Page 23 TRANSFORMATION FROM WITHIN: THE CDBG CASE Scott Johnson, Northeastern State University David Kern, Northeastern State University Katie Haight, Northeastern State University Ryan Haight, Northeastern State University CASE DESCRIPTION This case is designed for the study of leadership and organizational change within a unit of a larger organization. As such it provides an important learning experience for students who are already managers or who aspire to that level of responsibility. The primary learning opportunities address building a vision at the unit level, restructuring for success, overcoming resistance to change internally and across other units of a larger corporation, building support with powerful sponsors, and the importance of communication and persistence where authority is limited. The case has a difficulty level appropriate for undergraduate seniors and graduate students, and is designed for courses addressing organizational change, leading change, and leading teams. It can be covered in a one hour class. Preparation for the case is expected to require 3-4 hours. CASE SYNOPSIS The case begins with the recognition by a senior vice-president that the inadequacies of a seemingly insignificant compliance unit could jeopardize the overall growth strategy of BOKF, a large regional bank holding company. Paula Bryant-Ellis agrees to take on the transformation of the CRA department into a modern Community Development Banking Group (CDBG) that will contribute to the overall strategy of BOKF, the parent banking company. The case covers the first two years of significant organizational change, with emphasis on creating a vision, restructuring the organization, and shared leadership at the unit level. For the first three months, Bryant-Ellis is learning the existing, inefficient and archaic process while she studies benchmark banking groups to crystallize a vision for the future and an initial direction for the group. Early in this process, she brings new leadership into the unit. The case chronicles the new leadership team's approach to transforming the basic functions of the group, while concurrently managing the old processes until the new ones are operable. The challenge is complicated by substantial resistance to change by executives in powerful operating divisions affected by the compliance responsibilities of the CDBG. Communication and collaboration across organizational silos and the role of powerful sponsors are key elements of the transformation. The case ends with a summary of \"early wins\" for the unit, and a list of challenges its leaders will face over the next few years. Journal of the International Academy for Case Studies, Volume 18, Number 7, 2012 Page 24 INTRODUCTION Steve Bradshaw, Senior EVP of BOK Financial Corporation, was concerned about the performance of the CRA Department, which had recently been assigned to him. The department was named after the Community Reinvestment Act (CRA), a federal regulation that encouraged banks to promote development in low-to-moderate income (LMI) communities through lending and investment programs. The bank had received \"satisfactory\" ratings over the past few years in CRA performance evaluations; however, government regulators were increasingly critical about antiquated processes, the lack of required policies and procedures, and the absence of initiative in addressing needed improvements. Failure to receive satisfactory ratings could jeopardize the growth strategies of the holding company. In effect, the performance of a single compliance-oriented department could hinder strategic action by BOK Financial Corporation (BOKF) and its subsidiaries1. The Board CRA committee, whose members included the chairman of the board and the CEO, met quarterly to review the status of compliance in this area, an indication of the strategic issues involved. As a member of this committee, Steve Bradshaw had observed two additional concerns. The CRA Department was not profitable, and had not met BOK Financial Corporation's expectations in serving the community. He had seen enough of the problems to know that the current approach was not working, and that little change could be expected under the existing structure. Steve acted quickly in addressing the leadership of the department. The new leader would have to be a self-starter and work with minimal direction. Due to the poor reputation of the department and the necessity of building cooperation with the business units, a candidate would have to understand the bank's internal culture, work across organizations and interact with senior executives. The idea of bringing in a compliance expert from the outside was discarded quickly. There were no obvious internal candidates. Paula Bryant-Ellis, although no longer with bank, fit the requirements of the position. She had worked in the high pressure lending activity, which operated under Steve Bradshaw's direction. Paula also had gained experience in another bank and had recently been working as an executive in an organization focused on community development projects. Steve believed that Paula had the background, initiative and interpersonal aptitude that would be needed. Paula Bryant-Ellis began her career in the accounting field before building a successful career in lending at BOK Financial Corporation and at another Oklahoma bank. In 2003, Paula had accepted a call to serve the community as a key player with Community Action Project of Tulsa. Her work in the community was rewarding, but she realized that she missed the \"action\" and intensity of her previous positions. The call from Steve Bradshaw was a surprise, but was intriguing. It combined the challenge of banking operations with the positives associated with contributing to the local community. The downside was that the CRA Department had a poor reputation in the bank, and was focused on compliance, which was not Paula's strength. But Steve was convincing, emphasizing the significant potential for growth, and promising a great deal of latitude. The opportunity was compelling. Paula agreed to accept the challenge. Journal of the International Academy for Case Studies, Volume 18, Number 7, 2012 Page 25 THE