Great. As everyone takes their seats coming back from lunch, we could put up the first ARS question. Kicking off this afternoon, slate of banks, very pleased to have KeyCorp with us. From the company, we have Chris Gorman, Chairman and CEO, and Clark Khayat, our Chief Financial Officer. Chris has, I think, one slide and some brief comments he's going to make to kick it off, and then we're going to sit down and take some Q&A. Chris?
Well, perfect. And thank you, Jason. We always look forward to participating in your conference. I'm joined today on the stage by Clark Khayat. Clark's our Chief Financial Officer. On slide two, you'll find our statement on forward-looking disclosures. These statements cover our presentation materials and comments, as well as the question and answer segment of our presentation. Now, on slide three, we will devote most of our time this afternoon to Q&A, but I want to begin with just a few opening comments. This continues to be a very challenging time for our industry, but with challenges also come opportunities. Key is well positioned to continue to serve our clients through all market conditions and deliver long-term value for our shareholders.
It starts with having a solid foundation with a strong core funded balance sheet, supported by our long-standing strategic commitment to primacy, namely, having our primary operating account. There's been a lot of focus on our balance sheet positioning, which has clearly been a near-term headwind. However, over the next six quarters, Key will benefit from a well-defined net interest income opportunity as short-term swaps and treasuries reprice. As I mentioned during our Q2 earnings call, we expect our interest income benefit to reach approximately $900 million on an annual basis by the Q1 of 2025. We also benefit from a strong fee-based business, with approximately 40% of our revenue coming from fees, a competitive advantage in the proposed new regulatory framework.
Our fee businesses are driven by our leading positions in capital markets, payments, wealth management, and commercial real estate, and that's commercial real estate services. We have growth opportunities in each of these areas, including significant upside as capital markets return to more normalized levels. We are also continuing to focus on improving productivity and efficiency. Earlier this year, we successfully completed a company-wide initiative to reduce our annual expense run rate by $200 million, which in our instance, is 4% of our annual spend. We will further reduce expenses in the second half of 2023 and accelerate our plan, our plans to streamline and simplify our businesses and position Key for success in the future environment and the post-Basel III environment. Another strength of our company is credit quality.
Credit losses remain relatively low across the entire industry, but as we move through the business cycle, asset quality will matter. Today, more than half of our C&I loans are investment grade, and over 70% of our consumer originations have a FICO score of 760 or greater. These measures reflect the de-risking of our portfolio over the past decade in concert with our underwrite to distribute model. Key also has very limited exposure to leverage lending, office loans, and other high-risk categories. Our exposure specifically to B and C class office space in central business districts is a total of $121 million. We continue to benefit from insights gained from our third-party commercial real estate servicing business as we service over $630 billion of off-us real estate debt.
I also want to comment a bit on the Basel III Endgame. We continue to be proactive from both a balance sheet optimization and capital allocation perspective. We are well positioned to build capital and reduce and reduce risk-weighted assets. We will reduce risk-weighted assets by approximately $10 billion during fiscal year 12/31/2023. We will continue to prioritize full relationships and exit non-relationship business and non-strategic assets. In the Q2 , our period-end loan balances declined by $1 billion. We anticipate an acceleration in the pace of reduction in the second half of this year. As I mentioned earlier, we will continue to benefit from our strong fee-based businesses, which make up a significant portion of our revenue. As capital markets normalize, we will utilize our differentiated platform, driving fee income and reducing our balance sheet exposure in the ordinary course of business.
On the capital front, we will benefit from ongoing capital generation and the roll down of our AOCI over the next six quarters. We expect our Common Equity Tier 1 ratio to be above our 9%-9.5% targeted range by year-end. I will close by reaffirming our earnings guidance for the next two quarters and for the full year, consistent with that which we provided during our Q2 earnings call, which is included in the appendix of our presentation. I am confident in the long-term outlook of our business. Our business flows are good, and our risk management practices are strong. Today, we are under-earning due to our short-dated swaps in Treasury securities, which will mature over the next six quarters.
As these positions mature and capital markets activity normalizes, we expect to deliver results which reflect the long-term earnings potential of our company. With that, Jason, I'd like to turn it over to you, and we can jump into the Q&A. Thank you.
... So, Chris, while those were short remarks, there was a lot in there. So I do want to follow up.
Short from a time frame perspective.
Yes. RWA is coming down $10 billion.
Mm-hmm.
-this year.
Mm-hmm.
