What Is CECL vs. ACL?
For those that have not implemented the Current Expected Credit Loss (CECL) standard, the time is here. For financial institutions, an Allowance for Credit Loss (ACL) using the CECL methodology for loans replaces the former Allowance for Loan and Lease Losses (ALLL). The ALLL, originally referred to as the “reserve for bad debts,” was a valuation allowance each entity established and maintained with credits or debits against operating income – referred to as the provision for loan and lease losses.
The objective of a valuation allowance is to estimate uncollectible balances used to reduce the book value of loans and leases to amounts expected to be collected. An ACL similarly represents an estimate of uncollectible balances maintained through charges to a valuation allowance trued-up to an estimate through operating income - now referred to as expense for credit loss.
Under the CECL framework, ACLs are estimates of expected credit losses on financial assets measured at amortized cost. The measurement framework and conceptual basis supporting an ACL differs from that of the ALLL. As such, implementing CECL may have considerable impact on how the loan valuation allowance is computed. The methodology also applies to other financial assets such as receivables, held-to-maturity securities and net investments in leases for non-financial institutions.
Decoding CECL Implementation
Recently, the Financial Accounting Standards Board (FASB) issued a Practice Aid that lays out a simple five-step process to implement and adopt the requirements of FASB Accounting Standard Codification (ASC) Topic 326, Financial Instruments – Credit Losses
The following is a summary of the Practice Aid from FASB:
Measurement of Credit Losses on (ASC 326-20-15-2):
- Financing Receivables
- Held-to-Maturity debt securities
- Receivables from revenue transactions
- Receivables from repurchase agreements
- Net investments in leases
- Off balance sheet credit exposure
- Reinsurance receivables
The CECL Model does not apply to available-for-sale debt securities.
Step 1: Identify and gather contracts for all financial assets that are owned by the entity.
Step 2: Apply the following guidance for first-time adoption of CECL: (ASC 326-10-65)
- Apply ASC Topic 326 by cumulative-effect adjustment to opening retained earnings.
- Apply ASC Topic 326 prospectively for financial assets with credit deterioration to financial assets to which ASC Topic 310-30 was previously applied.
- Apply ASC Topic 326 prospectively to debt securities for which other-than-temporary impairment had been recognized before the date of adoption, such that the amortized cost basis (including previous write-downs) of the debt security is unchanged.
- Practice point: Because expected losses must now be estimated and recorded upfront and then re-measured at each reporting date, companies must have the right relevant data, relevant factors, and reasonable and supportable forecasts.
- ASC Topic 326 permits the use of a number of models and methodologies to estimate losses, so this is an area of significant judgment.
- Data must be relevant and reliable, which means it must also be available and objectively verifiable.
Step 3: Develop an Estimate of Credit Losses. (ASC 326-20-30)
- The ACL is a valuation account that is deducted from, or added to, the amortized cost basis of the financial asset(s) to present the net amount expected to be collected on the financial asset.
- Expected recoveries of amounts previously written off and expected to be written off should be included in the valuation account and should not exceed the aggregate of amounts previously written off and expected to be written off by an entity.
- At the reporting date, an allowance for credit losses should be recorded on in scope financial assets. The amount necessary to adjust the ACL for management’s current estimate of expected credit losses on financial assets should be reported in net income as a credit loss expense.
- Expected credit losses on financial assets should be measured on a collective (pool) basis when similar risk characteristics exist. If it is determined that a financial asset does not share risk characteristics with other financial assets, the financial asset should be evaluated for expected credit losses on an individual basis. A financial asset evaluated on an individual basis should not be included in a collective evaluation.
- Examples of similar risk characteristics are:
- Internal or external (third-party) credit score or credit ratings;
- Risk ratings or classification;
- Financial asset type;
- Collateral type;
- Effective interest rate;
- Geographical location;
- Industry of the borrower;
- Historical or expected credit loss patterns; or
- Reasonable and supportable forecast periods
Step 4: Review implementation guidance and illustrations as needed.
- See ASC Topic 326, Financial Instruments – Credit Losses, 20 Measured at Amortized Cost, 55 Implementation Guidance and Illustrations, for current implementation guidance and illustrations.
Step 5: Identify and prepare required presentation and disclosures.
- For financial assets measured at amortized cost, the ACL that is deducted from an asset’s amortized cost basis should be separately presented on the statement of financial position.
- When a discounted cash flow approach is used to estimate expected credit losses, the change in present value from one reporting period to the next may result not only from the passage of time, but also from changes in estimates of the timing or amount of expected future cash flows. An entity that measures credit losses based on a discounted cash flow approach is permitted to report the entire change in present value as credit loss expense (or reversal of credit loss expense). Alternatively, an entity may report the change in present value attributable to the passage of time as interest income. See ASC paragraph 326-20-50-12 for a disclosure requirement applicable to entities that choose the latter alternative.
- Changes in the fair value of the collateral should be reported as credit loss expense or a reversal of credit loss expense.
- An entity may make an accounting policy election, at either the classification of financing receivable or major security-type level, to present balances separately on the statement of financial position or within another statement of financial position line item in the accrued interest receivable balance, net of the allowance for credit losses (if any).
What Are the Risks and How Can You Mitigate Them?
As financial institutions and other entities implement CECL, it’s important to consider potential risks and internal controls that can mitigate those risks. Examples or risks and controls include:
|Inaccurate economic variable assumptions obtained from external source are used in calculations
|Prepare and periodically update an ACL memo based on economic forecasts and outlooks that is presented to an Asset Review Committee. The Committee meets at least quarterly to review economic forecasts, outlooks, changes from prior periods, and potential adjustments to the ACL calculation or model, minutes of the meetings are maintained.
|Loan setup at inception is inaccurate
|Independently review system inputs of new loans against supporting documentation such as the note, loan approval memo, loan setup sheet or checklist to ensure new, renewed loans are on-boarded properly.
|Inaccurate calculations within the ACL model or workbook
|Perform periodic reconciliations to compare balances used in ACL calculations to the core system and/or Call Report.
|Inaccurate calculations within the ACL model or workbook
|Perform periodic reconciliations to compare unfunded commitments in ACL calculations to the core system.
|Inaccurate calculations within the ACL model or workbook; qualitative adjustments are inconsistent with changes in loan portfolio or economic conditions
|Independently review ACL calculations in the model by comparison to supporting documentation as well as approved Q-factors at periodic intervals.
|Loan segmentation or other conditions required by the new CECL standard are not appropriately considered
|In the ACL memo presented to the Asset Review Committee, document methodology, assumptions used (including management estimates).
|Third party systems are inaccurate
|If using a third-party model, obtain and review third-party SOC Type 1 and 2 reports at least annually. Verify validation controls were documented and tested and determine whether there are established complementary end user controls.
|Data inputs or calculations in internally developed ACL model are inaccurate
|Establish data quality validations at multiple points through the entire data pipeline from system of origin to data preparation. On a periodic basis, have the ACL model independently reviewed for accuracy of calculations, completeness and accuracy of data inputs, and accurate inputs and usage of assumptions.
How Can Weaver Help?
Weaver’s Risk Advisory Services group has a dedicated team with the knowledge to walk you through the new CECL standard. We have consulted with several organizations to help strengthen their internal control environment and help mitigate related risks.
Authored by Priyanka (Pree) Wakharkar, CPA, CA.