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CECL readiness: Vendor or no vendor? 

02.10.22

Read this if you are at a financial institution.

For some financial institutions, it’s only 11 months to CECL adoption and they haven’t yet decided on whether or not to use vendor model software for their CECL calculation. If this sounds familiar, then take a few minutes to consider these five key factors to making this decision so you gain traction on your CECL readiness efforts:

  1. Criteria: Identify and list the specific criteria you and others will need to make the vendor/no vendor decision. Ask key decision-makers to weigh-in. Getting this consensus on the criteria up-front ensures you present enough of the right kind of information to make the final decision quickly.     
  2. Time: Create a timeline of what has to happen between now and the CECL adoption date for your organization to be ready and confident in your chosen method(s). Identify the staff and hours required to accomplish it. Clarifying both the time commitment and time constraints will help you assess if additional support or trade-offs are required. Get tips on creating or revising your CECL implementation timeline here. 
  3. Expertise: Define the level of expertise necessary to understand, develop, test, and document the new model(s). This work may involve model design, data flow, mathematical formulas, and the ability to document assumptions and limitations of each. If you’re not sure, ask others to help assess if the organization has the internal expertise necessary to do this work, understanding those resources may work in different departments. 
  4. Technology: Determine if you have access to, or enough of, the technology needed for CECL model development and testing. In this context, technology may include systems, programs, analytical software, processing speed, and secure access. Knowing what your current technology capabilities are helps you identify any limitations you may need to address in advance.     
  5. Risk: Understand the risks. Take time to think through the risks posed by using – and not using – vendor model software. For example, developing a model in-house may save you the cost of vendor software, but what risk does developing a model in-house pose to the organization in allocating the people resources to do so? Likewise, securing vendor software may reduce the strain on limited internal resources, but what risks to access, process, communication, and control are posed by having to manage the vendor? 

Questions about your CECL implementation?

No matter what stage of CECL readiness you are in, our Financial Institutions team is here to help you navigate the requirements as efficiently and effectively as possible. If you would like specific answers to questions about your CECL implementation, please visit our Ask the Advisor page to submit your questions. 

Topics: CECL

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If you are considering using a third-party vendor model software, you may find some of these considerations helpful to making your selection:

  • Demos—getting a live demonstration of the software will help you start to visualize how it will work in the context of your business structure and workflow. Ease of use, customization requirements, and learning what decisions or manual inputs you have to make along the way may narrow your choices.
  • References—it’s always good to ask for and obtain references from clients using the software; asking “what do you wish you’d known sooner,” “what do you wish you’d done differently,” and “describe your vendor experience after the sale” are three great ways to discover client satisfaction and learn from other experiences.
  • Timeframe—with so many organizations coming on line with CECL in 2023, it will be important to find out what the vendor’s capacity is for getting you up and running. Equally important is finding out what resources/support on your end you need to meet that timeline.
  • Software—involve your information security and technology department(s). Some systems may be installed and require you to host and maintain them; others may be cloud based (include this in your risk assessment above). Neither type is inherently good or bad, but they do come with different technology, security, and people resource risks and needs.
  • Due diligence—performing vendor due diligence will help you assess experience, stability, and overall transparency. Make sure the vendor can provide a current SOC-1 report with bridge letter(s) over the model itself.  

Keep in mind that even if you opt to use a vendor model solution for your CECL calculation, your organization and management remain responsible for the results and explanations. The rationale and process behind model decisions, choices, and elections, as well as the recognition of model limitations, data simplifications, etc., are likely topics your auditors and regulators will want to hear about from you.

Resource
Third-party model software: Considerations

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

 

Article
CECL documentation: Your methodology blueprint

Read this if you are at a financial institution.

