007 (Exhibit 25).
Exhibit!25 !
P&C INSURERS PREMIUM REMAINED STRONG THROUGHOUT THE RECESSION!

Net Premiums Written for P&C Insurers! 450! 450 400! 400
350 350!
Dollars ($B)!
300 300! 250 250! 200 200!

150! 150
* Annualized based on third quarter year-to-date!

Net premiums written for a specific line of business is an insurers retained premium income, which is either direct business or assumed reinsurance minus payments made for reinsurance ceded, for this specific line of business.
2011*!
2000!
2001!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!
100! 100
!Spotlight: Support in Joplin, MO One place where the insurance system worked as well as expected in fact even better than expected was Joplin, Missouri. The southwestern Missouri city was devastated on May 22, 2011by a massive tornado that claimed more than 150 lives and tore apart 7,000 homes and 2,000 buildings. The deadly tornado produced more than 15,000 insurance claims, and Missouris insurers were lauded for the quick, helpful and compassionate work they did in the aftermath. This is the largest insurance event in Missouri history, said John Huff, Director of Missouris Department of Insurance, Financial Institutions and Professional Registration. The industry should be The industry should be commended for commended for the the response thus far. Within 100 days after the event, they had paid out $1 response thus far. Within 10 billion to policyholders. ! 100 days after the event,
they had paid out $1 billion Loretta Bailey is an Allstate agent who experienced the tornado first-hand and to policyholders. played an integral role in helping her customers rebuild their lives. Hearing sirens indicating bad weather is common in this area of the U.S. This time was different, as the warnings advised that the tornado was headed straight into Joplin. Bailey rushed home, parked her car in the garage, and joined her boyfriend in the basement just as the tornado was close enough to make the fans in the homes furnace rapidly spin.
The damage was catastrophic. While Bailey survived the tornado, her house and car did not. She decided to head to the Allstate office, which she initially couldnt get to due to the towns wreckage. Eventually, she and some of her colleagues set up shop with laptops in a nearby business, and immediately started giving their fellow community members the checks they needed to get basic necessities in addition to funding for new residences and cars. Allstate was widely praised for its efficiency in the days and weeks after the tornado. Bailey proudly tells the story of one elderly couple that rode the tornado out inside a fireplace. Significant damage was done to their residence, and within seven days they were given a claim check and the ability to purchase a permanent home. I realized why I do what I do, she says. I realized what I am giving back to the community. People would come in, and I would tell them what their policy pays them, and see the relief on their faces and the words were going to be ok. Its going to be alright. People ask, How can you help others when youre hurt yourself? I told them that when I signed on to be an Allstate agent, I signed on to help people. People were coming to us and saying, My neighbors had [Allstate] as an agent, and had a check in their hand so quickly. You were out there, you werent just sitting in the office waiting to be called.
Based on policy coverage, when the insured party experiences a loss, the insurer must reimburse in the form of a monetary benefit. Total benefit or payouts for the P&C industry amounted to $264.6 billion year-to-date as of the third quarter of 2011, for an annualized amount of roughly $352.8 billion. If year-end values prove to be around the annualized amount, payouts in 2011 would be the highest on record (Exhibit 26). 2011 was a bleak year for catastrophic events, and this contributed to the large amount of payouts. While these losses are not favorable to the industry, they are extremely helpful to the insured parties, providing monetary benefit in time of need.
Exhibit!26 !
P&C INDUSTRY PAYOUTS WERE AT AN ALL-TIME HIGH IN 2011!

Loan & Loss Adjusted Expense! 400! 400
350 350! 300 300!

Dollars ($B)!
250 250! 200 200!

150! 150
100 100!
50! 50
2000!
2001!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!