CRA DEPARTMENT The department had been created years earlier to deal with federal regulations of the Community Reinvestment Act (the acronym CRA was originally selected as the name of the department). Compliance is necessary for regulated banks if they wished to expand their businesses (e.g., acquisitions, branches and ATM). Banks are required to follow processes directed by CRA regulations, and provide loans and investment services to low-to-moderate income communities. Banks are required to document their compliance and periodically present their results in an examination of each bank subsidiary. The examinations involve performance evaluations of a broad range of lending and investment activities. These activities can be originated either by a community development group such as the CRA Department, or by business units within a bank. Consequently, examinations require coordination across multiple units. The responsibility for completing the reporting and providing documentation had been assigned to the CRA Department at BOK Financial Corporation. An effective approach should have included strong written procedures, experienced lending officers, and coordinated systems for reporting. This was not the case. At the beginning of 2004, the department was only meeting the minimum requirements of the regulations. Policies and procedures within the department were deficient or did not exist. There was no interface with the bank's loan systems. This led to a manual process of reporting and documentation. Loans were originated by CRA personnel with little underwriting experience and an inadequate understanding of credit policies and procedures. Lending decisions were often made on an ad hoc basis. The result was a significant portfolio of negative return loans. Other business units also originated loans that should have been subject to examination, but often were not recognized as such by CRA personnel. There had been no attempt to correct or even document procedures and performance. No meaningful effort had been made to improve efficiency. The department itself was a loosely organized collection of 19 people spread across five locations with the head office in Tulsa. The department focused on compliance reporting, ad hoc loan origination, and critiques of business unit practices. Attempts by CRA personnel to address compliance deficiencies in the business units were frequently presented negatively, accompanied by threats of examination failure, which ultimately led to an atmosphere of resentment and mistrust. The complaints of CRA Department personnel generally fell on deaf ears. It was no surprise that the CRA Department garnered little respect, and even less cooperation from the business units of the bank. Although the bank subsidiaries had managed to receive \"satisfactory\" performance evaluation ratings in previous examinations, there were warning signs that multiple problems in CRA compliance could lead to unsatisfactory ratings. Unsatisfactory ratings could restrict expansion plans of the parent company and its subsidiaries. As importantly, the inefficient processes and lack of profitability ran counter to BOK Financial Corporation's commitment to excellence. The corporation's strategic plans embraced excellence in all operations with full support from the executive team. The CRA Department was out of step by considering satisfactory \"good enough\". There were no plans for improvement. The department did little to actively contribute to the growth and sustainability of low-and-moderate income communities. With acquisition and expansion essential to the overall Journal of the International Academy for Case Studies, Volume 18, Number 7, 2012 Page 26 strategic plan, the potential failure in the CRA compliance activity developed into a strategic issue. It was in this environment that Steve Bradshaw made his decision to revamp the department. BUILDING THE FOUNDATION One of Paula Bryant-Ellis' priorities in August 2004 was to meet with executives and business line leaders in order to understand their view of the CRA Department and the potential for cooperation in the future. This would prove to be valuable in a number of ways. The meetings increased awareness that the area was important to executive management, that there was new leadership, and that cooperation would be necessary. These sessions would begin a pattern of communication and consultation with key individuals at the executive level in various bank groups and divisions who could provide support in overcoming resistance and facilitate necessary improvements in communication and cooperation. Another early priority was to successfully complete examinations in two bank subsidiaries, which would also contribute to a third priority - to gain an understanding of the regulations and the capabilities of the existing staff. The first three months involved long, frustrating hours working with local CRA personnel in preparing for examinations that would begin in the fall of 2004 for the Albuquerque and Arkansas bank subsidiaries. It would involve full immersion in coordinating the antiquated processes employed by CRA personnel, and in learning the compliance end of the business. The days were spent manually collecting and recording data, fighting fires, and trying to make some sense of the department. CRA Department personnel would make copies of documents and summarize on spread sheets, sometimes even by hand. The extent of the problem was driven home by a series of communications from one of the examiners who severely criticized obvious deficiencies in process and implementation. Problems in coordination and initiative within the department were typified by the lack of integration with Credit Services' recent upgrade of the bank loan system. No attempt had been made to integrate CRA activities into the upgraded system by either department. It was obvious that this was the wrong way to run a business. Without a background or experience in the compliance elements of the regulations, Paula worked nights reading the regulations in detail, and reviewing performance evaluations of other banks that had received \"outstanding\" ratings. These documents provided a view of what