CECL isn't just for banks: Are you ready?

Read this if you are a financial institution.

Whether you think of New Year’s resolutions or goal setting, it’s that time of year where we traditionally take time for reflection (current state, desired state) in order to take action on the change we want to see. Understandably, as many institutions have been so focused on developing and understanding their CECL model and results, evolving the internal control environment may have, well, lagged a little. Which is why, in the spirit of starting the new year on the right foot, now is the perfect time to think about internal CECL controls.

CECL internal controls: Where to start?

Let’s acknowledge this right away: there is no “best” place to start. Some folks like to review what controls they already have in place and then think about how best to evolve or tweak them. Others may prefer to take a clean slate approach—map out the CECL workflows, identify risks, and then determine what controls are needed. One way to bridge these approaches is after you’ve mapped out the process, risks, and controls, then compare that to what you already have and make the necessary adjustments. We’ve seen all of these approaches work, but there are some pros and cons and pitfalls to consider for each. 

Existing controls

If you choose to begin by reviewing and tweaking the controls you already have, one pitfall is that you may not challenge your thinking enough to recognize where new risks have been introduced with your CECL methodology. For example, how does the CECL calculation—and all the new data you are now relying on—impact controls? Is your area responsible for making choices about all those numbers, values, and codes, or are those calculations, choices, and decisions taking place in other areas where controls may need to be developed, or reviewed and enhanced for CECL?

Another good example: if you’ve invested in software, have you recognized the need for new controls over data flow in and out of that system, including the manual calculations you’re doing outside of the system and then keying those results into the system as model inputs? We have found that some people go into this approach thinking it will save them time—like a short-cut—only to realize later they’ve missed the opportunity to identify one or more key risks/controls.

Clean slate mapping

Speaking from experience, this approach can take some time but may be a great way to ensure your thinking is not limited by “what you’ve always” done or had in place. That said, we can appreciate that while staring at a blank page is energizing to some, it can feel overwhelming to others. Moreover, that overwhelmed feeling may be the underlying reason why it is tough to engage in this approach.

Here’s the big tip: put some sort of starting point on paper (maybe even the middle of the paper) understanding that as you think about it, you could be adding to the workflow before, above, under, or past that starting point. It’s okay that you don’t know all the related workflows because you’re identifying that there are related workflows whose risks/controls may be in other areas that need to be further explored. Maybe take this activity, initially, to a conference room with a big dry-erase board (there are online versions of this, too)! 

Now, just like those new year’s resolutions for increased exercise that sometimes are easier to stick to when you have an accountability partner—is there someone in your organization that is particularly adept at creating workflows whose strengths and talents you can tap into to help you create this one? 

Tips for helping ensure CECL internal control success

No matter which approach you end up taking, here are some of our top tips for helping ensure CECL internal control success:

Communicate: Outreach and awareness are foundational to engaging others in this process. It is so understandably easy for people not directly involved in the day-to-day CECL calculation to even realize they have a key role to play when it comes to CECL controls. 

Cooperate: Invite others into the process, especially when it comes to helping you evaluate how changes under CECL relate to work they do day-to-day. Work together to simply understand or clarify how the pieces fit together. 

Collaborate: There are lots of ways to design, test, and monitor internal controls. Lean into the strengths and talents of others to help create efficient and effective controls that can save you and others a lot of time and headache. I recommend this no matter how mature the control practice is—there may be ways to make it better and easier.

Coach, train, and support: I advise against the “control dump and run”—letting someone know they have one or two new controls, and then leaving them to it. Certainly, there is value in having to solve something from the ground up. However, helping others connect the dots between why controls are important, ways to evaluate and structure them, and who in the organization can collaborate with them to make them as easy and effective as possible, goes a long way toward getting the most value out of your control environment.

Seek advice: CECL is new for almost everyone, and controls are not a one-size fits all. Engaging someone experienced in both CECL and controls can help challenge your thinking, open your eyes to pitfalls, prevent over-engineering, provide perspective, and help you transition as you grow. 

