In Your Best Interest: An ALM First Podcast
Our goal is to give you an insider's view of the latest market trends, explore common depository challenges and share success stories and insights from industry leaders. Join us to gain new perspectives as our experts dive into effective balance sheet management techniques and break down best practices. Visit our website at https://www.almfirst.com/.
In Your Best Interest: An ALM First Podcast
Enterprise Risk Management: Staying Ahead of Uncertainty
Welcome to this episode of, In Your Best Interest, an ALM First podcast. Have you ever wondered how financial institutions can stay ahead of uncertainties and manage competitive pressures? Join us as Jessica Coulis and Ben Schexnayder reveal the secrets of Enterprise Risk Management (ERM) and its critical role for many institutions. Through personal stories and professional insights, they detail how ERM can break down departmental silos, foster collaboration, and provide a comprehensive view of risks that enhances strategic decision-making. Listen in to understand how a holistic approach to risk management can transform your organization's ability to navigate rapidly changing environments.
Unlock best practices for strategic risk management, with a focus on dynamic risk appetite statements and proactive risk metric monitoring. Jessica and Ben discuss how aligning products and services with an organization's risk-taking philosophy ensures new offerings fit within the company's risk appetite. Additionally, get a deep dive into the challenges of deposit sourcing, loan growth, and FinTech integration, all while emphasizing the significance of creating a robust risk culture. Don't miss this opportunity to learn how a strong ERM program can prevent financial surprises and build resilience in today's volatile market.
Welcome everyone to the 24th episode of In your Best Interest, an ALM First podcast, a show that explores common depository challenges, gives you an insider's view of the latest market trends and shares stories and insights from industry leaders. I'm your host, mike Enzweiler. Banking themes today include deposit sourcing, loan growth and fintech integration, just to name a few, all while emphasizing a need or significance for creating a robust risk culture. Have you ever wondered how financial institutions can stay ahead of uncertainties and manage competitive pressures?
Speaker 1:We have been getting a lot of questions lately related to the best practices for strategic risk management and decided to tackle this idea today on the show. Joining us are Jessica Koulis, director of Enterprise Risk Management at Independent Financial, and Ben Schexnader, director of Enterprise Risk Management at ALM First. We will have them reveal the secrets of ERM and its critical role for many banking institutions Through personal stories and professional insights. They will detail how ERM can break down departmental silos, foster collaboration and provide a comprehensive view of risks that enhance strategic decision-making. We will also explore how a holistic approach to risk management can transform your organization's ability to navigate rapidly changing environments. Jessica and Ben, welcome to the show.
Speaker 2:Thanks for having us. Glad to be here, awesome, you know.
Speaker 1:Before we get started with the subject at hand, which is you, which is the ERM edge staying ahead of uncertainty. Maybe you can share a fun fact about yourself with our listeners.
Speaker 2:Yeah, I'll start. I have traveled all over the world and I've had the opportunity to bungee jump once, which I'll never do again, and also skydive twice, which I'll never do again, and also skydive twice. So those events have turned me into a risk professional, where I focus on managing risk to the right level.
Speaker 1:That's great how about you, ben.
Speaker 4:Yeah, so I guess how I even got into this crazy financial services world. In college I was a teller at Whitney Bank and I think every day I was fine in my short, I didn't have any shortages, and then one day I had a $400 outage and I still to this day don't know where that $400 went. And so I mean it's driving me crazy from just thinking about it all the time. I still think about it, and so I pretty much have just thrown myself at financial services as kind of a you know a penance. I'm just going to work in financial services and make up for that $400 loss.
Speaker 1:Trying to figure out what happened to it to this day. So I've been in the financial services space since then.
Speaker 4:And even when I think about some of the risk you know, it's those little small things sometimes that just stays with you.
Speaker 1:Yeah, and that took you down the risk path instead of lending or accounting or whatever it's. I need to figure out what happened.
Speaker 2:A pivotal moment.
Speaker 1:I love it. The last couple of years we've seen a lot of headlines in banking or we felt a lot of these themes of a rapidly rising rate environment. Obviously, we had all the headlines last March with Silicon Valley Bank and so forth. We're perhaps in an inflationary period. We've got an upcoming election. There's a lot of uncertainty in the industry and in the, I guess, the environment these days, and it does seem like now's a good time to discuss risk as well as the monitoring and the managing of those risks so I'm excited about the the topic at hand today, so maybe we'll just throw out to both of you you know where and how have you seen enterprise risk management programs create and drive value for financial institutions?