Also affected by the large amount of losses due to catastrophic events was the reinsurance industry. In order to reduce risk, insurance companies transfer risk to a reinsurance company, which assumes all or part of the risk. This reduces the overall amount one company can pay for a specific claim. Instead, the premiums and losses are shared. The process is known as reinsurance. Although 2011 produced record losses that affected reinsurance performance, as a whole, the industry remains strong with stable capital and performance ratios well situated.11 Whereas the P&C industry covers losses on physical and economic assets along with other liabilities, the Life industry provides coverage to a decedents family or
2011!
0! 0
other beneficiaries in the case of loss of life, illness/disability and other events. Life insurance can provide those left behind with a lifetime of financial security. The method of obtaining a policy follows the same process as it does for the P&C industry payment of premiums (annuities or deposits) in exchange for coverage. The Life industry had Premiums, Consideration and Deposits (a comparable metric to Net Premiums for the P&C industry) of $476.8 billion as of the third quarter of 2011, and an annualized amount of roughly $635.7 billion (Exhibit 27). Given three consecutive quarters of growth in 2011, the year-end value would represent the highest amount for the industry on record.
Exhibit!27 !
LIFE INSURERS ANNUITY AND LIFE INSURANCE PREMIUMS HAVE STRONGLY REBOUNDED!
Net Premiums, Considerations and Deposits for Life Insurance! 700! 600! 500!
Dollars ($B)!
400! 300! 200! 100!
2000!
2001!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!

Source: FDIC, SNL Financial! !
Life insurance payouts are measured in the form of Benefits and Surrenders. Yearto-date payouts as of third quarter of 2011 for the industry amounted to $368.3 billion, with an annualized amount of $491.1 billion, which is in line with historical levels (Exhibit 28). Benefits include death benefits, matured endowments, annuity benefits, accident & health benefits, guarantees, group conversions, and life contingent contract pay. Surrender benefits and withdrawals for life contracts include all surrender or other withdrawal benefit amounts incurred in connection with contract provisions for surrender or withdrawal.
2011!
0!
Exhibit!28 !
LIFE INSURERS HAVE INCREASED PAYOUTS SINCE 2010!

Life Insurance Payouts, Surrenders and Benets! 600! 600 Surrenders ($B)! Benets ($B)!
500 500! 400 400!

Dollars ($B)!
300! 300 200! 200
100 100! 0 0 !
2000!
2001!
2002!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!
The industrys main role is to provide coverage in the event of loss; however, investments made by the P&C and Life industries in stock markets, bonds and other asset classes contribute to economic growth. The benefit of investment income is vast. In short, companies are able to use invested funds to expand (increase employment) and increase shareholder value, while governments at the national, state and local levels are able to use the funds to the benefit of the taxpayer. As a whole, the insurance industry (including Health insurers) had cash and investments of $4.65 trillion in 2011. These investments are used to generate earnings, which are then used to provide payouts to insured parties and pay dividends to investors and policyholders.
2011!
Spotlight: Financial Planning ! !One particular bright spot in the financial services industry is the planning and advisory !sector. Retiring Americans are increasingly reporting positive, comforting results when it comes time to leave the workforce and enjoy the next phase of their lives. David L. Blaydes, CFP, MS says his clients are regularly surprised and relieved to see that their retirement packages withstood the recent recession and will indeed allow them and their loved ones a pleasant retirement. Blaydes, a Certified Financial Planner with a Masters in Financial Planning is Founder and President of his own firm, Retirement Planners International, Inc. in Naperville, IL. He tells a particularly powerful story of one such client. Blaydes client was a successful Chicago-area attorney who planned to retire on his 65th birthday in 2011. This client had invested wisely, heeding Blaydes advice about how much to invest in his 401(K), and how to diversify it according to the rate of return needed to accomplish his goals. Importantly, this resulted in a substantial reduction of risk before the 2008 market downturn. The client was pleased with his retirement plan, and told Blaydes he was ready to cash out on his life insurance policy and start making use of that money. Blaydes advised his client against this decision and used data from the clients own plan to show him why the insurance was, from a planning perspective, still a wise investment. The client took the advice, which Blaydes was able to objectively offer as a financial planner, not an insurance underwriter. Within a month, the client asked Blaydes to visit him at his home. House visits are not in the typical course of business, and this caused Blaydes some anxiety as to what the issue could be. Upon arrival, Blaydes was given the sad news that his client had just learned he had only six months to live. He asked Blaydes to assure his wife that she would have what she needed without him, and thanked Blaydes for the counsel. He has since passed away, and the $1,000,000 of insurance he decided to keep, based on Blaydes recommendation, has allowed his spouse to maintain her financial independence for the rest of her life, just as he wanted. Blaydes believes that his industry has fundamentally changed for the better over the past 30 years, and is now focused not just on selling a financial product, but on compassionate caring for clients and acquiring the technical skills that are demanded by complex planning.
Saving for the Future