Although you kind of stuck with your loan growth guidance and your NII guidance, do you want to just expand in terms of, you know, what, how you are reducing RWAs? And then, you know, I would think there'd be more of an earnings impact that maybe not this year, how it thinks about your thought process for next year.
Sure. Well, thank you for the question. And obviously, the premise of the question is that RWAs are dropping significantly at a greater rate than our loans. And so there's really a few things. One is we've gone through our portfolio, and a lot of our—a significant amount of our portfolio has unused lines, Jason. And to the extent you're exiting credits that don't make sense from an earnings perspective, and you have unused lines, that gives you an opportunity to do so. While I'm on that point, we have literally ripped through our portfolio, and any business that's not returning our hurdle levels, and obviously, the number of businesses that are returning at our hurdle levels just went up, given that the amount of capital has gone up and the cost of capital has gone up. We're exiting those businesses.
Then to some extent, there's also, as we looked at our portfolios, there were opportunities for us to reclass RWAs, both on an idiosyncratic basis, and on a portfolio basis. Which leads me to the second part of your question, Jason, is: Is there a huge impact with respect to earnings as we go forward? The answer is, it's some impact, but for example, if you're looking at whether it's a reclass or whether you're exiting unused line fees, there's absolutely zero impact. So in each instance, we're exiting business that we don't think gives us the return that we want. In some cases, the leap of RWAs is free, so to speak.
Okay, that, that's helpful. Any particular examples of businesses you want to talk about? I know you guys were early in terms of getting out of indirect auto, a few years ago. Anything else of consequence, or is it more kind of smaller hobbies?
I think you could assume that it's mostly smaller hobbies, but when you go about the business of reducing expenses, one of the best ways to reduce expenses is to stop doing things. And like indirect auto, which we exited in 2024, we had about $4.4 billion of exposure. That's a nice opportunity to eliminate the expenses in the front, middle, and back office. So more to come on that as we, as we work through the balance of the year, Jason.
And then you touched on, you know, the opportunity from net interest income as swaps and treasuries reprice. You know, it seems like it's a, you know, meaningful benefit over. You know, I guess we should start to begin to see it, you know, nearer term. Just may talk to, are there any kind of risks or concerns that you're not going to be able to benefit that, or, or just, you know, is that just a function of timing?
Well, a huge function of it is timing, and I'm going to ask Clark to comment on the specific drivers that could move it up or down. But the important thing to think about is these short-durated swaps and treasuries is that really the only thing, when I say the only thing, 85% or 90% of it is all based on nothing but timing. Now, having said that, there are obviously variables that could impact that. Clark, do you want to comment on that?
Sure. So, I mean, look, as rates go up, there's more benefit when you come out of the treasuries and the swaps. There's also likely more funding costs, so it moves a little bit in tandem. Same thing on the way down. I think if you isolate this opportunity, what happens to the swaps and the treasuries? The biggest risk is rates come down, and your reinvestment rates lower. We have offsetting benefits in that case as well. So we do think there's a little bit of movement kind of in either direction to support that, but it will largely be timing, as we talked about. So as you get through the second half of 2024 and most of this is rolling, then, you know, you're starting to see it really pull through heavily. We are going to see treasuries start to mature this quarter.
So we've been talking about this now for 12 months, and we will see the Treasuries. We'll see, you know, close to $3 billion of swaps over the last two quarters of the year, and then, you know, all the things we've talked about before.
And all that incremental revenue from that roll-off, we should find its way to the bottom line?
Again, it depends. I think if you look at it in a stable rate environment, yes. As rates go up, the benefit increases, but cost increases. Rates go down, the benefit decreases, cost should decrease. And again, there's some timing mismatches in terms of betas and when things like that would get deployed, but it should be sort of, work in tandem to some degree there.
Gotcha. And so, you know, we, we talked about kind of earlier, the guidance. I think we had NII down 4%-6% in Q3, getting better to kind of flatten down only 2% in Q4. As we start to think about 2024, is it safe to assume we could start to see maybe gradual NII NIM growth from there? Or how should we kind of think about that backdrop given this repricing scenario?
Yeah. So we'll obviously give full guidance when we give full guidance, but I think it's safe, given that portfolio, to expect NII NIM to go up in 2024 as we move through the year.
Got it. And then, on deposits, you know, I think the guidance was kind of relatively stable for Q3 and Q4. You know, you reaffirmed that. I guess maybe just get some more granularity, you know, around that in terms of maybe how deposit costs are, are moving, deposit mix, deposit beta expectations.... I know there's catch up this year and just kind of what you're seeing today.