Speaker 4:right. Yeah, um, a lot of times, you know, I think about ERM and is it being effective, is it driving discussion right? Because ERM ultimately is a program tool that asks questions of the organization, that helps the organization kind of peel apart assumptions underlying its objectives. And what I've seen a lot of times is, while management's busy, focused, you know, tactically on one area, the risk exposures around the organization are constantly evolving and they're changing and ERM kind of allows the organization to see and understand those changes, while its management team is focused in one area and kind of stays ahead of the curve right, stays ahead of those risk exposures as they're changing, and I think that ability puts them ahead of competition, especially when it's done correctly.
Speaker 2:Yeah, I totally agree with you, Ben. Just having that ability to be more proactive than reactive is so important to your point. It's a rapidly changing environment and you just have to be in front of things. And, like you said, Ben, it's really about driving discussions. And in ERM you have this really cool enterprise view. You have this bird's eye view and you're breaking down silos.
Speaker 2:So, yeah, everyone thinks that everyone sees it all, but really ERM does have that lens and you, your role is to weave together the story.
Speaker 2:So you're bringing together things that you know someone might look at and think that's just fine, but looking at it collectively with the other risks, it is maybe something that you want to think about, and just looking through those trends is really super important. So it's really a huge advantage if you have a great dashboard that helps you prompt those discussions and think through. And just recently, I think something we can all relate to is cost of funds have been increasing. It's harder with the competitive pressures for deposits and you think about that. Well, that's very specific. It's an interest rate and market risk, but then how does that play on your strategy and your capital and your strategic risks in terms of maybe you're not accreting capitals fast, and then does that play on some of your credit risks because you're concentrating, you know your portfolio and you don't have the capital to kind of even that out. So it's really that story of weaving it all together and that's where ERM comes in.
Speaker 1:So and I like where you're going with this. So, beyond the story, you know we bring a consulting lens to the table here today and kind of within the bank, within the walls perspective. So you know, sometimes I feel like and I'm not as close to it as you are that ERM and some of this is for some institutions it's very much a check the box exercise From your perspectives and as I think about, if I put my kind of my banking hat on, a management hat on, is, are you seeing, by having these discussions and facilitating discussions, you're getting some alignment between, for example, finance and lending right, where there's historically maybe some give and take, whether it comes to pricing or other kinds of decisions? So maybe speak to that a little bit in terms of, because the question was how does it drive value for the organization? So I'm really curious how you get all of these different parties from within the organization to see the value of it, versus just I'm checking a box because I have to.
Speaker 4:Right, absolutely. I think when we come together from an ER perspective, we're able to see that cross department kind of discussion take place, and sometimes it's between the credit administration and the producers, right. But we'll see things where, you know, maybe we see a compliance alert function, maybe BSA alerts, you know, is increasing and we have people around the room that say, oh yeah, I understand that, and then we're able to transfer that to see, okay, that's because we changed maybe how we were setting up a deposit product or marketing a deposit product, and that side, the institution, didn't understand the BSA effect that would come around, you know, a few months later. And so being able to have the same people in the room and then come at it from an ERM perspective really allows that executive management team to understand the interdependencies and connections between these different risks.
Speaker 2:And that's still right, ben, the products and services are so important that you have that cross-functional team at the table to understand okay, I have all these risks, and then your ERM person that connects it for everyone. But yeah, to your point earlier, yeah, I do see more collaboration with teams, especially in this environment that's so dynamic and you have to just react really quickly and maybe you want to get some loans in a different portfolio than historic. So, yeah, you're seeing a lot more collaboration than I think previous and I think the value of ERM is becoming ever more apparent with the quick know, the quick environment that's going on.
Speaker 1:Yeah, for sure. That makes a lot of sense to me. So let's talk a little bit about so. There certainly is value in getting the stakeholders in the room having these discussions. You know understanding, you know the risks and how we're doing inside of the organization. So when you're building an ERM program, you know we'll take it back a couple steps. What decisions early on will most likely help lead to a successful program at the end of the day?