Having adequate retirement savings is vital to personal financial security and a big component of our financial services. According to the Investment Company Institute (ICI), as of the third quarter of 2011, retirement savings accounted for 36 percent of all household financial assets in the United States, equal to roughly $17 trillion (Exhibit 29). This level amounts to a 21 percent increase since 2008 with increases in all retirement financial vehicles. Total retirement savings are aggregated using six plan types: Annuity Reserves, Federal pension plans, State and Local pension plans, Private Defined Benefit Plans, DC Plans and IRAs. All plan types fell from 2007 to 2008; however, IRAs took the largest hit, going from $4.7 trillion to $3.7 trillion, a 22 percent decrease. As of the third quarter of 2011, IRAs represent 4.6 trillion of the U.S. total retirement market, a 25 percent increase since 2008.
Exhibit!29 !
TOTAL RETIREMENT MARKET STANDS ABOVE 2006 LEVELS AT $17 TRILLION IN Q311!
Total US Retirement Market! Annuities! Federal pension plans! "State and local government pension plans! Private DB plans! DC plans! IRAs!
18! 16! 14!

Dollars ($T)!
+21%!
12! 10! 8! 6! 4! 2!
2008! 2011*! 2000! 2001! 2002! 2003! 2004! 2005! 2006! 2007! 2009! 2010!
0!
* As of 3rd quarter! Source: Investment Company Institute!
Much of the planning aspect behind retirement advisory involves the balancing of a portfolio. Known as asset allocation, investors must make a choice of tradeoffs between risk and reward. Risk is determined by a variety of factors, but is most often associated with age of the account holder. As individuals near retirement and their personal risk aversion rises, the dollar proportion of bonds (fixed income) will replace holdings of equities.12
Value to the Economy Summary