This article is part of our series on CECL implementation. You can read previous articles in the CECL series here

Segments, sub-segments, pools, cohorts—by whatever name you call it, grouping loans (and other financial instruments) for CECL1 is kind of a big deal. Like choosing an inner circle of friends, creating effective loan pools can have a lot of influence over your CECL experience, from methodology decisions to your allowance estimates. As a CECL adopter, you are expected to evaluate, support, and document segmentation choices (no such requirement for your inner circle of friends!), even if you plan to use the same segmentation in place today. To do so successfully, consider these segmentation ABCD’s:

A: Accuracy and completeness of data

The accuracy and completeness of data used to determine the most appropriate segmentation under CECL covers a lot of ground – everything from what information you considered to be relevant and why, to where the data came from and how it was determined to be valid (aka accurate and complete). CECL requires loans sharing similar risk characteristics2 to be pooled together for “collective evaluation”; examples include loans with similar terms and structures, lien position on collateral (e.g. first, or junior lien), or collateral use (e.g. owner-occupied or investment real estate). As a result, “accuracy and completeness” applies not only to the data you rely on to pool loans, but also to what you determined the common risk characteristics to be, why those, what others you identified but ultimately didn’t use, and why. Read our earlier article, CECL Adoption: The five W's of data, for more information on data considerations.

B: Balance between granularity and significance

Striking a balance between how many segments you create and the significance of doing so can be a little like trying to achieve the “just right” goal of Goldilocks. For example, is pooling all your consumer loans together most aligned with your past loss experience, or does the type of collateral also influence your risk of loss? How far is too far (real estate, cars, boats, RV’s, tractors)? At what point does it become difficult to consistently demonstrate or predict meaningful differences in risk of loss for each? Several sections of the standard address this need to balance detail with what is useful3. In this way pools should be small enough that the risk characteristics they share are relevant to estimating inherent risk, but not so small as to be confusing, misleading, or not able to be modeled consistently over time. Being aware of how small a pool is in terms of the number of loans it consistently contains may be one consideration for whether or not the segmentation is too granular. 

C: Controls over the selection of risk characteristics

Your segmentation choices will likely have far-reaching effects on other key decisions in your CECL methodology. Model selection, qualitative adjustments, and even if/what/how external or peer data may apply are examples of what could be impacted by your segmentation selection.  As a result, and in addition to the above, your auditors and regulators will want to see evidence the risk characteristics driving your segmentation choices were robustly reviewed, challenged, tested, and documented. Further, they will want to see that you have a similar systematic approach in place, and ongoing, to identify when a loan no longer shares the defined risk characteristics of its segment, resulting in its removal from the pool to be assessed individually.4  

D: Documentation tips

Documentation is like exercise—you know you should do it, but sometimes you don’t make it a priority. CECL opens the door for all kinds of documentation expectations, so coming up with a way to do this as you work through implementation can save you a lot of headache later. For segmentation, setting up a simple spreadsheet with the ABC’s to the left and columns to the right to list data, testing, key considerations, decisions, approvers, and even links to supporting evidence (data files, governance memos, etc.) is but one example of how you might keep track of these items as you work. Be sure to include any assumptions you had to make along the way (e.g. how you handled missing information on old or purchased loans), or aggregations (larger-level pools than you might have preferred) you accepted and why.

Finally, while you may be checking out what segmentation others in the industry are using—which will vary as it does today—what you’ll want to document most is why the choices you made are right for your institution.

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

No matter what stage of CECL readiness you are in, our Financial Institutions team is here to help you navigate the requirements as efficiently and effectively as possible. If you would like specific answers to questions about your CECL implementation, please visit our Ask the Advisor page to submit your questions.

1Current Expected Credit Loss (CECL) methodology as provided for in the Financial Accounting Standards Board (FASB) Accounting Standards Update (ASU) Financial Instruments-Credit Losses Topic 326, commonly referred to as FASB ASU 326. A copy of the standard is available for download from the FASB website.
2Refer to FASB ASU 326-20-55-5
3Examples include FASB ASU 326-20-50-3, 326-20-55-10, and 326-20-55-11 (for financing receivables)
4Refer to FASB ASU 326-20-30-2

Article
CECL implementation: Segmentation ABCD's

Read this if you are at a financial institution.