Speaker 4:Yeah, I mean I would say it really starts with a risk appetite statement. That's kind of the central fundamental document for the program and a lot of times that document's approached and it's very limited and it really doesn't serve a strong purpose. And so I think approaching that document with a thorough understanding of where your risk exposures come from right and they're derivative of your product and services Jessica mentioned product services earlier Execute a product service kind of assessment really across your taxonomy from a risk perspective and use those results as inputs into kind of organizing inherent risk factors that contribute to an appetite right. Really structure your risk appetite statement in a better way than just listing, you know, risk categories and kind of going up low, moderate, high, limiting it to that. Make it something of value. The other thing I would just throw real quick is a lot of institutions will select, they'll go out and think, hey, I'm going to go find a software program, a grc program, when I start erm and that's I got to call time out.
Speaker 1:What does grc stand for? Ben governance risk compliance okay, great, thank you, and so they'll go select a program from an
Speaker 4:expensive vendor that they signed a four to five year deal and then they're stuck with this thing and they think that that is going to give them ERM, when it's not. You really need to know who you are from an ERM program perspective until you make these large system commitments right, yep.
Speaker 1:So you're going to do a little soul search on the front end Right.
Speaker 4:A lot of those systems aren't built by risk professionals. They're built by. It developers and without having an understanding of your own program, you get kind of locked in and then you feel like you're chasing something that doesn't even reflect who you want to be as an institution. So I would just say approaching that decision very carefully and patiently and really working internally first before you go outside.
Speaker 2:Yeah, I couldn't agree with that more. I mean, when I think back of my career thus far, that has been a left turn many times. So, yeah, it's really important to select a GRC that's probably not overly complicated, especially at the beginning, like, or something that gives you some content that you can turn key, because it's a huge effort to really start from scratch and often you end up abandoning those programs. You spend a lot of money and then it's hard to make the business case to say like well, this next program's it.
Speaker 3:I know this one's it. This is going to work.
Speaker 2:So you know, being very careful to Ben's point about your selection and if you can start out more basic with a tool that gives you some of the content, gives you some of the building blocks, don't worry about having to have your program fit it exactly. I think it's important to just get started and later on you can get into that more expensive tool if that's what you want to go for.
Speaker 1:So get started, get some quick wins under your belt and grow it as you go. That kind of an idea.
Speaker 4:I think between Jessica and myself we've probably seen every GRC software out there and worked with all of them. And they all have challenges, right For sure. So giving yourself some optionality, especially in the early stages, maybe from like a contract perspective where you have an off ramp, maybe a year or two in, or you can get off if things aren't working out and you're not stuck with a five-year deal, something like that, because I think, would you say, the majority of the ones we've worked with, we've had it like you know they've been failures essentially right.
Speaker 2:We've had issues right yeah, I mean, that's maybe real strong, but yeah you know, I think you um yeah, it's it's.
Speaker 2:It's just, it's a tricky space and, um, you don't want to get locked and they all try to be something for everyone, and that's sometimes the pitfall of a GRC. So if you have one, that's great and a couple of things, that's a win, that's huge. So it just can't be everything to everyone. I just haven't come across that unicorn yet, but maybe someday. But yeah, I think that's a huge thing.
Speaker 2:I guess some other pitfalls that I would avoid, or some advice I'd give to people that are just starting their program, or maybe even if you are coming in and someone made some missteps is go interview your executive leadership team and understand what is it that they want and what is their perception of risk, especially if you've had a leader that maybe took them in a different direction. They may think that ERM is just operational risk or why do we really need it? So helping to set expectations and also build the program with what that institution needs is key, and you're also building all the relationships at the same time. So it's really facilitates two things. And then the last point I'll bring up is that if you can build a program to scale, it's so important because the last thing you want to be is ahead of where your business is. That is not a good spot to be in, because then they view you as too bureaucratic, clunky, not providing that value. And then the flip side is, if you're behind the business, you're scrambling.
Speaker 2:And you probably have crossed some regulatory threshold that you're now kind of preventing the business from moving forward, and so you have to understand what's the strategy of the bank or the institution, because if they're really acquisitive, maybe they're at the $5 billion mark, and so you have to set your program so it's scalable. But you certainly don't want to make it where you're going to alienate your employees.
Speaker 1:And that makes sense to me. So you know we talk a little bit about building an ERM program, so maybe let's talk a little bit about for those folks that have an established ERM program. You know what are the areas of improvement for those who have maybe been doing this for a while. That again bringing from your perspective that you've seen.
Speaker 4:Yeah, I'd say two areas come to mind.
