Banking

As banks navigate through their CECL implementation, many are experiencing challenges and uncertainties along the way. Since last summer when the new standard was announced, we’ve advised banks to get started on their implementation timeline sooner than later. In part, it’s to give time to mitigate the unexpected. In part, the advice comes from our experience with how complex and challenging it can be to implement new models, standards, regulations, and technologies. And finally, it’s because more robust data analysis means more confident decisions and ultimately more profitable loans over the long term.

While the on-paper goal for banks working toward their implementation deadline for the new Current Expected Credit Loss (CECL) impairment standard is compliance, the long game opportunity is much greater. Every decision in the process hinges on data.

As 2017 gets underway, and we understand more about what’s on the horizon for the new administration’s regulatory and tax reform, there’s a sense that the coming years will bring unprecedented changes for financial institutions. In this last post in our series about CECL adoption, we will revisit the timeline and steps. More than ever, it is critical that you are preparing now for ensuring a successful adoption in the midst of an ever-changing landscape.

The previous post about preparing for CECL compliance looked at how to assess data, human, credit management, and technology resource capabilities and needs. It’s a critical step that documents how your institution collects, stores, measures, and manages loan portfolio data, and includes a review of future requirements, warehousing and automation capabilities, and probable risks in your loan portfolio.

In the previous post about preparing for your CECL compliance deadline, we established that there is no one-size-fits-all solution under the new standard. We provided some of the key considerations for determining how sophisticated your model should be, as well as unique benefits and weaknesses of the options available to manage the loan pools in your portfolio.

Once you have evaluated the various model options and identified which you’ll use to perform calculations, it’s time to assess your resource capabilities and needs. This is a big consideration with cross-functional implications. It will help to identify the software models and provider that will be the best fit for your institution. In this step, you'll look at four main categories—data, human, credit data management, and technology. Data should be your starting point, as it will influence every subsequent decision at this juncture.

In the previous post about preparing for your CECL compliance deadline, we looked at the steps needed to analyze the credit risks within your loan portfolio, and clarify the credit quality indicators (CQIs) impacting those risks. These first two steps of this complex, lengthy lead up to your early or required implementation date should have provided you with a solid understanding of the composition of your loan portfolio.

The countdown that began June 16, 2016 is officially underway. The runway to CECL (Current Expected Credit Losses) compliance promises to be riddled with complexities. You don’t need to look much farther than the fact that FASB implementation dates are set several years out to get the sense of how important it is to take a long-term, multi-faceted approach to ensuring compliance.

The allowance for loan losses (ALLL) standard (ASU 2016-13) known as CECL (Current Expected Credit Losses) was released June 16, 2016. The standard was proposed in 2012 and has been deemed the “biggest change to bank accounting ever.” It’s adoption changes 40 years of standards related to how banks account for changes in their credit risk. It promises to pose significant compliance and operational challenges, and implementation is well underway for some institutions.

The Financial Accounting Standards Board (FASB) today (June 16, 2016) issued its long-awaited Accounting Standards Update (ASU) regarding its new loan loss accounting framework. The Current Expected Credit Loss model (CECL) was first proposed in 2012. With its adoption, 40 years of standards related to how banks manage their business change, posing significant compliance and operational challenges for banks.

On April 27, 2016, the Financial Accounting Standards Board (FASB) met to discuss the costs and benefits of its planned standard for writing down bad loans and securities. During that session, the board voted to proceed with a new accounting standard that provides timelier financial reporting of expected credit losses on loans (CECL) and other financial instruments held by financial institutions and other organizations. 

Last week, a group of community bankers from the Independent Community Bankers of America (ICBA) and representatives from the American Bankers Association (ABA) met with the Financial Accounting Standards Board (FASB) to discuss concerns about the upcoming impairment standard on credit losses. The meeting came partly as a result of two years of requests from the ABA to consider the implications of accounting changes on community banks.