Data. Statistics. Analysis. Modeling. Whatever happened to good old-fashioned experience? When it comes to CECL (current expected credit loss), it’s going to take a combination of both—data and experience—to help you design an effective methodology. While “experience” sounds like a fun day of reminiscing, getting the “data” side can feel like a never-ending journey in the fog. If, in your CECL readiness journey data has you feeling a little lost, let the five W’s of data be your guide.

What data: Knowing what data you need is like having a map for the journey ahead. Understanding how CECL is different—in scope, requirements, definitions, and techniques—is the first step. One approach is to make a list of the differences. To the right of the list (or insert a column to your spreadsheet), add what data you will need to fulfill this part of the standard. For example, a new requirement for CECL is making adjustments for prepayments (new on-going data need). Some methods may use a prepayment rate which is, itself, a calculation requiring data and assumptions. It’s okay if this initial list is incomplete as capturing what’s new and different is an important start, and one that you can build upon as you go.

Where data: Next, you need to know where to get the data you need (sometimes it’s about even knowing if the data exists). This is where having key people from departments across the organization on the team can be very helpful. Time to add a new column to that spreadsheet: identify the system, department, person, and/or vendor responsible for the data you need. Find out where and how the data is stored. For example, is the data in a core system as a data point already, or is it manually calculated and recorded in a monthly memo going back 15 years? Where the data is located may be a key factor in decisions you will make about allocating resources, changing processes, and ensuring good controls over data.    

When data: The next essential question is, 'when is the data going to be needed and used?' In this regard, data falls into two broad categories: periodic and always. Examples of periodic data include data used to make model selection(s), support segmentation, or data that help you choose among several available techniques. Periodic data may be in the form of analysis and testing. Always data is the kind needed on an on-going basis, most typically to directly support the allowance calculation. Examples of always data are prepayments (from our earlier example), and the codes in the core system that allow you to group loans into their proper segments. Knowing when data will be needed and used will help keep your implementation moving forward.  

Why data: Data is often imperfect; it can be historically incomplete, somewhat dated, messy to compile, and may even be biased. Recognizing this upfront and throughout the process will not only reduce your stress; it will also help you document why certain data may have needed to be adjusted, modified, transformed, or ignored. Being equally inquisitive about why the data is in the shape it’s in may lead you to discover important ways to improve its quality, integrity, and the efficiency and effectiveness of collection and validation processes. Ensuring management has a good understanding of why assumptions or adjustments to data had to be made will help them fulfill their oversight responsibilities, pose credible challenge questions, and build context for understanding results.    

Whose data: Finally, whose data are you using? There are options for considering and using external data in your CECL methodology. When thinking through what this ultimately means to you in this process, it’s helpful to define external data as data provided by outside parties. In our journey analogy, think of these as alternate routes and, like alternate routes, there may be trade-offs to taking them that you’ll need to assess. Probably two of the most recognizable external data examples are economic forecasts and peer data. They may also include any data of yours that a vendor may have transformed and returned to you—a common example of this being prepayments. It is important to understand that from an auditor and regulator perspective, you remain responsible for the integrity and use of this data in your methodology. 

Once you have the five W’s of data locked in, you are well on your way to CECL implementation. No matter what stage of CECL readiness you are in, our Financial Institutions team is here to help you navigate the requirements as efficiently and effectively as possible. If you would like specific answers to questions about your CECL implementation, please visit our Ask the Advisor page to submit your questions.

Article
CECL adoption: The five W's of data

Read this if you are at a financial institution.

Feeling stuck, or maybe even frozen, in your CECL readiness efforts? No matter where you are in the process, here are three things you can do right now to ensure your CECL implementation is on track:

  1. Create or re-visit your 2022 timeline
    With just under 12 months to the January 2023 CECL adoption date, it’s important to make every moment count. Consider CECL adoption your Olympic moment and, like every great Olympic athlete, you have interim events—a timeline of major milestones—to ensure you are ready for “Day 1” and beyond. One strategy to ensure you do not “run out of time” is to start at the end of your timeline and work backward.

    Tip: Whether it be 1/1/2023 (“Day 1” adoption), or the first date by which you want to start parallel runs, fix the date of that final must-hit milestone, and work backward. For example, in order to adopt CECL on 1/1/2023, what major milestone has to be achieved before then and how much time will you need for that? Setting milestones from the final date backward will help you fit the remaining major activities into the time you have left—you can’t “run out of time” this way!