No matter your CECL challenge or pain point, our team of experts is here to help you navigate the requirements as efficiently and effectively as possible. For more information, visit the CECL page on our website. If you would like specific answers to questions, please visit our Ask the Advisor page to submit your questions.

For more on CECL, stay tuned for our next article in the series, or enjoy our CECL Radio podcasts. You can also follow Susan Weber on LinkedIn.

Read this if you are at a financial institution. For more CECL information, tune in to the latest episode of BerryDunn’s CECL Radio podcast. It features Susan Weber and David Stone discussing how to handle unfunded commitments and debt securities during CECL preparation.

I love a big surprise! Of course, I mean the fun, uplifting kind—like birthday parties, a best friend’s unexpected visit, or that special anniversary gift. Not that other kind of surprise that’s more like biting into an apple only to find half a worm. Calculating a loss reserve for unfunded commitments is not a new concept, but the reach and significance of it may end up surprising institutions. How much? A review of 2020 public filings and disclosures shows that some adopters saw unfunded commitment reserves increase millions of dollars, from one percent of total reserves pre-adoption to six percent or more post-adoption. In this article, we take a close look at unfunded commitments under CECL, in an effort to help you avoid that “other kind” of surprise.  

Within the CECL standard (Accounting Standards Codification (ASC) 326 – Financial Instruments-Credit Losses), key considerations for estimating reserves tied to unfunded commitments are covered in section 326-20-30-11. The section lays out three key fundamentals: it applies to credit commitments that are not unconditionally cancellable, and that institutions should consider how likely the commitment is to be funded, and its expected life. 

First, let’s look at unconditionally cancellable—this essentially means that unless an institution can, at any time and for any reason, cancel its commitment to lend, then the commitment has to be included in this part of the estimate. Institutions may be surprised to discover that a portion of its commercial sales pipeline should now be included in unfunded commitment balances. Why? Because commitment letters issued to business loan applicants are often considered legally binding and they typically do not contain language that would make them unconditionally cancellable by the institution. This makes sense when you realize the primary goal of the commitment letter is to assure the applicant that the bank is committed to making the loan. This discovery, in turn, has led those involved in CECL implementation to develop (1) processes to ensure commercial loan pipelines are sufficiently detailed enough to know what, when, and how these commitments should be included in the calculation, and (2) internal controls that assure the accuracy, completeness, and timeliness of the information. 

Next up—how likely is it that the commitment will be funded? For unused portions of existing loans and lines, this may mean taking a look at average utilization rates. For in-scope pipeline commitments, institutions may find that they need to dig through information that is not commonly held in a central system to come up with a success or close rate. The likelihood of funding may vary widely between products or segments, and over its expected life. For example, the expected funding of a residential or commercial real estate construction line may approach 100%, whereas only 40% or less of a revolving line may ever be used. These funding rates become the basis for “discounting” the unfunded balances subject to reserve estimation and should be re-evaluated on some periodic basis, which can be detailed in the institution’s CECL model documentation related to governance and monitoring.

Finally, let’s look at the expected life of the loan component. This language and expectation are consistent with on-balance sheet credit, leading institutions to (1) make sure they are able to segment their off-balance sheet commitments in the same pools used for boarded loans, and (2) apply the appropriate pool reserve factor to unfunded commitments over the expected life of that type of loan. One-way institutions may accomplish this is by making sure that they are using the same fully adjusted reserve factor and expected life assumptions for unfunded pools as they do for their funded pool counterparts. 

You may discover that your CECL model or software vendor does not provide for unfunded commitment calculations, or only provides support for the available credit portion of loan facilities boarded to your core loan system. In either case, this means institutions must consider, support, and complete calculations outside of the model. Writing clear step-by-step instructions and ensuring a robust independent review/approval process will help off-set risks posed by such manual calculations.