Yeah. So, you know, we said nearing 50 as we got through the year. I think that's still pretty safe. I think we are seeing stability in the deposit base for sure. We are seeing the slope of increase in betas plateau some. So I think, generally it's all, I think, constructive. And our stable to flat, I think this is an important point on deposits, our stable to, to flat on balances is also working out of our brokered deposit mix. So we're really replacing a lot of brokered runoff with customer deposits.
Got it. And then with respect to loan growth, I think that's one of the things in the conference, is it seems like loan growth has been a bit, you know, sluggish. You know, your, your guidance kind of incorporated that to be down a little bit, each of the next two quarters. Maybe just talk to, I guess, on the supply side, you know, how much of that is tied to initiatives to manage RWAs more carefully versus demand side, where, you know, the economy is slowing, borrowing costs are higher, and, and maybe borrowers are pulling back?
I think it's some of each. Clearly, in our instance, we are aggressively managing our balance sheet, and so we are engaging in new loans because we're supporting our clients. But we're also. We ended the Q2 down $1 billion in loans, and we've guided that we're going to continue to be down. I don't think there's robust loan demand right now. As we look at, for example, at utilization, we've been flat at about 32% over each of the last three quarters. So I think it's on the supply side and on the demand side that we're seeing sort of tepid loan demand right now. There's also not a lot of transactions. I think that will change.
One of the things that really drives loan demand is people making significant investments in property, plant, and equipment, and people doing strategic things. And I think as there's more clarity, higher for longer, I think you'll start to see more demand out there.
Then, you know, you stuck with your, you know, fee income guides above, I think, two-four and four-six, this quarter and next quarter, respectively. One of the themes kind of coming out of the conference is, while maybe July and August was soft from a capital markets perspective, it feels like the tone coming out of Labor Day was a bit better. You guys have a very solid capital markets operation. Maybe just provide some more context in terms of what you're seeing there.
No, I think your point is well taken. I mean, granted, these numbers are coming off a very low base, so you have to qualify what I'm going to say. But clearly, to this day, I see pitch activity, and pitch activity for the months of September and October, very significant. So people are starting to think about strategic things. You know, in the last couple of weeks, you've started to see some initial public offerings roll out. This, believe it or not, was the second worst year in the last 50 years on the IPO side. On the M&A side, starting to see the private equity community start to both be a buyer and a seller.
They have really been, in the middle market, they're a big part of the of the market, and they were basically on the sidelines this half. So I'm not realistic. I'm out talking to all our clients all the time. I think there had been a real pause in terms of people not knowing where the economy was going to go, not knowing what the cost of capital was going to be, and there was sort of, and I think it's starting to sort itself out. It's not going to come, it's not going to come roaring back. Just to frame it for everyone here, our capital markets business on an annual basis has kind of a run rate of, call it, $900 million. In the last quarter, we had $120 million in revenue.
So it's clearly coming up, but it's coming off an artificially low base, which I think is an opportunity as we go forward.
Got it. And then on your slides, you talked about aligning expenses with revenue opportunities, targeting additional expense opportunities in 2H 2023. You're shedding $10 billion of RWA. Maybe just talk about how, you know, smaller banks, potentially smaller expenses, you know, what are you working on there? And, you know, you talked about a 4% expense reduction program. Just how does that position you as you kind of enter 2024?
Yeah. So to kind of get to sort of the headline here, I think in 2024, our expenses will be roughly flat, and that will include both a lot of expense cuts and investment. Because I'm a believer that you can't ever put yourself in a position where you're not investing. So we took out $200 million in the Q1 . And what we're going about the business of doing that I mentioned from my prepared remarks is we will, we'll take out more expenses. What we'll focus on is not just cutting by 5%, but figuring out those businesses that we don't think make sense in the new kind of Basel III Endgame. So it won't be necessarily whole businesses, but it will be activities within those businesses.
Okay. And then maybe on credit quality, just maybe any developments on the credit front, any changes in lending standards, just how you're thinking about that?
So, absolutely no, no changes in lending standards. And I say that because I'm a big believer, you can't have a bunch of variation in what you're willing to do from a lending perspective. It's not good for your customers, and it's not a good way to run your business. Oh, by the way, if you wait until you're at sort of the end of the cycle, and you start making adjustments, it's too late anyway, because you own what you own on your balance sheet. But with respect to our credit quality, I feel really good about it. We, we charged off 17 basis points in the Q2 . We've guided through the cycle being at 40-60 basis points. I looked very closely at this.