Speaker 4:Going back to the risk appetite statement, you know, using that document as a governance tool, right as a gatekeeper, and thinking about including in your risk appetite statement statement a listing of products and services that align with your risk-taking philosophy as an organization and including maybe a list of product services that don't align with what you're trying to do.
Speaker 4:That way, if the organization decides, hey, we're going to offer a different product than we ever offered before, like maybe we're going to offer a buy now, pay later product, we need to go through some type of governance exercise where we reconsider our risk appetite right and how it fits in with this product and service, and using that risk appetite statement as a way to kind of gatekeep products and services. I think that's key. Another one is really thinking about risk, especially our risk metrics in terms of a range of outcomes, and less about binary you know, did I meet a threshold exceeded or am I under the threshold? Really thinking about how to report and monitor risk across a distribution or a range of outcomes that will help the organization. I hope you're reporting so much more in terms of you can watch as risk start to escalate, right, and you're not waiting to have a discussion until you're bumping up against a threshold? Yeah, Okay.
Speaker 2:Yeah, I mean Ben hit the nail on the head. The risk appetite, I think Ben mentioned it before. It's often this document you do once a year, you let the dust collect and then you dust it off for the next time. But if you can make that so much more meaningful to people and, like Ben said, you have these ranges for your metrics, it's going to drive the conversations. It's really what sets your whole program and so if you do have one of those where it's a once a year activity and then you just monitor to it, then I'd say, go back and you can make that better, you can operationalize it, because the last thing also that you want is if someone they just report that metric for you.
Speaker 2:Yeah that's not what you want. You want them to be able to use that in their business and help them manage better. So going back and getting that right is so crucial and something that I think we overlook. We think, okay, yeah, we check, we did that, but we don't go back and really realize the value. But it is the most fundamental component of the whole program and it's really like Ben said, if you have these ranges for metrics and you can articulate even qualitatively, how, like someone that's external to the company, if they can pick that up and understand. Yeah, I understand that's going to be key and to help you be proactive, you need the ranges and I would just say you know you can. If you don't have that right, you can often end up being this glorified reporting function. You know some people like joke, you don't have that right.
Speaker 1:you can often end up being this glorified reporting function Right.
Speaker 2:You know some people like joke oh it's enterprise reporting. So you know, it's very important if you get in that rut to get out of it. And that's where dashboards come into play and that's where, if you can get industry data and peer data, that's going to be super helpful because you're now not just looking at how you view yourself internally, but also how has your regulator going to look at you, how it's the analyst looking at you. So that is super key in terms of having a good program. And if you get into the reporting function and you're just aggregating things that oh, we talked about that in like five committees, guys, you need to get out of that.
Speaker 4:Yeah, yeah, and I think that's a great point. And yeah, we've been able to work with clients where they ask us to come in and maybe you know recently we were talking about liquidity. They say, all right, help us understand our liquidity risk appetite. We've been saying it's low or on the low end, and then we go in and we kind of do a look back through their liquidity measures and we bring them up against peers in industry and we're like no, you've actually been operating kind of the 65th, 70th percentile for the last 20 years in terms of the liquidity risk you take. So there's no way you can call yourself a low risk appetite or you've just been operating even exceeding that by far.
Speaker 4:And so we're able to reposition them a little bit. And once we reposition, all of a sudden everything makes more sense. Right, because as we take more and more of these kind of financial risk, credit, market liquidity, we should be getting compensated for those risks. There should be a risk reward balance. That shows out in our strategic risk measurement as well, and so it kind of all relates to each other and they were struggling with that. And once we were able to, to Jessica's point view it in terms of how we sit relative to an industry, our peer group, you can really better understand. Okay, well, what kind of risk are we taking relative to other people?
Speaker 1:Right Perspective is key in all of this. It can help so much I like it. Right Perspective is key in all of this. It can help, so much I like it. You know it seems like we're talking about best practices a little bit now too. So you know, as we continue down that path, you know where and how have ERM programs failed to produce the value that we've been talking a little bit about for the institution and, ultimately, how can we help the listener avoid these pitfalls?
Speaker 4:Yeah, I'd say one of the biggest challenges when I go in and help institutions who are maybe struggling is we look at their program and a lot of times they focus more on risk assessments before we focus more on assessing qualitative risk, before we've measured what can be measured. And so I always say, when you're in the program, first measure what's measurable, then get to kind of the qualitative risk, right. And I think the second part of that is, once you start measuring your qualitative risk, you know, don't start with controls, right. A lot of people will start controls work their way back to risk. Don't even start with the risk.