Could you use an experienced resource to help you document or validate your CECL model?  

No matter what stage of CECL readiness you are in, we can help you navigate the requirements as efficiently and effectively as possible. For more information, visit the CECL page on our website. If you would like specific answers to questions about your CECL implementation, please visit our Ask the Advisor page to submit your questions.

For more tips on documenting your CECL adoption, stay tuned for our next article in the series. You can also follow Susan Weber on LinkedIn.

Read this if you are a financial institution.

One of the new components to CECL is the consideration of how future economic conditions may impact your estimate of expected losses. What forecasts do you need, how to find and evaluate forecasts, and what are the things you need to think about regarding the forecast choices you make are all excellent questions. Below are 10 things that may help you make, evaluate, and support your “reasonable and supportable” forecast decision:   

1. Source(s): Even though many understand that economic forecasts, like their weather counterparts, are often wrong, reputation and experience of the forecaster(s) matter. Beyond name recognition, learning more about the people and process of how the forecast is derived will go a long way to helping you defend the source you’ve chosen.  
2. Types: Forecasts may be produced by an individual, model(s), or group. You may have heard the term “consensus” to describe a forecast—literally, a forecast that results from the majority or average opinion of a group of contributors. An awareness of the type of forecast will help you identify the unique risks of each.    
3. Assumptions: With any forecast, it is important to understand the specific assumptions on which the forecast is based. “This forecast assumes…,” or “The accuracy of this forecast is contingent upon….,” or “In developing this forecast we relied on….” are just a few examples of what to look for when reviewing introductions, footnotes, or disclaimers to the forecast(s).  
4. Cost: Fee-based economic forecasts are not inherently more “reasonable and supportable” than free ones; remember, no forecast is perfect. Some fee-based providers may offer a version of their forecast for free. In these cases, having a clear understanding of what’s included in each version may be a deciding factor.
5. Completeness: The more economic forecasts you read, the more you realize that what they are actually forecasting varies. Evaluating whether or not a forecast is complete is really about discovering if it forecasts all the economic conditions—or economic factors¹—that you want to use in your model. For example, you may have mathematically shown that a local or regional unemployment rate is more informative about loss risk in your portfolio, but is there a forecast source for that local or regional rate?
6. Frequency: Knowing how often a forecast is updated, and when it will be made available is crucial to the timing of your CECL reserve calculation, and the answers may affect more than just your decision of which forecast to use (see “Trade-offs”). For now, consider how reliably and consistently the forecast is available, and if you can count on it with enough time each quarter-end to use it in your reserve calculation.
7. Future: With all the uncertainty of the past couple of years, it may seem optimistic to think about sources providing more than a one-year forecast. Yet, for some, this may be an important option. For this reason, finding out if a source does, can, or charges extra for providing one-, two-, and three-year (or longer) forecasts may be necessary.  
8. Bias: It is important to be aware that forecasts can be biased, meaning that they always tend to be more or less enthusiastic about the future. Bias is not the same thing as providing alternative outlooks or scenarios—such as best case/worst case, or neutral/severe, which are more about the assumptions being made. Bias is often detected when over a period of time you compare sources against each other and discover that one source tends to forecast consistently higher or lower than others. This may be especially important when you consider how a forecast does or does not align with the views of the institution’s management.  
9. Accuracy: Again, since all forecasts will be wrong to some degree, let’s set a new standard for thinking about accuracy. Perhaps the goal here is to find the less-wrong forecast. One way you might want to do this is to locate (or ask for) previous forecasts over different periods of time and compare them to what actually happened. This one is tricky because of assumptions and bias, but if you’ve narrowed it down to a few choices, you may find this kind of exercise helps you decide.
10. Trade-offs: Given all the forecasting options and considerations, it may be re-assuring to hear that there is no one right answer. But in order to properly support your choices, it is important to think through and document what trade-offs have been made along the way, how they may affect your reserve calculation, and whether or not you feel it should be addressed elsewhere in your methodology.

