Julian Vandermark · Chief Data Officer · United States
I would bring a board a working knowledge of where its regulatory and customer figures come from. Directors attest to call reports, approve fair-lending programmes and oversee model and vendor risk, often without seeing the decisions inside the data. I can help them ask the questions that expose those decisions: which definitions changed this year, which reconciliations failed, what a fairness test could not see, and which vendor controls the meaning of a field. I have led that work inside a community bank for more than a decade, after years on the reporting desk and the vendor side. I have not been a director, and my credit experience is in the records rather than the lending decision itself. A board would gain an audit or risk committee member who understands data, technology vendors and fair-lending analytics, and who will say when a clean figure rests on something thin. I would not replace the judgement of directors who have run lending businesses; I would make the evidence they rely on easier to examine.
| Capacity | Committees |
|---|---|
| Ready to join | Audit · Risk · Compliance or fair-lending oversight |
I am looking for one non-executive seat on an audit or risk committee where data quality affects what the board signs or approves. A community or regional bank holding company outside our market would suit, as would an agricultural lender, a specialist small-business lender or a payments business serving small merchants that depends on bank partners. I would be most useful where the organisation is preparing for a new reporting obligation, replacing a core platform or beginning to use models in credit or pricing. I would not present myself as a credit officer, a technologist or a lawyer, and the board should already have those skills among its members. I would rather join a board that knows it needs a data-literate director than one wanting another title on its list. The right chair will expect me to learn the business before offering opinions about it, and will tell me plainly when I have not.
Presented to the Board or a committee
Audit committee; risk committee
June 2015–present
Presents call report data controls to the audit committee twice a year and fair-lending testing results, with the chief compliance officer, to the risk committee annually; an officer, not a director.
The farmland reclassification showed me how a regulatory return can be arithmetically right and wrong in classification. On another board, I would ask management to identify the call report lines that depend on one manually entered field, and to show the reconciliation that would catch an error in each. I would not expect every weakness to be fixed at once. I would want the audit committee to know which remain, who owns them and when the committee will hear about them again. If an error were found, I would ask how far back the evidence allowed correction, and whether examiners had been told what could not be corrected. A board that sees the limits of its records is better placed than one that hears only that the filing went in on time.
The pricing-exception case taught me that a board will often receive a fair-lending result before anyone can fully explain it. I would ask what method produced the estimate, how wide its error range is and how small the samples are in the branches concerned. I would also ask what management is doing while the explanation is incomplete, because waiting for certainty is itself a decision with consequences for borrowers. I would not ask directors to treat a proxy estimate as proof of discrimination, nor to dismiss it as statistical noise. The useful questions are whether the bank's controls on lender discretion would catch the problem if it were real, and whether compliance, rather than the analysts, owns the conclusion and the remedy.
In the first months I would read the last eight quarterly regulatory filings alongside the audit committee's minutes, to see which questions directors had already asked and which they had not. I would ask to meet the people who prepare those filings, the chief compliance officer and the head of credit administration, outside the formal committee schedule. I would also ask for the inventory of vendor-supplied data and the current fair-lending testing plan, because those two documents show quickly whether data ownership is real or nominal. By the third meeting I would hope to contribute specific questions rather than general ones. After six months I would ask the chair for frank feedback on whether my questions helped the committee or distracted it. I would not propose changes to management's reporting formats in my first year unless something material was missing.
Three kinds of relationship need checking before I accept any seat. The first is regulatory. Federal rules restrict a management official of one depository institution from also serving an unaffiliated one in certain overlapping markets or above certain sizes, so counsel would need to confirm that no such overlap applies. The second is commercial. Kellanbrook buys from core, origination and analytics vendors, holds correspondent accounts and sells participations in agricultural loans to other lenders, so a board connected to any of them would need careful review. I worked for Arbelune Core Systems until 2011 and would declare that wherever it is relevant. The third is information. I would not carry pricing, customer or examination material between institutions, and I would step out of any discussion engaging my employer's interests. If those steps would leave me absent from discussions too often, the seat would be the wrong one, however attractive it looked, and I would rather decline it before appointment than recuse myself repeatedly afterwards.
I am a salaried officer of Kellanbrook Bank and hold shares in its holding company through the employee stock ownership plan. A prospective board would need to weigh those ties, my former employment at a core vendor and our correspondent relationships before treating me as independent of its business.
IICA Independent Directors’ Databank: Not yet registered
The Indian independent directors' databank applies to Indian company boards. I am a US banking executive seeking a US seat, so it does not apply and I have not registered.