Speaker 4:Start with the management objectives, right, you should be able to link, you should be able to go to any of your executives and say, hey, this risk, we're monitoring this risk because it threatens this objective, right, this is an objective that's challenging the organization that we're trying to accomplish, right. And so we want to link everything to management objectives and basically ERM is a partner with management and helping them achieve those objectives by identifying these threats, right. And so those would be two things, you know, just making sure that you start with objectives when you're doing a risk assessment and then measure what's measurable, first, in terms of data, what can you quantify before you get to the? How do I quantify a qualitative Sure? Yep, yep.
Speaker 2:Yeah, I think that's well said, ben. You know, if you just do all these qualitative assessments, or maybe some even mix of both quantitative and qualitative, you're going to end up with this big giant paperweight. Um, I can see it visually in my mind it's this big stack of papers yeah, I may or may not have produced some paperweights right right, um.
Speaker 2:So, yeah, I think you're to your point, ben, if you really focus on your quantitative, that's where people are going to grasp it and then you bring in the qualitative and to your point. Um, you don't want to focus too much on risk or controls, as then people think like, okay, what are we doing here? Um, but if you focus on the objectives and you take your strategic plan and your capital plan and you say, okay, this is what's important to us, this affects everyone. How are we going to get there and how, uh, will we bump into roadblocks? If you can focus on that, that's going to be huge, because you're going to see some things that you wouldn't have seen, versus if you're just down here in the weeds like, okay, what could happen here? That isn't always the most value add.
Speaker 4:Yeah, If your organization, if members of your organization are confusing you with internal audit or external audit, you've gotten to lost in controls. You need to go up a little bit. Doesn't mean the controls aren't an important part of the conversation, but they should be seeing you as separate right.
Speaker 2:Yeah, I mean if they're blurring and they're saying did the guy with the beard just come?
Speaker 3:and talk to me.
Speaker 2:Then that's a problem.
Speaker 1:So I want to shift gears a little bit and really maybe send this out to you, jessica how has the regulatory landscape changed since Silicon Valley Bank and you know, where do you see it going?
Speaker 2:Yeah, it's a great question and I wish I had a magic eight ball here, but I mean, I think as a general statement, there's more focus on risk programs. So I think there's even more importance to getting that in place. You know the FDIC has published proposed rule making that some really heightened standards on both corporate governance and risk management, and you know that's really a play off of the OCC's heightened standards and the Federal Reserve's enhanced prudential standards. But they're lowering the threshold. So where those are coming into play at $50 billion and $100 billion, this is $10 billion and up.
Speaker 2:So you're really seeing a reaction of, hey, these risk programs and really good governance for your board and action on your board is super, super important. So, yeah, I'm definitely seeing a lot of that just generally in the industry. And then, of course, the obvious, just more focus on market and liquidity, making sure that your board has a direct line of communication to those risks and also that you know what will be determined is if that the capital requirements start getting increased. And I think we saw this week some of the stress tests be released from the big banks and maybe it's not quite as bleak of a picture and maybe we don't have to get to that 16% that I think they were proposing. So maybe it's less than that, but nevertheless that's going to have a huge impact on institutions.
Speaker 4:Yeah, we don't know what the outcomes of the Basel 3 endgame are going to look like and we've seen different proposals come across for some of liquidity, where institutions may be required to hold a certain percentage of their underserved deposits at the Fed at the discount window. Even so, there's a lot of different proposals out there and I think there's a lot of uncertainty for sure.
Speaker 1:So I'm going to direct this question to you now, ben. You talk a lot of our clients about their programs, or their establishing them, or existing or best practices, that kind of thing. As you look at that kind of landscape, what are the biggest needs or challenges that you hear when you're speaking with clients?
Speaker 4:Yeah, we've met with a lot of proactive CEOs, cfos and chief risk officers who are wanting to make sure either put an ERM program in place or want to redevelop their ERM program after the events of SVB, where kind of liquidity and the rising rates and what it did to our balance sheets kind of felt like it snuck up on a lot of people and they don't want a surprise. Right, they don't want to be surprised. I think that's the worst position to feel if you're an executive of a financial service is to be surprised.