In closing, two words of caution. First, while having a good single source for a forecast may sound like a great idea, have a back-up plan. Some forecast sources did not produce an update in March-April 2020, the time when first-wave adopters were trying to produce their first quarter CECL estimates, sending some folks scrambling. With this in mind, making use of several forecasts may help you mitigate single-source risk in the long-run. Second, having a process in place to ensure the same economic outlook is being used in all major functions is important. For example, relying on a “severe” future outlook to build loss reserves while at the same time using a “neutral” economic outlook for budgeting and ALM purposes could call into question the reasonableness of your CECL estimate. 

No matter what stage of CECL readiness you are in, we can help you navigate the requirements as efficiently and effectively as possible. For more information, visit the CECL consulting page on our website. If you would like specific answers to questions about your CECL implementation, please visit our Ask the Advisor page to submit your questions.

For more tips on managing your CECL adoption, stay tuned for our next article in the series. You can also follow Susan Weber on LinkedIn.

¹In this context, “economic factors” are measured conditions – such as unemployment, gross national product, consumer price index, etc. 

Read this if you are a financial institution.

Have you ever noticed how a countdown seems to want to pick up speed the closer you get to the finish? 10, 9, 8… The chanting gets louder, and excitement builds with each passing number: 7, 6, 5… For me, the adrenaline really kicks in below 5: at 4, 3, 2.

Whether it’s excitement or anxiousness you’re feeling as CECL adoption approaches, staying focused on the remaining decisions is vital to your success. One of those decisions—and a frequently asked question in recent discussions with 2023 adopters—is about implementing Q factors (qualitative adjustments). So let’s take a look at some key considerations for Q factors.

10, 9, 8…

The role and nature of Q factors are to adjust for certain things you know or think will be different about losses in the future than they were in the past. They are also intended to be transitory. Like a scientific hypothesis, each Q factor adjustment exists until it bears out and is picked up in your primary model output, or it doesn’t. Either way, the need for that particular adjustment would presumably end. The one adjustment that most often comes to mind is economic forecasts, a new component of CECL. Let’s assume you have a qualitative adjustment for an expected upcoming recession—depending on your chosen method, for instance, the difference in reserve calculated when using a more severe economic scenario, or using historical losses only from a time period that was recessionary. Regardless, one would not expect this to be a permanently held adjustment—at some point, the recession happens, or it does not, and the adjustment may no longer be warranted. Categories of Q factors give us a place to start thinking through what specifically is different or what is changing, whether it is something broad, like economic forecasts, or something specific like new products or geographies in which you lend money. The key here is that it is something not accounted for already in the design, structure, inputs, or output of your core model.¹  

7, 6, 5…

Effectively implementing Q factors requires you understand how your segmentation (pools for collective analysis) and method selection affect your opportunity to make and support adjustments. What does this mean? 

Segmentation under CECL requires grouping loans based on similar risk characteristics. This is inherently about behavior that has to do with risk and loss. Grouping all first lien residential mortgage loans together is a common one. If you have a big enough portfolio with enough historical loss history to support it, you may be able to further sub-segment that pool by geography (region, state, county), or by nature of use (primary residence, vacation home, or investment property), or by collateral lien position (first lien, junior lien). You’d want to do this if the inherent risk of loss you face is different. This loss risk difference could be a matter of customer behavior, or a difference in market conditions.

But what if, through the model development stage, you realize (or are told) that you don’t have enough data or big enough pools to model effectively at your preferred level of segmentation? Or, what if the method you chose comes with a level of segmentation already built-in?

4, 3, 2…

Let’s stick with residential mortgages. If you’ve accepted a higher level of segmentation, for example at the product level (residential mortgages) or even higher at the call report code level (1c), you may be thinking you have lots of leeway to make qualitative adjustments for all the nuances underneath. Not so fast. Are there any other modelling choices you’ve made that may prevent you from doing that? What about the use external loan data?