     
  2. Assess where you are, tactically, and fill in the gaps
    What would an Olympic athlete be without a training schedule, and coaches, trainers, and other professionals to guide and push them? In order to make the most of each event (or milestone) in the countdown to CECL adoption, let’s fill in our training schedule. What key decisions still need to be made or documented? Who has the authority to approve them? What’s the right time and venue to obtain that approval? Will these be one-to-one, small group, or committee/board meetings? Will meetings be set up as-needed, or is the meeting schedule (e.g. quarterly executive/board) already set? Who are you engaging for model validation and key control review? What is the date of that review work? 

    Tip: Add those key approval, review, and validation dates to your timeline, and make sure the meeting time you need with decision-makers is booked in their calendars now. Scheduling this time in advance is a transparent and tangible sign that you’ve charted the course, helps ensure decision-makers are available to you when needed most, and incremental progress is being consistently made toward your ultimate goal. 
  3. Identify the top three tasks to complete this week, reserve the time in your calendar, and complete them!
    Like any athlete, you are now “in training”, and daily and weekly actions you take will ensure you reach your goal in as strong a position possible. Whether it’s scheduling those meetings, identifying subject matter experts you can rely upon for coaching, or putting the finishing touches on model documentation and internal control mapping, booking that time with yourself to complete these tasks is key to feeling prepared and ready for CECL adoption. 

    Tip: Set aside a few minutes at the end or start of each week to review your timeline/milestones and identify the next key actions to complete.

Would you like assistance with certain aspects of your CECL readiness efforts? Are you ready for some validation/review work, or need guidance on policy, governance, or internal/financial reporting controls?

Contact our Financial Institutions team. We'll help you get your CECL implementation over the finish line. 


 

Article
CECL implementation: Three steps for a medal-winning adoption 

Read this if you are a financial institution.

As you know by now, ASU No. 2016-13, Financial Instruments – Credit Losses (Topic 326), better known as the CECL standard, has already been implemented for some and will soon be implemented for all others (fiscal years beginning after December 15, 2022 to be exact). During your implementation process, the focus has likely been on your loan portfolio, and rightfully so, as CECL overhauls 40+ years of loan loss reserve practices. But, recall that the CECL standard applies to all financial instruments carried at amortized cost. So, it therefore includes held-to-maturity (HTM) debt securities. And, although not carried at amortized cost, the CECL standard also makes targeted enhancements to available-for-sale (AFS) debt securities. As if re-hauling your entire allowance methodology wasn’t enough! Before tearing out your hair because of another CECL-related change, let’s quickly review what is currently required for securities, and then focus on how this will change when you implement CECL.

Current US GAAP

Under current US generally accepted accounting principles (GAAP), direct write-downs on HTM and AFS debt securities are recorded when (1) a security’s fair value has declined below its amortized cost basis and (2) the impairment is deemed other-than-temporary. This assessment must be completed on an individual debt security basis. Providing a general allowance for unidentified impairment in a portfolio of securities is not appropriate. The previous amortized cost basis less the other-than-temporary impairment (OTTI) recognized in earnings becomes the new amortized cost basis and subsequent recoveries of OTTI may not be directly reversed into interest income. Rather, subsequent recoveries of credit losses must be accreted into interest income.

CECL: Held-to-maturity securities

Then comes along CECL  and changes everything. Once the CECL standard is implemented, expected losses on HTM debt securities will be recorded immediately through an allowance for credit loss (ACL) account, rather than as a direct write-down of the security’s cost basis. These securities should be evaluated for risk of loss over the life of the securities. Another key difference from current GAAP is that securities with similar risk characteristics will need to be assessed for credit losses collectively, or on a pool basis, not on an individual basis as currently prescribed. Also, contrary to current GAAP, since expected losses will be recorded through an ACL account, subsequent improvements in cash flow expectations will be immediately recognized through earnings via a reduction in the ACL account. CECL effectively eliminates the direct write-down method, with write-offs only occurring when the security, or a portion thereof, is deemed to be uncollectible. 