it would take to become a high performing community development group. Excellence could only be achieved with a comprehensive approach, incorporating strong compliance processes and meaningful community development lending, investing and services activities. It was clear that the most successful banks developed profitable lending and investment strategies, effective service programs for the community, and strong compliance systems and processes. The late night study sessions laid the groundwork for an outline that would be refined and enhanced by input from key players in the restructured group. The plan ultimately addressed four key thrusts: 1) establish a new direction; 2) build an effective group; 3) automate the arcane manual review process; and 4) create a culture of collaboration with business units. The reader should note, however, the word \"ultimately\" in the previous sentence. Developing the plan was a process that began with the broad, initial vision, which would gain clarity over time, and Journal of the International Academy for Case Studies, Volume 18, Number 7, 2012 Page 27 evolve as the new leadership team learned the ropes and began to solve the problems. It was a messy process, interrupted by the necessity of fighting the daily fires, but informed by study, analysis and open discussions among the new team members. THE VISION AND INITIAL STEPS Developing the overall direction was an important first step; however, building a comprehensive approach would involve a complex, evolutionary learning process that would take several years to produce significant results. The next step was to create a vision of what this group would ultimately accomplish. That vision would not allow continuing to operate as a cost center; nor could it accept merely \"satisfactory\" performance ratings. The vision focused on: becoming a positive force in supporting people and businesses in LMI communities; being recognized through the achievement of outstanding performance evaluation ratings, and contributing to the growth and profitability of BOK Financial Corporation. It would take the addition of experienced colleagues and several years before this vision would be fully developed into a formal plan. The initial plan was not documented as such, but one that involved a mix of doing and planning on the run. Formal processes and planning documents would have to come later. An essential early action in setting and communicating a new direction was to change the status and scope of the department. The CRA Department would become the Community Banking Development Group (CDBG). This name was chosen in a deliberate process that included all people in the department. The change redefined and expanded the intent and purpose of the group. The broad charge was to make CDBG an organization that fully represented the mission, vision and values of the bank, and its commitment to excellence. The change in name and status acted as a clear statement to those within the group. Externally, the new name and elevation to group status would represent both a highly visible statement of new direction, and a more powerful voice in cross-functional interactions. CDBG would be led by a senior vice-president, providing more effective access to leaders in larger, more powerful divisions and groups within the bank. This \"higher\" apparent status would also be important in providing position recognition when working with each of the leaders in bank subsidiaries and business units. The leadership team's work in the trenches and their study of successful community development organizations in other states provided an initial level of clarity to what \"excellence\" would mean. Three initial priorities emerged: achieve outstanding performance evaluation ratings, which would require substantial automation of the process and support from various business line partners; serve the low-to-moderate income communities more effectively and, aggressively build a loan and investment portfolio that would not sacrifice credit quality, have impact in the community as well as provide profitability for the organization. Journal of the International Academy for Case Studies, Volume 18, Number 7, 2012 Page 28 This plan would require the transformation of the internal group, while the leadership team continued to manage ongoing examinations. Unfortunately, the current staff had neither the skills, nor the structure to operationalize the vision. It was essential to add new leadership in each major area of responsibility, and to develop a core group of professionals in Tulsa. The new leadership team would multiply Paula's efforts and expand upon the initial ideas for the group. BUILDING THE TEAM The CRA Department had 19 employees spread over five locations with only a few in Tulsa. There was a void in leadership and little organizational structure. Every employee reported directly to the department manager, but much of the work was directed by the office manager. The skill set of most employees focused on clerical activities and manual preparation of reports. The current loan portfolio was unprofitable. There was little aptitude for investments and loans, which was essential in building a strong community development organization. There was no impetus for automation, which was typical of banks achieving \"outstanding\" performance evaluations. Other business units (e.g., Business Banking and Mortgage groups) considered the CRA Department a minor irritant, and did not welcome changes in their processes. People within the department were entrenched, and questioned the need for improvement. It was evident that minor adjustments would not suffice. The change would have to be dramatic, involving a different skill set, new leadership and a culture that embraced excellence and continuous improvement. The process started with the recruitment of two experienced managers who would drive the investment and compliance priorities. Angela (AJ) McKean joined CDBG as Investment Manager in November 2004. She brought a wealth of knowledge and experience in loans and investments both in banking and in community development. The fact that she had worked for Bank of Oklahoma for seven years