The core functions of our financial institutions are critical to our economy. Deposits, while a simple service, provided a safe place for our finances during volatile times. Consumer loans increased to help our financing needs during the crisis and, more recently as our economic recovery has picked up, loans have increased to small businesses to finance job creation. Insurance is there to support us during the most difficult times, and the full range of our financial services support us as we plan for the future.
Regulatory Spotlight:
The Durbin Amendment
The least understood aspect of regulatory policymaking in Washington is unintended consequences. Unforeseen costs and unexpected outcomes are inevitable given the current scale and scope of new regulations. In the midst of a slow recovery, these costs should be at the forefront of the debate. For example, higher capital requirements associated with Basel III may result in less credit growth, higher interest rates and slower economic growth in the short-run. Congress and regulators do not develop rules with the intention of reducing economic growth or unnecessarily hurting American companies. However, by imposing overly burdensome costs and creating unintended consequences, poorly crafted regulatory policy can do just that. The poster child for this type of counterproductive regulation is the Durbin Amendment.
Key Findings: The enforcement of the Durbin Amendment in the fall of 2011 has resulted in a rollback of consumer benefits with no retail price reductions The percent of checking accounts that are free has dropped by 30 percent A study found that retail prices actually increased 1.7 percent after the Durbin Amendment took effect Small businesses specializing in small-ticket items have seen costs rise significantly due to the Durbin Amendment
This section of the report will evaluate the merits and outcomes of the Durbin Amendment. We will evaluate the claims made by both sides of the debate based on what has been seen over the first four months of the laws enforcement. While the Durbin Amendment is unlikely to be changed in the near future, this analysis can inform future regulatory debates.
The Durbin Amendment pitted merchants against banks over approximately $17 billion in annual interchange fees, the cost merchants pay banks for processing debit card transactions. While the lobbying battle was business against business, consumers are impacted as well. Unfortunately, our analysis finds that the Durbin Amendment has made consumers worse off. The Immediate Effects of the Durbin Amendment In the first four months of its implementation, the Durbin Amendment has led to profound changes on the merchant and consumer side of the market. Just as increased interchange fees in the 2000s helped increase the availability of free checking, no-fee debit cards and rewards programs, reduced interchange fees will cause benefits to be scaled back. Meanwhile, there is no evidence that merchants, who received a major windfall, have lowered prices (Exhibit 30). The price controls in the Durbin Amendment completely ignore the economic incentives facing both banks and merchants.
Exhibit!30 !
REDUCING INTERCHANGE FEE SHIFTS COSTS TO CONSUMERS!

The Durbin Amendment adjusts the price merchants pay for the debit payment system. However, in this particular two-sided market, those costs had supplied a number of goods to consumers. Banks will raise costs and reduce rewards on consumers to make up for lost revenue.! Increased merchant savings! Old! interchange fee!
Consumers!
Decreased: ! Free checking! No fee debit cards! Debit rewards!
Merchants!
New! Interchange fee!
Pre-Durbin pricing structure! Post-Durbin pricing structure!
Bankrate data shows that the amount of free, non-interest bearing checking accounts peaked in 2009 at 76 percent, fell to 65 percent in 2010 due to the regulation of overdraft fees, and then fell even further to 45 percent due to the Durbin Amendment. (Exhibit 31). Free checking is less available now than it has been in the past six years. The cost in terms of access to traditional banking services is steep. One estimate found that approximately one million people may forego checking accounts at traditional banks.13
Exhibit!31 !
FREE CHECKING OFFERS HAVE DECREASED 30 PERCENT SINCE 2010!

Percent of Non-Interest Checking Accounts that are Free! 80! 70! 60!
Percent (%)!
+73%! -30%!
50! 40! 30! 20! 10! 0!
2003!
2004!
2005!
2006!
2007!
2008!
2009!
2010!
2011!
Source: Bankrate.com!
While interchange fee revenues helped support no-fee debit cards, the Durbin Amendment has led to banks attempting to make up the lost revenue elsewhere. Consumers pushed back against banks that tried to charge debit card fees, but a reduction of previously free benefits on other services have not drawn such protest. Increasingly, debit rewards programs are being terminated as the revenue used to support them evaporates. According to Pulse Networks 2011 Debit Issuance study, which took place prior to the Amendments implementation, 54 percent of institutions were looking to re-structure or terminate rewards programs due to Durbin.14 Bankrates Fall 2011 Check Card survey found that 30 percent of banks surveyed the year before had terminated their debit rewards programs in 2011. The early results are clear; the Durbin Amendment has reversed the trend of lower consumer costs for debit cards and other bank services. The banks will charge you While banks have had to recoup lost revenue, merchants have not passed on savings to customers to offset their gains. A study by the Electronic Payments Coalition (EPC) surveyed the cost of a set basket of goods before and after the Durbin Amendment went into effect. The EPC study found that the cost of this basket of goods actually rose 1.7 percent.15
more, and I dont think the retailers are going to charge you less, which is why I didnt want to put it in the first place. -Rep. Barney Frank!
The result of this study is not surprising. International experience in Australia found no evidence of price reductions due to reduced interchange fees.16 The economics behind these results are simple. While the banking industry is highly competitive, merchants face various levels of competition. Prices tend to be sticky for merchants.17 Merchants tend to price items around focal points such as $9.99 and face menu costs, the actual cost to changing prices. As a result, we have a situation where banks are reacting to price controls by cutting costs, while merchants have little incentive to reduce prices. This situation was not lost on some legislators. Representative Barney Frank (DMA-4) stated The banks will charge you more, and I dont think the retailers are going to charge you less, which is why I didnt want to put it in the first place.18 The Durbin Amendment has led to a significant reduction in free checking, fewer rewards programs and consumers have not seen lower prices from merchants. Consumers are clearly worse off. This outcome should be no surprise if we consider the history of payment options and the economics of these systems. Durbin Amendment 101 When a customer swipes a debit card to purchase an item, the merchant, two banks and the network association all process the transaction (Exhibit 32).
Exhibit!32 !
DEBIT CARD PAYMENT SYSTEM!