A common modeling technique is to use peer data to help establish the mathematical relationship between historical losses and changes in the economy. Most peer data is only available at the call report code level, which means that all those nuances in your “1c segment” that you want to further adjust may already be embedded in your methodology because of the connection to peer data. This may be even further complicated by situations in which you have no say in more proprietary loan data sets model developers may be using to support their model design, assumptions, and formulas. External loan pool data is just one of many things to consider when evaluating when, and if there are opportunities to support a Q factor adjustment.

So what’s a responsible CECL adopter to do when considering how best to make qualitative adjustments? 

First, understand that the intention is to account for changes and differences, which inevitably is a moving target. Adjustments and their related reserve dollars are not fixed, which is why they should be subject to re-assessment each time you update your CECL calculation. Second, if you’re using a vendor’s model, it is imperative that you know how, when, and to what extent loan data other than yours is or has been used, both in developing the model and in its on-going operation. Third, you need to understand, document, and think through the interplay between the segmentation you have and model design or other assumptions made along the way. Finally, if in the normal course of operation, you change any of those assumptions or inputs, it should trigger a re-evaluation of your Q factors to ensure they remain relevant. 

Want help with your Q Factor approach? Are you struggling with CECL documentation or other elements of CECL? 

No matter what stage of CECL readiness you are in, we can help you navigate the requirements as efficiently and effectively as possible. For more information, visit the CECL consulting page on our website. If you would like specific answers to questions about your CECL implementation, please visit our Ask the Advisor page to submit your questions.

For more tips on documenting your CECL adoption, stay tuned for our next article in the series. You can also follow Susan Weber on LinkedIn.

¹If you haven’t already, I highly recommend that you read these sections of the accounting standards codification (ASC) 326, commonly referred to as the CECL standard: 326-20-55-4, 326-20-30-7, 326-20-30-8, and 326-20-30-9.

What the C-Suite should know about CECL and change management

Read this if you are at a financial institution. 

Some institutions are managing CECL implementation as a significant enterprise project, while others have assigned it to just one or two people. While these approaches may yield technical compliance, leadership may find they fail to realize any strategic benefits. In this article, Dan Vogt, Principal in BerryDunn’s Management and IT Consulting Practice, and Susan Weber, Senior Manager and CECL expert in BerryDunn’s Financial Services Practice, outline key actions leaders can take now to ensure CECL adoption success.  

Call it empathy, or just the need to take a break from the tactical and check in on the human experience, but on a recent call, I paused the typical readiness questions to ask, “How’s the mood around CECL adoption – what’s it been like getting others in the organization involved?” The three-word reply was simple, but powerful: “Kicking and screaming.”  

Earlier this year, by a vote of 5-2, the FASB (Financial Accounting Standards Board) closed the door to any further delays to CECL adoption, citing an overarching need to unify the industry under one standard. FASB’s decision also mercifully ended the on-again off-again cycle that has characterized CECL preparation efforts since early 2020. One might think the decision would have resulted in relief. But with so much change in the world over the past few years, is it any wonder institutions are instead feeling change-saturated?  

Organizational change

CECL has been heralded as the most significant change to bank accounting ever, replacing 40+ years of accounting and regulatory oversight practices. But the new standard does much more than that. Implementing CECL has an effect on everything from executive and board strategic discussions to interdepartmental workflows, systems, and controls. The introduction of new methods, data elements, and financial assets has helped usher in new software, processes, and responsibilities that directly affect the work of many people in the organization. CECL isn’t just accounting—it’s organizational change. 

Change management

Change management best practices often focus on leading from optimism—typically leadership and an executive sponsor talk about opportunities and the business reasons for change. Some examples of what this might sound like as it relates to CECL might include, by converting to lifetime loss expectations, the institution will be better prepared to weather economic downturns; or, by evolving data and modeling precision, an institution’s understanding and measure of credit risk is enhanced, resulting in more strategic growth, pricing, and risk management. 