contributed to her credibility with the business units. Her most recent position as executive director of the Tulsa Industry Authority provided insight into the community. Angela's input provided an important second perspective to critical early decisions for the group. Angela also started to develop opportunities in the investment arena, working with outside experts and across units within the holding company and its subsidiaries. Her expertise and experience within the bank and the community further enhanced the image of CDBG. In this time frame, Cassandra Burroughs was promoted from within the bank to Compliance Manager for CDBG. With seven years experience as a commercial loan officer, Cassandra contributed a strong banking background, but had little knowledge of systems and compliance. Her ability to grasp new concepts, hard work and driven personality would be essential to overhauling the manual processes. Hers would be a key area where automation was essential. The automation initiative would provide strong impetus for improving multiple procedures and performance evaluation processes involved in CRA examinations. As importantly, Cassandra eagerly sought the challenge with a high level of energy and commitment. By the end of 2005, it had become increasingly apparent that lending operations represented an important opportunity to support compliance activities and transform a seriously Journal of the International Academy for Case Studies, Volume 18, Number 7, 2012 Page 29 under-performing loan portfolio, and that it would need new leadership. In January 2006, Gail Banham joined the team to restructure the loan activity, and to make the changes necessary to develop a strong loan portfolio. Gail's background in commercial lending and in credit administration brought critical knowledge to the group. Gail recognized the lack of lending expertise in the group and began to build her team. Carl Shields was hired for the Texas bank subsidiary. Carl had twenty years experience in commercial, small business and community development lending. Lisa Albers, who had extensive experience in Bank of Oklahoma commercial real-estate, also joined the lending unit. The overall lending knowledge and capability of the Community Development Group was substantially enhanced. The issues of focus and structure were also tackled. Most of the new managers would be located in Tulsa, encouraging the existing staff to develop new skills, while adding experienced personnel where necessary. There was a shift from a loosely organized collection of individuals in multiple locations to a strong central group that would begin the process of building collaboration with the business units. The restructuring of the Community Development Banking Group was completed with an overall reduction of two positions, providing salary allocations to add experienced managers. The enhancement in human capability provided the resources needed for the group to tackle existing problems, automate systems, serve newly acquired subsidiaries and begin building profitable loan and investment portfolios. OVERCOMING EXTERNAL RESISTANCE Much of the initial effort was directed toward building a competent group with capable leaders; however, resistance to change from larger, more powerful organizations within the bank presented greater challenges. The business units continued to view CDBG as another version of the old CRA Department. CRA compliance was not their problem. This attitude was a major impediment for the CDBG leadership team, which could only be successful by working with business units and bank subsidiaries. How could a small organization with a poor reputation initiate improvements and change with large units whose key people did not share their vision and objectives? How do you lead a team to make sweeping improvements and develop new approaches and products, while operating an archaic process during the conversion? Paula Bryant-Ellis made key decisions early that would allow her to focus effectively on cross-organizational collaboration. The group had acquired experienced leaders who developed detailed plans and executed them in concert with the overall vision. That vision and overall plan was clearly and continuously communicated to upper management and leaders in business units and bank subsidiaries. Steve Bradshaw acted as a powerful sponsor for CDBG, providing support and assistance at critical times in the process. Steve's support was particularly important in assisting Paula in building alliances with key players in business units. Developing collaborative relationships involved a consistent approach. Paula and her key team leaders would identify an issue or opportunity. In each area, the appropriate manager would research issues and problems, develop initial ideas for solutions, and review with Paula prior to preparing reports or setting up meetings. Concurrently, CDBG unit managers would meet with business unit peers to establish a level of common understanding and begin building ongoing working relationships. The communication program operated at multiple levels. At the Journal of the International Academy for Case Studies, Volume 18, Number 7, 2012 Page 30 initial meetings with business unit leaders, Paula provided support to CDBG unit managers to encourage broad agreement on the issues and the options for improvement. These sessions would be followed with multiple meetings and contacts involving the unit managers and their peers in the business units. The process appears to be straightforward, but it frequently involved multiple iterations, starts and stops, personality issues, and, occasionally, failure to move forward. It was often frustratingly slow and difficult. In some cases, this influencing approach worked reasonably well. In other situations, this approach was not enough to assure compliance or collaboration. Members of the CDBG leadership team also visited key managers in the bank subsidiaries to build communications essential for a collaborative relationship. Paula would address \"how we will work with you and how we operate in your market.