CECL—Questions to Consider When Selecting Loss Methodologies

Paragraph 326-20-30-3 of the Financial Accounting Standards Board (FASB) standards update[1] states: “The allowance for credit losses may be determined using various methods”. I’m not sure if any statement, other than “We need to talk”, can be as fear inducing. Why is it scary? Because in the world of details and accuracy, this statement is remarkably vague and not prescriptive.

Below are some questions to consider when determining the appropriate loss methodology approaches for a given segment.

How much history do you have?

If a financial institution (FI) has limited history[2] then the options available to them are, well, limited. To build a model one needs sufficient data to capture the behavior (e.g., performance or payment) of accounts. Without enough data the probability of successfully building a model is low. Worse yet, even if one builds a model, the likelihood of it being useful and robust is minimal. As a result, loss methodology approaches that do not need a lot of data should be considered (e.g., discount cashflow or a qualitative factor approach based on industry information).

Have relevant business definitions been created?

The loss component approach (decomposing loss into PD, LGD, and EAD) is considered a leading practice at banks[3]. However, in order to use this approach definitions of default and, arguably, paid-in-full, need to be created for each segment being modeled. (Note: these definitions can be the same or different across segments.) Without these definitions, one does not know when an account has defaulted or paid-off.

Is there a sufficient number of losses or defaults in the data?

Many of the loss methodologies available for consideration (e.g., loss component or vintage loss rates) require enough losses to discern a pattern. As a result, banks that are blessed with infrequent losses can feel cursed when they try to implement one of those approaches. While low losses do not necessarily rule out these approaches, it does make for a more challenging process.

Are loan level attributes available, accurate, and updated appropriately?

This question tackles the granularity of an approach instead of an approach itself. As mentioned in the post CECL – Data (As Usual) Drives Everything, there are three different data granularity levels a model can be built on. Typically, the decision is between loan-level versus segment level. Loan-level models are great for capturing sensitivities to loan characteristics and macroeconomic events provided the loan characteristics are accurate and updated (if needed) on a regular interval.

Jonathan Leonardelli, FRM, Director of Business Analytics for the Financial Risk Group, leads the group responsible for model development, data science, documentation, testing, and training. He has over 15 years’ experience in the area of financial risk.

 

[1]FASB accounting standards update can be found here

[2] There is no consistent rule, at least that I’m aware of, that defines “limited history”. That said, we typically look for clean data reaching back through an economic cycle.

[3] See: Capital Planning at Large Bank Holding Companies: Supervisory Expectations and Range of Current Practice August 2013

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CECL—The Caterpillar to Butterfly Evolution of Data for Model Development

CECLData (As Usual) Drives Everything

IFRS 9: Evaluating Changes in Credit Risk

Determining whether an unimpaired asset’s credit risk has meaningfully increased since the asset was initially recognized is one of the most consequential issues banks encounter in complying with IFRS 9. Recall the stakes:

  • The expected credit loss for Stage 1 assets is calculated using the 12-month PD
  • The ECL for Stage 2 assets (defined as assets whose credit risk has significantly increased since they were first recognized on the bank’s books) is calculated using the lifetime PD, just as it is for Stage 3 assets (which are in default).

To make the difference more concrete, consider the following:

  • A bank extends an interest-bearing five-year loan of $1 million to Richmond Tool, a hypothetical Virginia-based tool, die, and mold maker serving the defense industry.
  • At origination, the lender estimates the PD for the next 12 months at 1.5%, the PD for the rest of the loan term at 4%, and the loss that would result from default at $750,000.
  • In a subsequent reporting period, the bank updates those figures to 2.5%, 7.3%, and $675,000, respectively.

If the loan were still considered a Stage 1 asset at the later reporting date, the ECL would be $16,875. But if it is deemed a Stage 2 or Stage 3 asset, then the ECL is $66,150, nearly four times as great.

Judging whether the credit risk underlying those PDs has materially increased is obviously important. But it is also difficult. There is a “rebuttable presumption” that an asset’s credit risk has increased materially when contractual payments are more than 30 days past due. In general, however, the bank cannot rely solely upon past-due information if forward-looking information is to be had, either on a loan-specific or a more general basis, without unwarranted trouble or expense.

The bank need not undertake an exhaustive search for information, but it should certainly take into account pertinent intelligence that is routinely gathered in the ordinary course of business.

For instance, Richmond Tool’s financial statements are readily available. Balance sheets are prepared as of a point in time; income and cash flow statements reflect periods that have already ended. Nonetheless, traditional ratio analysis serves to evaluate the company’s prospects as well as its current capital structure and historical operating results. With sufficient data, models can be built to forecast these ratios over the remaining life of the loan. Richmond Tool’s projected financial position and earning power can then be used to predict stage transitions.

Pertinent external information can also be gathered without undue cost or effort. For example, actual and expected changes in the general level of interest rates, mid-Atlantic unemployment, and defense spending are likely to affect Richmond Tool’s business prospects, and, therefore, the credit risk of the outstanding loan. The same holds true for regulatory and technological developments that affect the company’s operating environment or competitive position.

Finally, the combination of qualitative information and non-statistical quantitative information such as actual financial ratios may be enough to reach a conclusion. Often, however, it is appropriate to apply statistical models and internal credit rating processes, or to base the evaluation on both kinds of information. In addition to designing, populating, and testing mathematical models, FRG can help you integrate the statistical and non-statistical approaches into your IFRS 9 platform.

For more information about FRG’s modeling expertise, please click here.

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