I don't see any path, absent something significantly geopolitical or something, I don't see any path for us to get to 40-60. We've got, 50% of our C&I loans are investment grade. Average FICO score, in consumer 760. The consumer's in good shape. You will see some migration in terms of criticized and classified. When interest rates go up, to the degree that they have, the trajectory that they have, we look very closely at places where there's any leverage and where, and the business model could, you know, could come under pressure. Having said that, while we might see some migration on criticized and classified, I don't see loss content there.
And then, you know, your allowance, though, is up, like, 18 basis points over the last 2 quarters, combined. You know, definitely 17 basis points of charge-offs in that span. Your office exposure, I think, is surprisingly much, much lower than anyone else I cover. I guess maybe kind of, you know, what's, you know, driving that build, and kind of how do you think the reserve position now that you've kind of added more to it versus half?
Well, we're pretty conservative. The biggest thing that drives under CECL, that's supposed to be proactive. The biggest thing that drives it is: What's your view of the economy going forward? And in each of the last three quarters, you know, unambiguously, if you look forward, it looked worse going forward than if you look backward. And so we felt the need to build reserves there. We're actually shrinking our loan book. That's another thing that would drive reserves. And the third are kind of idiosyncratic risks. And as I mentioned, as we went through the portfolio, in general, we felt good about that. So I think right now our reserves, I think cover seven years at our current charge-off levels. I feel good about it, but we're pretty conservative when we take a look at things like that.
I just think it's important to be proactive and build the reserves.
Yeah, I meant to ask this earlier, so I go to now, but, Laurel Road, maybe provide us an update, and just how does that fit into kind of all the stuff we talked about?
Sure. I'd be happy to. And, Clark's been intimately involved in Laurel Road. Let me kinda kick it off, and then, we can talk a little bit about it. So Laurel Road is a business that we bought, that is in the student loan refinance business. It's a complete digital approach, basically for doctors and dentists. We then, the next step is we built it out so it wasn't a single product company, so that digitally, we have 80 some odd partners, people like the AMA and the ADA, so that digitally, you could have a checking account, you could have a savings account, you could have a credit card. Then we built it out to include nurses. Nurses obviously expanded the loop a lot. Then we bought a business called GradFin.
GradFin is a really interesting business because they are the leaders, and we got to know them through the student loan business. They're the leader in providing advice on should you refinance the student loan, and also do you qualify for public service loan forgiveness? So everyone that works at a hospital, not everyone, almost everyone that works at a hospital is a works for a not-for-profit. And now the government has really expanded the opportunity under Income Based Debt Repayment. So that's a way that we can continue to grow that business. Now, what will change going forward, if you think about the new asset-light model, is we will go back to securitizing and selling student loans as opposed to putting them on our balance sheet.
Because if you think about the Basel III Endgame, we'll have to make some changes to our business as we, this, asset light. Clark, would you add anything to that?
Yeah, I think we always intended to build it as a full service business, and we'll continue to do that. But to Chris's point, we'll revert to, you know, moving the loans rather than holding them.
Got it. And then, Basel III proposal, you kind of touched on it a bunch. If we could put up the next ARS question. But, you know, I guess a lot of different views on the impact of the NPR. Maybe share kind of what you think about it overall and maybe implications for the industry and for Key?
Well, I will say this, it came out about how we thought it would. I mean, I think it had been telegraphed very clearly. There are certainly some things in there that I would say are positives. There are some things in there that I think as an industry, I think we have some concerns about. To your specific question around RWAs, I'm going to ask Clark to answer that because we've done a ton of modeling. And Clark, how would you respond to that?
You know, there's puts and takes. Obviously, the Op Co piece is brand new. That's going to add for everybody's. I do think what is reflected in the NPR is very consistent with the way we talk about our credit profile. So 50%+ C&I's investment grade, that'll get some RWA value in the new outlook. Our CRE portfolio, similarly, it's an LTV stratification, not just 100%. Most of that is, you know, 60% or lower, so we'll get some real benefit there. There's some other portfolios that sort of go in either direction, but I think net-net-
... you know, the credit quality is largely offsetting the addition of the Op Co piece.
So don't expect much RWA inflation?
I wouldn't expect a ton based on our current read.
'Cause the buy-side consensus has you up 10%-15%, but it sounds like if you were answering this question, you would have put 1% flat to 5%.
That's where I would be based on our current view.