In practice, there may be some types of HTM debt securities that your institution believes have no risk of nonpayment and thus risk of loss is zero. An example may be a US Treasury debt security or possibly a debt security guaranteed by a government-sponsored enterprise, such as Ginnie Mae or Freddie Mac. In these instances, it is acceptable to conclude that no allowance on such securities is necessary. However, such determination should be documented and changes to the credit situation of these securities should be closely monitored.

Financial institutions that have already implemented CECL have appreciated its flexibility; however, just like anything else, there are challenges. One of the biggest questions that has risen is related to complexity, specifically from financial statement users in regards to the macroeconomic assumptions used in models. Another common challenge is comparability to competitors’ models and estimates. Each financial institution will likely have a different methodology when recording expected losses on HTM debt securities due to the judgment involved. These concerns are not unique to the ACL on HTM debt securities but are nonetheless concerns that will need to be addressed. A description of the methodology used to estimate the ACL, as well as a discussion of the factors that influenced management’s current estimate of expected losses must be disclosed in the financial statements. Therefore, management should ensure adequate information is provided to address financial statement users’ concerns.  

CECL: Available-for-sale securities

Upon CECL adoption, you are also expected to implement enhancements to existing practices related to AFS debt securities. Recall that AFS debt securities are recorded at fair value through accumulated other comprehensive income (AOCI). This will not change after adoption of the CECL standard. However, the concept of OTTI will no longer exist. Rather, if an AFS debt security’s fair value is lower than its amortized cost basis, any credit related loss will be recorded through an ACL account, rather than as a direct write-down to the security. This ACL account will be limited to the amount by which fair value is below the amortized cost basis of the security. Credit losses will be determined by comparing the present value of cash flows expected to be collected from the security with its amortized cost basis. Non-credit related changes in fair value will continue to be recorded through an investment contra account and other comprehensive income. So, on the balance sheet, AFS debt securities could have an ACL account and an unrealized gain/loss contra account. The financial institution will be responsible for determining if the decline in the value below amortized cost is the result of credit factors or other macroeconomic factors. In practice, the following flowchart may be helpful:

Although changes to debt securities may not be top of mind when working through CECL implementation, ensuring you reserve time to understand and assess the impact of these changes is important. Depending on the significance and composition of your institution’s debt security portfolio, these changes may have a significant impact on your financial institution’s financial statements from CECL adoption forward. 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.

Article
Don't forget about me! Changes in debt security accounting resulting from CECL 

Read this if you are a Chief Financial Officer at a financial institution.

The Financial Accounting Standards Board (FASB) issued its second Accounting Standards Update (ASU) of 2022 on March 31, 2022. Seen as a fairly quiet year thus far on the accounting standards issuance front, both ASUs issued so far should catch the attention of financial institutions’ accounting and finance teams. For readers who may have missed it, on March 31, 2022, we wrote about the FASB’s first ASU of 2022: ASU No. 2022-01, Derivatives and Hedging (Topic 815): Fair Value Hedging – Portfolio Layer Method. Seen as enhancing the flexibility of hedge accounting, this ASU, among other things, expands on the “last-of-layer” hedging method by allowing multiple hedged layers to be designated for a single closed portfolio of financial assets or one or more beneficial interests secured by a portfolio of financial instruments.

The most recently issued ASU, ASU No. 2022-02, Financial Instruments – Credit Losses (Topic 326): Troubled Debt Restructurings and Vintage Disclosures, responds to feedback received during the FASB’s Post-Implementation Review process of ASU No. 2016-13, Financial Instruments – Credit Losses (Topic 326): Measurement of Credit Losses on Financial Instruments. Commonly known as the “CECL (current expected credit loss) standard,” financial institutions that have not yet adopted ASU No. 2016-13 should be well into their CECL implementation plan. ASU No 2016-13 is effective for fiscal years beginning after December 15, 2022, including interim periods within those fiscal years. 