Hypothetical $100 Dollar Purchase with 1.55% Merchant Discount! Pays $100! 1! Merchant Discount! Pays $1.55!
Pays merchant $100!
Customer!
5!
Merchant!
Deducts $100 from customer checking account!

! Network Fee! !
2! Submits
4!
payment for processing!

Acquirer Fee! Keeps $0.10!
Pays merchant $98.45!
Interchange Fee!
Issuer
! Bank! ! Keeps $1.15! 3!
Network Association!
Pays acquirer $98.87!
Acquirer ! Bank! !
Keeps! $0.30!
Source: GAO, Congressional Research Service!
After the card swipe, the merchant submits the payment for processing by routing the card information through an acquirer bank to the card issuer bank. The merchant contracts with the acquirer bank, while the issuer bank is responsible for the card. After the process is approved, the money, minus the interchange fee and the acquirer fee, is transferred back to the merchant. The issuing bank deducts the full cost of the item purchased from the customers account.19 The Durbin Amendment capped interchange fees at 21 cents to 24 cents per transaction, depending on anti-fraud investments by issuers. The cap was intended to keep fees at cost. Prior to the Durbin Amendment, the average debit purchase was $38 with an interchange fee of 44 cents.20 Therefore, banks will lose 45 to 52 percent of their potential revenue from reduced debit interchange fee if benefits, behaviors and purchase patterns hold constant. Central to complaints made by merchants was that over the same time period of rising interchange fees, the cost of processing transactions and mitigating fraud fell. Merchants argued that the rise in fees above the cost of providing the service was an anticompetitive practice in need of price control. The merchants argument was that due to Visa and MasterCards market power, they could present take it or leave it offers that merchants had to go along with.21 While this argument might sound intuitively correct, it rests on the theories of onesided markets where the seller is producing a good for one buyer. The payment card system, however, is a two-sided market where the seller is balancing the demands of both consumers and merchants. Evaluating what is a fair price in a two-sided market requires a different framework than that of a one-sided market. Debit Card Payment as a Two-Sided Market In the debit card payment system, there is a two-sided market, where network associations must balance the demands of consumers and merchants. Consumers enjoy the convenience, organization and rewards of paying with a debit card, while merchants benefit from increased sales due to these consumer incentives, as well as more efficient checkout and accounting processes. Like the debit card payment system, news sources must balance the demands of both consumers and advertisers. Consumers want low-cost (if not free) news. Advertisers want to reach a large audience. The challenge for the news source is to price both sides accordingly to maximize the use of the product. In this instance, charging advertisers more and consumers less benefits both readers and advertisers. Readers get low-cost content and advertisers, while bearing most of the cost, reach a larger audience. These types of markets, where sellers balance the demands of two buyers, exist throughout the economy and in almost every situation where one buyer subsidizes the other.
When lobbying for regulatory action, merchants have highlighted the rising costs of the payment system on one side of the market. Very little attention, however, has been paid to the other side. As outlined above, one must examine the overall price of the payment structure to determine competitiveness, not just one side. We find three concrete cost reductions over the past decade: free checking, the introduction of no annual fee debit cards and debit rewards programs. According to Bankrates Fall Checking Studies, in 2003 only 44 percent of noninterest checking accounts were free. By 2009, 76 percent of non-interest checking accounts were free (Exhibit 33). This rise of free checking has helped lower consumer costs and brought more people into the formal banking system. Beyond free checking, banks have reduced