Elements of Current Expected Credit Losses (CECL)

Jun 26 / Tod Ellis, Loan Review Associate
On April 27, 2023, bank regulatory agencies (FDIC, OCC, and FRB) issued joint guidance concerning accounting changes to the Allowance for Credit Losses (ACL). These changes, based on the Financial Accounting Standards Board (FASB) ASU 2016-13 Topic 326, require banks to comply with updated accounting standards to improve the accuracy of financial reporting and risk management.

Why CECL Matters for Community Banks

For community banks, the implementation of CECL is not just a regulatory requirement but a strategic imperative. The new standards demand a forward-looking approach to estimating credit losses, which can significantly impact financial stability and operational resilience. Understanding and preparing for these changes is crucial for several reasons:

  1. Enhanced Risk Management: CECL requires banks to anticipate potential losses more accurately, allowing for better risk management and preparation for economic downturns.
  2. Regulatory Compliance: Non-compliance with CECL can result in regulatory penalties and increased scrutiny, which can be detrimental to a bank's reputation and operational efficiency.
  3. Financial Stability: Accurate loss forecasting helps maintain sufficient capital reserves, ensuring financial stability and protecting against unexpected credit events.
  4. Investor Confidence: Transparent and reliable financial reporting boosts investor confidence, potentially leading to more investment and support for community banks.
  5. Competitive Edge: Proactively implementing CECL can give community banks a competitive edge by showcasing their commitment to robust financial practices and customer trust.

Key Requirements of FASB ASC Topic 326

FASB ASC Topic 326 mandates that expected losses be evaluated on a collective, or pool, basis when financial assets share similar risk characteristics. Segmentation of financial assets may be based on one or a combination of the following risk characteristics:

  • Internal or external credit scores or credit ratings
  • Risk ratings or classifications
  • Financial asset type
  • Collateral type
  • Size
  • Effective interest rate
  • Term
  • Geographical location
  • Industry of the borrower

ASB ASC Topic 326 does not mandate a specific loss estimation method for determining ACLs. Various methods can be used to estimate the expected collectability of financial assets, and these methods should generally be applied consistently over time.

However, the same loss estimation method does not need to be applied to all financial assets. Management can select a different method if it will result in a more accurate estimate of ACLs.

Loss Estimation Methods

Management may use several methods to estimate expected credit losses, including but not limited to:
  • Loss-rate method
  • Probability of default/loss given default (PD/LGD) method
  • Roll-rate method
  • Discounted cash flow method
  • Methods that use aging schedules

The chosen method(s) should be suitable for the financial assets being evaluated and consistent with the institution’s size and complexity.

How PCI Performance Management Can Help

PCI Performance Management specializes in helping community banks navigate the complexities of CECL compliance. Our services include:

  • Customized Methodology Selection: We assist in choosing the appropriate methodology that aligns with your bank's size, complexity, and risk profile.
  • Advanced Software Solutions: We recommend and help implement cutting-edge software to streamline the CECL process.
  • Compliance Testing: We rigorously test your current systems to ensure they meet all regulatory requirements.
  • Ongoing Support: We provide continuous support to help your bank adapt to evolving regulatory landscapes and maintain compliance.
Don't wait until it's too late. The time to act is now. Ensuring your community bank is CECL-compliant not only safeguards your financial stability but also positions you as a leader in responsible banking practices.

Contact PCI Performance Management today to schedule a consultation and take the first step towards robust CECL compliance.
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