A banking industry perspective on key CECL decisions
Mike A Shearer
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
Accounting Standards Update No. 2016–13, Financial Instruments — Credit Losses (Topic 326), referred to herein as current expected credit losses (CECL), or the “Standard”, while prescriptive in some regards is generally considered a principle-based standard. As such, there are a number of decisions and elections that must be made. The objective of this chapter is not to outline every decision, but rather to focus on the more impactful decisions, and then provide an industry perspective on both factors and to consider a range of observed industry practices from its initial adoption in 2020. Specifically, this chapter will focus on:
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the reasonable and supportable (R&S) forecast period;
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reversion considerations;
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use of a single or multiple scenarios;
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discounted cashflow (DCF) or non-DCF based approaches;
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paydown curves on unconditionally cancellable instruments;
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off-balance sheet exposure; and
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reasonable expectation of a troubled debt restructure (TDR).
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REASONABLE AND SUPPORTABLE FORECAST
One of the most impactful decisions on the estimate of the
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