Outlining the most impactful assumptions and challenges under CECL: a banker’s view
Dylan Adams and Diane Menzo
Introduction
An overview of CECL: setting the context
Outlining the most impactful assumptions and challenges under CECL: an auditor’s view
Outlining the most impactful assumptions and challenges under CECL: a banker’s view
A banking industry perspective on key CECL decisions
Challenges and solutions for wholesale portfolios
Challenges and solutions for retail mortgage portfolios
Challenges and solutions for retail credit card portfolios
Challenges and solutions for student loans
Challenges and solutions for securities portfolios
The evolution of purchased loan accounting: from FAS 91 to the CECL transition
Challenges and solutions for qualitative allowance
Challenges and solutions: an auditor’s point of view
Early view of CECL integration into stress testing: practical approaches
Too many cooks in the kitchen: mastering the art of managing CECL volatility
Beyond CECL: rethinking bank transformation
Data collision: efficient lending under CECL
Cutting through the hype: how CECL is impacting investor views of procyclicality, credit analysis and M&A
Concentration risk: the CECL magnifying glass
Closing thoughts
During the implementation of CECL at our organisation, we often found ourselves thinking “The next time we implement CECL…”, followed by whatever obvious lesson we had just learned. Our hope with this chapter is to provide the reader with some of the lessons learned, and the overall best practices and pitfalls discovered throughout the process. The areas that we will highlight include resources, communication and education, data and assumptions, internal controls, documentation and explaining output. Even if CECL has been implemented in your organisation, these lessons may be useful to help further enhance processes and systems, and to serve as a guide for future implementations of the same or greater magnitude. CECL is a journey; the adoption date is simply a rest stop in that journey.
RESOURCES: EDUCATE EARLY AND BROADEN YOUR SCOPE
The CECL implementation project will have a significant impact on an institution’s resources. It is important to consider the difference between one-time project-related resources and permanent ongoing resource needs. CECL will likely require several new permanent resources in the department responsible for executing the process on a go-forward
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