Speaker 4:You don't want surprises, right, and so they're not waiting for regulators to tell them they have to do things. They see a lot of the benefits of kind of having a program in place to remove some of that uncertainty, and I think that's been big. And then, additionally, as we all kind of you know, there's a challenge for deposit sourcing, right. There's a challenge also on the loan growth side and with pricing. You're seeing a lot of new relationships with fintech and developing new products and services and considerations of what should I be offering right and that brings about. What are the risks right? How should I think about those risks? What is a good way to incorporate a thought process into evaluating the risk and how much risk am I currently taking right? And so all these are things that ERM helps to answer, and I think you're seeing that push, you know, come, come through those two ways. Yeah Well that's great.
Speaker 1:This has been a lot of fun. You know, we could sit here, I'm sure, for another hour and kick this stuff around, but we are butting up against the clock, so maybe I'll just ask each of you for any clothing closing thoughts for your listeners.
Speaker 2:Anything I forgot to ask or you forgot to address? Well, I hope we've answered the existential question of the why for ERM. Yeah, I think that the only other thing I would say is that just don't discount the fact of building your risk culture and making yourself be a trusted advisor in the whole process. That's really key. I think it's something that is super qualitative and a super soft skill, but it is really important to build that risk culture and have that tone from the top to help progress and mature your program.
Speaker 4:Yeah, I think that's a good point. On the culture of how, the soft, we've talked a lot more hard stuff today and the why, but the soft thing is really important from a culture standpoint. A lot of organizations have really good cultures, right. They have really good risk-taking philosophies and those are embedded in kind of the relationships that exist with the executive management. Well, those management teams turn over and there's a lot of turnover coming across management teams as certain demographics and we age out.
Speaker 4:Put that information, build something around your risk appetite statement that really ingrains those philosophies and that culture on paper that you can then push out to the organization, you can hand to new leaders, new managers, new directors and you can really carry that culture through through the years as you have changeover. And I think that that's important because, at the end of the day, there's a lot of decisions at the organization that are going to be made day-to-day tactical decisions that you know ERM is going to be not, they're not going to be involved in those right. That that's just tactical in those right, that's just tactical. But you want to have a culture in place that addresses those in a similar way as your risk appetite statement would align with them right. It would kind of inform those decisions and make sure that we're all operating kind of with that same goal in mind. That's been great.
Speaker 1:Well, I really want to thank you both, Jessica and Ben, for joining us today and sharing your insights on the importance of enterprise risk management programs as well as gaining internal alignment.
Speaker 2:Yeah, no, thanks for having us.
Speaker 4:Appreciate it, Mike.
Speaker 1:Once again, I want to thank Jessica and Ben for joining us today and sharing their insights on the world of enterprise risk management. My takeaways from today are one it's critically important to manage risk and not the regulator. Two, to use your ERM program to actively engage in understanding uncertainty, including using industry data to make sure you are where you think you are. And three, no matter the size of your institution, you should put a program in place. Side note, if you have reservations about creating a program because you are smaller. If you have reservations about creating a program because you are smaller, there are ways to get it done without adding FTEs At the end of each episode.
Speaker 1:I'd like to take a moment and let you know about some of the additional resources we have available. We have a robust workshop, conference and webinar schedule, so be sure to visit our website for more details on these, as well as our education hub and our resource center for recorded webinars, articles and more. As always, stay safe, stay healthy, and thank you for listening to In your Best Interest an ALM First podcast.
Speaker 3:Thank you. Risk and past performance has no guarantee of future results. Podcast should not be copied, distributed, published or reproduced in whole or in part.
Speaker 3:Information presented herein is for discussion and illustrative purposes only and is not a recommendation or an offer or solicitation to buy or sell any securities. The views and opinions expressed by the ALM First Financial Advisor speakers are their own as of the date of the recording. Any such views are subject to change at any time, based upon market or other conditions, and ALM First Financial Advisors disclaims any responsibility to update such views. These views should not be relied on as investment advice and, because investment decisions are based on numerous factors, may not be relied on as an indication of trading intent on behalf of any ALM First Financial Advisors product. Neither ALM First Financial Advisors nor the speaker can be held responsible for any direct or incidental loss incurred by applying any of the information offered. Alm First Financial Advisors is an SEC registered investment advisor with a fiduciary duty that requires it to act in the best interest of clients and to place the interest of clients before its own. However, registration as an investment advisor does not imply any level of skill or training.