Interesting. I guess with that, so RWA is not necessarily, is quite manageable. But you are kind of facing a 300 or so basis point headwind from-
Mm-hmm.
AOCI opt-out. You know, you talked about being above 9.5%, CET1, but, you know, you're probably, ex-OCI, probably a touch below 7%. Totally appreciate we're talking today versus something that's not going to be happening way into the future. But just, you know, how do you kind of think about that?
Well, I mean, obviously, one of the things that came out in the NPR is the time is our friend, right? And that's really, really important. As we think about capital and what we need to do, there's nothing that we need to do that is inorganic in order to hit all the capital measures that we need to hit. And so, we actually feel good about where we stand with respect to the capital build between now and either July of 2025 or July of 2028, however you look at it.
I guess one, on the topic of regulation, there's also this long-term debt proposal came out a week or two ago, for $100 billion-plus asset banks. Maybe just help us talk, what that impact could be.
Clark, why don't you cover that?
Yeah. So I mean, we've we're still sorting through some of it, which is at times overly complicated. But, you know, I think generally speaking, we're kind of looking in the less than $5 billion range of additional debt. And again, sort of fine-tuning those numbers, but, it's not... You know, we saw some things that were as low as $1 billion, some as high as $10 billion, just given what was grandfathered and what wasn't, that we think we're in that range, but towards the lower end of that range.
Got it. Maybe we'll put up the next ARS question. What do you think normalized ROTCE range is for Key? And I guess, you know, I noticed you, you put up your outlook slide, in the deck this—your deck this morning, kind of reaffirming Q3, Q4 guidance, full year guidance. It also kind of had your new long-term targets kind of unchanged with that 16%-19%, you know, ROTCE. As you kind of think about, you know, the new environment with implicitly higher capital, you know, RWA weighting, you know, does that alter your view in terms of kind of what the long-term ROE potential is?
So the guidance that we gave, we have not updated our long-term guidance. So to your question, there's been a lot written on what everyone thinks everyone's ROTCE is going to be. I've seen a lot of numbers that range from down 200 basis points to down 400 basis points. I'd make a couple comments, if I could, on that. One, as I go through most of the analysis, most of the analysis assumes that management teams aren't going to pull any levers and do anything differently than they have. And as you can tell by the comments that I made and the discussion that we've had so far, we and others will take a bunch of actions that are required.
And the other thing that is missing, I think, in a lot of the analysis, the biggest driver of ROTCE, at least in terms of degradation of same, is credit losses. So I don't think you can think about kind of ROTCE without really thinking about what are the credit losses going to be on an actual and on a relative basis. All that put all that together, do I think it's going to be no change? I do not. I think by definition, if you carry more capital and it's more expensive, it's going to impact it. Do I think it's going to impact our targeted ROTCE, which is currently 16%-19% by 400 basis points? I do not. We'll see where it shakes out.
I see, let's—we say here that so for it, for its 16-19, it looks like most folks are sort of in the, it looks like they're mostly 13-14. I think it will be—and we're running a bunch of models, it will be higher than that, I believe.
Higher than the 14?
Yeah.
But not the 16.
That's right.
Fair enough. So we'll go with mid-teens.
I think that's a reasonable assumption.
And then-
We're still running all the models.
You mentioned the risk. It sounds like, you know, you kind of talked about that 40-60 normalized loss rate. I guess, kind of given the current balance sheet, maybe that number is too high as well.
We're going to, when we come out with guidance, as we always do in January for next year, we're going to restate our long-term goals, as well, just under the Basel III Endgame. And my guess is that will be to your instinct. That'll be something under review, but we still think 40-60 is a good number. My guess is it'll be below that.
Fair enough. Why don't we look to the audience for questions? I guess, Key, you made the comment that, you know, given your CRE servicing platform, you have unique insights-
Mm-hmm.
-into what's going on in that segment, but you didn't share those insights.... So I mean, we keep on reading the Wall Street Journal, how it's like the end of the world. But, you know, maybe you could kind of talk to-- I know it's not on Key's balance sheet, and, and probably a revenue opportunity, but just maybe talk to in terms of what you're seeing.
Yeah. So it is a revenue opportunity because the $630 billion that we're the servicer of, over $200 billion of it, we're the named special servicer, and it goes into active. So picture, we're basically the workout agent, so that's how we have this unique insight. There's no question that it's that it's office, and it's office in central business districts, and it's B and C class. It was, as you look back, at first it was lodging, as you can imagine, coming out of the pandemic. Before lodging, it was retail. No surprise there, just given sort of the macro trends. And I actually think office is going to get a lot more challenging. I can speak for us. We said we were going to take out 25% of our non-branch, non-ops real estate.