The CECL standard is seen as a major disruptor event for financial institutions. I encourage you to check out my colleague Susan Weber’s CECL implementation series (the latest article can be found here) for best practices on a successful CECL implementation.

As soon as you see the acronym “CECL” in an article, especially one in regards to a new accounting standard, you may be already looking to “X” out of your web browser and save whatever horrors this ASU brings for another day. But, the changes that are forthcoming as a result of ASU No. 2022-02 are generally seen as being well received by accounting and finance teams (and likely credit teams as well). 

As its name implies, ASU No. 2022-02 addresses two separate issues: Troubled debt restructurings and vintage disclosures.

Troubled debt restructurings

The ASU eliminates the current troubled debt restructuring accounting guidance within Accounting Standards Codification (ASC) Subtopic 310-40 in its entirety. To help illustrate the impact of the proposed changes, let’s quickly review ASC Subtopic 310-40. ASC Subtopic 310-40, among other things, indicates a troubled debt restructuring should not be accounted for as a new loan because a troubled debt restructuring is part of a creditor’s ongoing effort to recover its investment in the original loan. A loan modification is considered a troubled debt restructuring if made to a borrower experiencing financial difficulty and if the modification grants a concession. Furthermore, all troubled debt restructurings are considered impaired loans. After adoption of the ASU, financial institutions will evaluate whether the modification represents a new loan or a continuation of an existing loan, in accordance with current ASC guidance (ASC 310-20-35-9 through 35-11). 

Current ASC guidance indicates a loan modification shall be treated as a new loan if the terms of the modification are at least as favorable to the lender as the terms for comparable loans to other customers with similar collection risks who are not refinancing or restructuring a loan with the lender. This condition would be met if the new loan’s effective yield is at least equal to the effective yield for such loans and modifications of the original debt instrument are more than minor. A modification is considered “more than minor” if the present value of the cash flows under the terms of the new debt instrument is at least 10 percent different from the present value of the remaining cash flows under the terms of the original instrument. However, even if the difference is less than 10 percent, the financial institution should evaluate whether the modification is more than minor based on the specific facts and circumstances surrounding the modification.

The ASU also modifies disclosure requirements. Rather than disclosing information on troubled debt restructurings, financial institutions will now be required to disclose information on loan modifications that were in the form of principal forgiveness, an interest rate reduction, an other-than-insignificant payment delay, or a term extension (or a combination thereof) made to debtors experiencing financial difficulty. Among other things, ASC 310-10-10-50-42 through 50-44 requires financial institutions to disclose, by class of financing receivable, the types of modifications utilized and certain financial effects of the modification, depending on the type of modification. ASC 310-10-55-12A provides an example of the disclosures required by ASC 310-10-10-50-42 through 50-44. The new disclosures must be made regardless of whether a modification to a debtor experiencing financial difficulty results in a new loan. In part, this section of the ASU is seen as providing structure around some of the types of modification disclosures financial institutions were providing during the coronavirus pandemic. 

Financial institutions have long had internal controls surrounding the determination of troubled debt restructurings given the impact such restructurings can have on the allowance for loan losses and financial statement disclosures. Although internal controls surrounding loan modifications will still need to exist, they will likely need to evolve as a result of ASU No. 2022-02. Furthermore, the data gathered for preparation of financial statement disclosures will also change. However, the data needed to satisfy the new disclosure requirements should be readily available, with possibly minor manipulation required to obtain the information needed under the new disclosure requirements.

Vintage disclosures

The ASU amends ASC 326-20-50-6 to require public business entities to disclose current-period gross writeoffs by year of origination for financing receivables and net investment in leases within the scope of ASC Subtopic 326-20. ASC 326-20-55-79 provides an example of this disclosure.

ASU No. 2022-02 is effective for fiscal years beginning after December 15, 2022, including interim periods within those fiscal years—the same effective date for those who have not yet adopted ASU No. 2016-13. As always, if you have any questions as to how this ASU may impact your financial institution, please reach out to BerryDunn’s Financial Services team or submit a question via our Ask the Advisor feature.
 

Article
FASB is on a roll: Another ASU aimed at financial institutions