costs for holding debit cards. In the early 2000s it was common for debit cards, especially PIN debit cards, to carry a swipe fee for consumers. Now, according to a Bankrate Check Card study, 95 percent of the top 100 depository institutions offer debit cards with no usage fees. In addition, card-issuing banks have instituted debit card rewards programs, such as airline miles and cash back incentives. According to Pulse Network data, the number of institutions offering debit rewards increased from 36 to 58 percent from 200522 to 2011.23 Consumers have not just seen lower overall costs, but have many options to maximize their personal benefit from the card. The Durbin Amendment Summary The Durbin Amendment represents an attempt to legislate against economics and the loser has been the consumer. The Amendments intrusion into the payment market through instituting price controls has led to distortions that have raised costs to consumers and small business while reducing innovation. As we look at future regulatory proposals, the experience of the Durbin Amendment should be a cautionary reminder to carefully weigh the costs and benefits of regulation and to be wary of unintended consequences.
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
1
Reflections on Dodd-Frank, A Look Back and a Look Forward, Simpson Thacher & Bartlett LLP, July 21, 2011. 2 Data provided by SNL Financial LC unless otherwise noted. 3 Quarterly Banking Profile: Third Quarter 2011, FDIC Quarterly, 2011, Volume 5, Number 4. 4 Property & Casualty Insurance Services: Competitive Conditions in Foreign Markets, United States International Trade Commission, March 2009 5 Fitch: Stable Outlook for U.S. Life Insurance Industry, Business Wire, Dec 14, 2011. 6 Fitch: P&C Industry Rated Stable; Improved Profitability in 2012, Property Casualty 360, Dec 15, 2011. 7 Carr and Shah, U.S. Banks Reduce Exposure to Eurozone Periphery, SNL Financial LC, Jan 31, 2012. 8 Foster, Meijer, Schuh, and Zabe, The 2009 Survey of Consumer Payment Choice, The Federal Reserve Bank of Boston, April 2011. "!Roxburgh, Lund, Daruvala, Manyika, Dobbs, Forn, Croxson, Debt and deleveraging: Uneven progress on the path to growth, McKinsey Global Institute, January 2012.! 10 Insurers Pay Out $1.13B for Joplin, Missouri Tornado Damage, Insurance Journal, November 30, 2011. ##!Simpson, Hettinger, Hole, Hochberg, DeMartini and Harrison, P&C Insights: An Inflection Point for the P&C (Re)Insurance Industry, Towers Watston, Jan 17, 2012. 12 Horneff, Maurer, Mitchell and Dus, Optimizing The Retirement Portfolio: Asset Allocation, Annuitization, and Risk Aversion, National Bureau of Economic Research, July 2006.!! 13 Zywicki, Durbins Innovation Killer, The American, June 11, 2011, 14 2011 Debit issuer Study 15 Wheres the Debit Discount, Electronic Payments Coalition, 2011. 16 Eubanks, Payment Card Interchange Fees: An Economic Assessment, Congressional Research Service, September 3, 2008. 17 Evans, Litan, Schmalensee, "Economic Analysis of the Effects of the Federal Reserve Boards Proposed Debit Card Interchange Fee Regulations on Consumers and Small Businesses," February, 22, 2011. 18 Zywicki, Barney Frank Criticizes the Durbin Amendment, San Francisco Chronicle, October 13, 2011. 19 Rising Interchange Fees Have Increased Costs for Merchants, but Options for Reducing Fees Pose Challenges, Report prepared for Congress by the Government Accountability Office, November 2009. 20 Wyatt, Fed Halves Debit Card Bank Fees, The New York Times, June 29, 2011. 21 Eubanks, Payment Card Interchange Fees: An Economic Assessment, Congressional Research Service, September 3, 2008. 22 New Comprehensive PULSE Debit Industry Study Reveals Continued Growth in Debit Card Market, Discover Financial. 23 2011 Debit Issuer Study: Amid Strong Market, Issuers Bracing for Pending Changes, Pulsations Online, May/June 2011.
Partnership for a Secure Financial Future 1001 Pennsylvania Avenue, NW, Suite 500S Washington, DC 20004 (202) 589-1927 www.OurFinancialFuture.com Hamilton Place Strategies 1501 M St NW, Suite 350 Washington, DC 20005 (202) 822-1205 www.hamiltonplacestrategies.com !