But leading from optimism is sometimes hard to do because it isn’t always motivating—especially when the change is mandated rather than chosen.  

Perhaps a more judiciously used tactic is to focus on the risk, or potential penalty, of not changing. In the case of CECL, examples might include, your external auditor not being able to sign-off on your financials (or significant delays in doing so), regulatory criticism, inefficient/ineffective processes, control issues, tired and frustrated staff. These examples expose the institution to all kinds of key risks: compliance, operational, strategic, and reputational, among them.

CECL success and change management

With so much riding on CECL implementation and adoption going well, some organizations may be at heightened risk simply because the effort is being compartmentalized—isolated within a department, or assigned to only one or two people. How effectively leadership connects CECL implementation with tenets of change management, how quickly they understand, then together embrace, promote, and facilitate the related changes affecting people and their work, may prove to be the key factor in achieving success beyond compliance.  

One important step leaders can take is to perform an impact assessment to understand who in the organization is being affected by the transition to CECL, and how. An example of this is below. Identifying the departments and functions that will need to be changed or updated with CECL adoption might expose critical overlaps and reveal important new or enhanced collaborations. Adding in the number of people represented by each group gives leaders insight into the extent of the impact across the institution. By better understanding how these different groups are affected, leaders can work together to more effectively prioritize, identify and remove roadblocks, and support peoples’ efforts longer term.           

 
No matter where your institution is currently in its CECL implementation journey, it is not too late to course-correct. Leadership—unified in priority, message, and understanding—can achieve the type of success that produces efficient sustainable practices, and increases employee resilience and engagement.

For more information, visit the CECL page on our website. If you would like specific answers to questions about your CECL implementation, please visit our Ask the Advisor page to submit your questions. For more tips on documenting your CECL adoption, stay tuned for our next article in the series, revisit past articles, or tune in to our CECL Radio podcast. You can also follow Susan Weber on LinkedIn.

Read this if you are a financial institution.

Choosing a method for estimating lifetime expected losses is a commitment. A commitment that signals, in spite of any other option, you’re certain this method is the right one for you—your segment, portfolio, and institution. While you might be able to support a change in method later, it is much more likely you’ll be living with this decision a good long while. So, how exactly does one know which method is the right one? Let’s take a few minutes to answer some frequently asked questions about selecting methods for CECL.

How many CECL methods are there?

This depends on who you ask. Section 326-20-30-3 of the standard names five (5) categories: discounted cash flow, loss-rate, roll-rate, probability of default, and aging schedule. Some categories, like loss-rate, have several methods. Additionally, some methods seem to be referred to by different names, giving people the impression that there are exponentially more options out there than there really are. With this in mind, I tend to think of two (2) broad categories, and seven (7) unique methods:  

• Loss-rate methods
  • Snapshot (open pool, static pool, cumulative loss rate)
  • Remaining Life and Weighted Average Remaining Maturity (WARM)
  • Vintage
     
• Other methods
  • Scaled CECL Allowance for Losses Estimator (SCALE) (option for banks with assets <$1 billion)
  • Discounted Cash Flow (DCF)
  • Probability of default 
  • Migration (roll rate, aging schedule)  

What’s the difference?

The loss-rate methods use actual historical net charge-off information in different ways to derive a loss rate that can then be used to calculate expected losses over the remaining life of a pool. In general, they do this by holding the mix of a group of loans constant (e.g., by year of origination) and then tracking net losses tied to that grouping over time. The “other” methods employ a variety of mathematical techniques and/or credit quality information to estimate expected lifetime losses. For a quick overview of each method and corresponding resources, access our CECL methodologies guide here.

How do I know which to use?