\" Unit managers would follow-up with multiple contacts. Previous successes and ongoing collaborative efforts would be discussed as examples of effective practices. Emphasis was consistently placed on working together for the benefit of the corporation and the bank subsidiary. This approach was particularly effective in reducing resistance and misunderstandings. Education and communication were the bedrock of the approach, complemented by the credibility built up with early and ongoing successes, and by the clear support of top management. In some situations, resistance from managers in a business unit or a department became enough of an issue that outside assistance was needed. Support from senior executives was necessary to move the process forward. The communication and improvement process was often complicated by the historically negative attitudes that had been created by the confrontational approach taken by of the former CRA Department leadership. Encouraging and leading change would require multiple approaches. Progress would be uneven. The CDBG leadership team often had to balance a push for timely change with the need to build long-term partnerships. Esprit d' corps within the leadership team and the overall CDBG was a critical element in breaking down external and internal resistance. Paula's collaborative and supportive approach to leadership was essential. Without Paula's encouragement and example, the resistance and roadblocks faced each week would have been overwhelming. More than one CDBG associate commented on the effectiveness of Paula's style in inter-division meetings, with a focus on factbased information, structure, and open communications. Among the CDBG team leaders, expectations were agreed upon and clearly stated. Each manager was encouraged to direct their individual area of responsibility with substantial autonomy. Support and assistance was provided when requested, but the managers were expected to take the lead in their area of responsibility. Additionally, the leadership team encouraged and supported each other. The positive internal culture of the group kept motivation high under difficult circumstances. Without the strong internal commitment to shared leadership, collaboration and support, the slow and trying process of moving resistors to compliers, and compliers to collaborators would have lead to early burn-out. The wear and tear on middle managers implementing significant change cannot be underestimated. The positive culture within the CDBG, and mutual support of the leadership team was crucial in maintaining the momentum, and in driving continuous improvement efforts. Journal of the International Academy for Case Studies, Volume 18, Number 7, 2012 Page 31 BUILDING A TRACK RECORD OF SUCCESS Procedures were addressed early in the change process. In the first six months, Paula, Cassandra and Angela developed and documented all key procedures while dealing with CRA examinations in the Albuquerque and Arkansas bank subsidiaries. This effort required a great deal of commitment and personal sacrifice in terms of hours and intellectual engagement, but the experience created the foundation for future successes. Whenever possible, procedures were improved in business units to encourage solid banking practices. The next major task was to embark on a comprehensive automation program that would transform the antiquated manual processes. Cassandra Burroughs took the lead as Compliance Manager, working with personnel in the CDBG compliance unit and partners in the Credit Services organization to build interfaces to the loan system. Recognizing that the task would take years with existing staffing and skill levels, external firms were engaged to accelerate the automation process. By the end of 2006, virtually all systems had been converted from the manual process. This was a major step for the group - one that had relatively wide visibility with senior executives and business line managers. Angela McKean had to start from scratch. Under the previous management, there had been little effort to engage in community development investment activities. After policies and procedures were developed, she began work on long term investment programs. By 2006, the first of these new investments were approved. This long term approach created the foundation for building a strong investment portfolio. By developing effective investments and exploring potential opportunities in tax credit investing, CDBG began to receive support from key executives in the Tax and Finance Department. This support would be crucial for developing long term profit strategies. Educating partners in the bank about the substantial long term payoff was as critical as identifying the investment opportunities. The most effective banks prioritized the lending activity as an opportunity to build longterm profitable business in developing communities, usually requiring focus and leadership by the community development banking organization within the bank. This type of leadership was lacking in the old CRA Department; however, it represented a significant opportunity for the restructured Community Development Banking Group and for the corporation. This opportunity was addressed when Gail Banham hired experienced lenders who would generate profitable, credit-worthy loan business that would meet regulatory requirements. As importantly, they would work with business unit and bank subsidiary managers to build a profitable loan portfolio that met regulatory requirements. Changes in standards for profitability and new loan development set the stage for dramatic improvements that would rebuild the CDBG loan portfolio as a consistent and profitable business for the corporation. The crowning success, however, was in receiving an outstanding rating for the flagship banking division, Bank of Oklahoma. This achievement reflected improvements in every area of CDBG, and was the \"aha\" moment for many skeptics in other parts of the bank. This achievement capitalized on all of the small and big successes the CDBG team achieved in two years, including documented procedures, automation, improved processes, a new investment program, a restructured CDBG organization, and an effective lending unit. Not only was it a source of intense pride for the \"team\