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The Hamilton Financial Index:

Matt McDonald Partner

Hamilton Place Strategies | 1

2 | The State of Our Financial Services

Hamilton Place Strategies | 3

The Hamilton Financial Index:

A Snapshot of Firm and Systemic Risk

HAMILTON FINANCIAL INDEX SHOWS BANKS SAFER THAN PRE-RECESSION!

Source: HPS Insight, St. Louis Federal Reserve, SNL Financial!

Hamilton Place Strategies | 5

St. Louis Fed Financial Stress Index

6 | The State of Our Financial Services

High Low Average

Tier 1 Common Risk-Based Ratio (%)!

Tier 1 Common Capital ($T)!

1.0! 0.8! 0.6!

Source: FDIC, SNL Financial!

Hamilton Place Strategies | 7

US COMMERCIAL BANKS HAVE REDUCED THEIR HOLDINGS OF RISK-WEIGHTED ASSETS!

69! 66! 63! 60!

Source: FDIC, SNL Financial!

8 | The State of Our Financial Services

The Hamilton Financial Index Summary

Hamilton Place Strategies | 9

Safety and Soundness:

10 | The State of Our Financial Services

Loan-to-Deposit (LTD) Ratio

CORE FUNDING INCREASES AS LOAN-TODEPOSIT RATIO FALLS 20% SINCE 2008!

80! 75! 70! 65! 60! 55!

Source: FDIC, SNL Financial!

Hamilton Place Strategies | 11

Insurers Capital & Surplus (C&S)

12 | The State of Our Financial Services

Capital and Surplus as a % of Assets (%)!

Total Surplus ($B)!

450! 400! 350! 300! 0!

Source: NAIC, SNL Financial!

LIFE INSURERS CAPITAL AND SURPLUS HAS RISEN SINCE 2008 !

Source: NAIC, SNL Financial!

Hamilton Place Strategies | 13

PERFORMANCE MEASURES BOUNCED BACK QUICKLY FROM 2009 LOWS!

75! 50! 25! 0!

Source: FDIC, SNL Financial!

14 | The State of Our Financial Services

Source: NAIC, SNL Financial!

Hamilton Place Strategies | 15

5! 0! -5! -10! -15! -20!

-20 -20! -40 -40! -60 -60!

Source: NAIC, SNL Financial!

Potential Roadblocks to Growth and Stability

16 | The State of Our Financial Services

Hamilton Place Strategies | 17

Total ! Non-Real Estate! Loans!

Source: FDIC, SNL Financial!

!"#$% ! !"!!"#$!!"#$!!"# ! !"#$%%&'$(!!"#$% !"#$%!!!"#$

18 | The State of Our Financial Services

TOTAL CHARGEOFFS AS A PERCENT OF TOTAL LOANS PEAKED IN 2010!

Source: FDIC, SNL Financial!

Hamilton Place Strategies | 19