This is the CECL equivalent of the proverbial million-dollar question. Technically, any institution could use any one, or all of these methods. But there are considerations that make some of them a more or less likely fit. For example, if your institution has >$1 billion in assets, SCALE is not even an option for you, and you can cross it off the list. If you are not in a position to afford software, or lack the internal expertise to build a similar model internally, then discounted cash flow and probability of default methods would likely be extremely burdensome in the normal course of business. For that reason, you may need to cross those off your list. If you lack large pools with consistently diverse performance over time, then migration methods will be difficult to support. If you have a relatively stable loan mix, consistent credit culture, and a lot of reliable historical loss data—especially through multiple economic cycles—the loss-rate methods may be a good fit, with or without software. If your portfolio has undergone a lot of changes—products, underwriting standards, merger and acquisition activity—and/or there are significant gaps in key data that cannot be restored, then you might want to re-consider software and one of the “other” methods. 

What are the pros and cons of the various methods?

One pro of the loss-rate and SCALE methods is they have been shown to be manageable without software. Examples of all of these methods have been illustrated using Excel spreadsheets. The use of Excel is also potentially a con, given that more spreadsheets and, maybe more people, are likely going to be involved in computing the Allowance for Credit Losses (ACL). As a result, version control as well as validation of spreadsheet macros, inputs, formulas, math, and risk of accidentally overwriting or deleting values should be addressed. One pro of the discounted cash flow method is that it is a bottom-up approach, meaning each loan’s discounted cash flow (DCF) is computed and then rolled up to the segment level. Because of this, DCF can more easily handle mixed pools, e.g., loans of all vintages, sizes, terms, payment and amortization schedules, etc. A potential con of DCF is that it really requires software, staff trained to use the software appropriately, and an understanding of the vast array of choices, levers, and decisions that come with it.     

Does my choice of method affect my qualitative adjustment options?

How’s this for commitment: maybe. In general, I think it’s safe to say that CECL requires additional thought be given to the nature and degree of adjustments. This is especially true when you look at the combination of potential segmentation changes, new elements of the calculation, and the variety of methods now available. Consider the example of a bank using a loss-rate method and facing a potential economic downturn. If that bank has sufficient history and a relatively stable portfolio mix, credit culture, and geography, then it might elect to use a different time period—say, historical loss-rates observed from the last recession—rather than those more recently computed. In this case, the loss-rate method would already be using a recessionary experience. 

How then, would the bank approach additional qualitative adjustments for changing economic outlooks to ensure it is not layering (or double counting) reserve? Going back to the original “maybe” response, perhaps the answer is less about inherent conflicts between methods and qualitative adjustments. Rather, it’s about understanding that given your chosen method, you may be faced with even more decisions about if, where, and how much adjusting you are doing.

CECL adoption is required. Struggling to adopt isn’t. We can help.

No matter what stage of CECL readiness you are in, we can help you navigate the requirements as efficiently and effectively as possible. For more information, visit the CECL page on our website. If you would like specific answers to questions about your CECL implementation, please visit our Ask the Advisor page to submit your questions.

For more tips on documenting your CECL adoption, stay tuned for our next article in the series. You can also follow Susan Weber on LinkedIn.

Read this if you are at a financial institution.

While documentation of your CECL implementation and ongoing practices is essential to a successful outcome, it can sometimes feel like a very tall order when you are building a new methodology from the ground up. It may help to think of your CECL documentation as your methodology blueprint. While others will want to see it, you really need it to ensure that what you are building is well-designed, structurally sound, appropriately supported, and will hold up to subsequent “renovations” (model changes or tweaks). To help you focus on what’s essential, consider these documentation tips:

Getting started

Like any good architect, you need to understand the expectations for your design—what auditors and regulators want to see in your documentation. Two resources that can really help are the AICPA Practice Aid: Allowance for credit losses-audit considerations¹, and the Interagency Supervisory Guidance on Model Risk Management². One way to actively use these guides is to take note of the various section/subject headers and the key points, ideas, and questions highlighted within each, and turn that into your documentation checklist. You’ll also want to think strategically about where to keep the working document, who needs access to it, and how to maintain version control. It is also a good idea to decide up-front how you will reference, catalog, and store the materials (e.g., data files, test results, analyses, committee minutes, presentations, approvals, etc.) that helped you make and capture final decisions. You can download our CECL Documentation checklist now.   