We had too much real estate before the pandemic. I travel around, and many of you travel around to your other offices. There's a lot of empty offices when you travel around. We took out 25%. We're probably closer to 30% or 33%, and we're going to take out more. I just think there's-- I think we're over-officed, and I think it's going to be, I think it's going to be a challenge that goes on for some time. The good news is, is that obviously these are multi-tenant buildings, and so the leases are staggered. But we-- as I said, we only have $121 million of exposure, and just to, to remind some of the listeners, we have, about $120 billion in loans, so it's not a big number for us.
Right. No, understood. Understood. Questions from the audience? I see one kind of stage left. Right, right, right there.
Can you talk a little bit about your long-term debt requirement and the friction sort of between the bank and the Op Co and what- or sorry, the bank and the, and the Hold Co, and what you need to carry for that friction relative to just the stated requirement?
Yeah, sort of a to be determined as we're sorting through the rule, but, I don't think, you know, if you were on either extreme, you'd... The one bad extreme would be issue with the Hold Co, push it down, issue again. I don't think that's the answer. I don't think it's as simple as issue once and push it all down, right? So the balance is really how much do you still need to hold at the, at the Hold Co. I think the other question we'll really have to understand, and it's too early to tell, is how regulators think about the ability to go up and down. So historically, you know, as long as you were in good standing, you could move dollars up and down relatively easily.
But, with different regulators, with different requirements, I'm not sure how much friction that's going to create, and that time will tell. But that's a place where, you may end up carrying more than you need because you can't move it as flexibly as we have in the past.
Maybe we'll go to the next ARS question as the audience thinks of others. But which would have the most impact on improving Key's valuation? Why don't you go ahead and ask while people tabulate?
Going back to your comments on office CRE, what are you seeing in terms of value declines and loss rates so far? And what's your expectation based on the special view that you have of the sector?
Well, the interesting thing is there's been such a precipitous decline. There's really nothing trading right now. So I can't really tell you what the adjustment's been. I mean, if you go to people, we use a bunch of outside sources. People would say that the degradation over from peak to present is a number that starts with a three. I think it might be greater than that. I don't really know because it's not something that we're really dealing with. We don't have troubled loans in that area, but I think it's going to be... I think it's going to be really, really significant. The other thing is everyone quickly goes to the fact that we don't have enough front doors in the United States, which we don't.
Everyone says, "Well, people will just convert offices to multifamily." It's not that easy. If you think about how, you know, if you think about just how they're plumbed, if for no other reason, it's just not that easy to do. So, more to come on that, but I think there's the adjustment period has just begun.
If you take it from the tenant standpoint, as Chris said, we're out of a lot of space. You know, it's do you just write off the lease and make the payment, and now the landlord has to decide what they do with the space? Do you sublet it? There's a whole series of that, and in multi-tenant buildings, they're all on different time frames. So I'm not sure we'll see the exact implication of this until we kind of start to move through leases turning over.
By the way, I agree with the concept that better NIM and NII performance would be the biggest driver. And the good news for us is it's just a matter of—it's just time-bound. Most times in business, there's all kinds of execution risks and all kinds of variables. This is pretty clear.
Maybe why don't we go to the next ARS question, kind of tease it up. But, expectations for Key's NIM next year, it was 2.12 in the Q2 . Clark, this is where I really would appreciate your answer.
You'll get our answer later, Jason.
Can't wait till January. Let's see what the audience comes up with. So that's interesting. So not much improvement from current levels would be the kind of buy-side consensus.
You want me to respond?
Yeah. Oh, I didn't- that didn't sound like a question.
We're obviously not going to give guidance today, but what Clark has said is that on a normalized basis, our NIM should start with a 3. And so that is after these things burn off. We've also said that our NIM bottoms out in this year. So those are kind of 2 data points that we have out there that I think would be potentially... Well, I'll just leave it at that.
Fair enough.
I would just say we, the other thing we've done this year, Jason, whether it's RWAs, whether it's driving down wholesale borrowings, there's a bunch of movement we made building capital through the year. I just think we have more flexibility today than we had six months ago to pursue different paths as the market changes. And I think that flexibility will only increase as the Treasuries and swaps mature.
Any last final questions? If not, please join me in thanking Chris and Clark today.
Thank you, Jason. Thank you.