What to watch out for

What’s new under CECL are areas requiring documentation (e.g., broader scope of “financial assets,” prepayments, forecasts, reversion, etc.). But watch out for elements that seem familiar—they may now have a new twist (e.g., segmentation, external data, Q factors, etc.). It’s a good idea to challenge any documentation from the past that you feel could be re-purposed or “rolled into” your CECL documentation. Be prepared also to spend time explaining or customizing vendor-provided documents (e.g., model design and development, data analysis memos, software procedures, etc.). 

While this material can give you a running start, they will not on their own satisfy auditor and regulator expectations. Ultimately, your documentation will need to reflect your own understanding and conclusions: how you considered, challenged, and got comfortable with the vendor’s work; what validations and testing you did over that work, and how you’ve translated this into policies and procedures appropriate for your institution’s operations, workflows, governance, and controls. For more information on making the vendor decision, and for suggestions of vendor selection criteria, read our previous article “CECL Readiness: Vendor or no vendor?” 

Point of view

It is human nature, especially whenever entering new territory, to want to know how others are approaching the task at hand. Related to CECL, networking, joining peer discussion groups, researching what and how those who have already adopted CECL are disclosing, are all great ways to see possibilities, learn, and gain perspective. When it comes to CECL documentation, however, the most important point of view to communicate is that of your institution’s management. Consider the difference in these two documentation approaches: (a) we looked at what others are doing, this is what most of them seem to be doing, so we are too; or (b) this is what we did and why we feel this decision is the best for our portfolio/risk profile; as part of our decision-making process, we did this type of benchmarking and discovered this. Example b is stronger documentation: your point of view is the primary focus, making it clear you reached your own conclusions. 

Other elements for CECL documentation

Documenting your CECL implementation, methodology, and model details is critical, but not the only documentation expected as you transition to CECL. It has been said that CECL is a much more enterprise-wide methodology, meaning that some of the model decisions or inputs may require you use data and assumptions traditionally controlled in other departments and for other purposes. One common example of this is prepayments. Up to this point, prepayment data may have been something between management and a vendor and used for management discussion and planning, but not necessarily validated, tested, or controlled for in the same way as your loss model calculations. Under CECL, this changes specifically because it is now an input into the loss estimate that lands in your financial statements. As a result, prepayments would be subject to, for example, “accuracy and completeness” considerations, among others (for more information on these expectations, refer to our earlier articles on data and segmentation). Prepayments is just one example, but does illustrate how CECL adoption will likely trigger updates to policies, procedures, governance, and controls across multiple areas of the organization.    

One final note: There are some new financial statement disclosures required with CECL adoption. Beyond those, there may be other CECL-related information either you want to share, or your audit/tax firm recommends be disclosed. Consulting with your auditor at least a quarter prior to adoption will help make sure you aren’t scrambling last minute to draft new language or tables.  

Struggling with CECL documentation or other elements of CECL? 

No matter what stage of CECL readiness you are in, we can help you navigate the requirements as efficiently and effectively as possible. For more information, visit the CECL page on our website. If you would like specific answers to questions about your CECL implementation, please visit our Ask the Advisor page to submit your questions.

For more tips on documenting your CECL adoption, stay tuned for our next article in the series. You can also follow Susan Weber on LinkedIn.

¹You can find the AICPA Practice Aid here.
²The interagency guidance was released as OCC Bulletin 2011-12, FRB SR 11-7, and as FDIC FIL 22-2017