Accounting and regulatory changes often require resources and efforts above and beyond “business as usual”, especially those like CECL that are significant departures from previous methods. The efforts needed can be as complex as those for a completely new technology implementation and can take precedence over projects that are designed to improve your core business … and stakeholder value.
But with foresight and proper planning, you can prepare for a change like CECL by leveraging resources in a way that will maximize your efforts to meet these new requirements while also enhancing business value. At Financial Risk Group, we take this approach with each of our clients. The key is to start by asking “how can I use this new requirement to generate revenue and maximize business performance?”
The Biggest Bang Theory
In the case of CECL, there are two significant areas that will create the biggest institution-wide impact: analytics and data governance. While the importance of these is hardly new to financial institutions, we are finding that many neglect to leverage their CECL data and analytics efforts to create that additional value. Some basic first steps you can take include the following.
- Ensure that the data utilized is accurate and that its access and maintenance align to the needs and policies of your business. In the case of CECL these will be employed to create scenarios, model, and forecast … elements that the business can leverage to address sales, finance, and operational challenges.
- For CECL, analytics and data are leveraged in a much more comprehensive fashion than previous methods of credit assessment provided. Objectively assess the current state of these areas to understand how the efforts being put toward CECL implementation can be leveraged to enhance your current business environment.
- Identify existing available resources. While some firms will need to spend significant effort creating new processes and resources to address CECL, others will use this as an opportunity to retire and re-invent current workflows and platforms.
Recognizing the business value of analytics and data may be intuitive, but what is often less intuitive is knowing which resources earmarked for CECL can be leveraged to realize that broader business value. The techniques and approaches we have put forward provide good perspective on the assessment and augmentation of processes and controls, but how can these changes be quantified? Institutions without in-house experienced resources are well advised to consider an external partner. The ability to leverage expertise of staff experienced in the newest approaches and methodologies will allow your internal team to focus on its core responsibilities.
Our experience with this type of work has provided some very specific results that illustrate the short-term and longer-term value realized. The example below shows the magnitude of change and benefits experienced by one of our clients: a mid-sized North American bank. A thorough assessment of its unique environment led to a redesign of processes and risk controls. The significant changes implemented resulted in less complexity, more consistency, and increased automation. Additionally, value was created for business units beyond the risk department. While different environments will yield different results, those illustrated through the methodologies set forth here provide a good example to better judge the outcome of a process and controls assessment.
| ||Legacy Environment||Automated Environment
|Reporting Output||No daily available manual controls for risk reporting||Daily in-cycle reporting controls are automated with minimum manual interaction
|Process Speed||Credit run 40+ hours|
Manually-input variables prone to mistakes
|Credit run 4 hours
Cycle time reduced from 3 days to 1 for variable creation
|Controls & Audit||Multiple audit issues and Regulatory MRAs||Audit issues resolved and MRA closed
|Model Execution||Spreadsheet driven||90 models automated resulting in 1,000 manual spreadsheets eliminated
While one approach will not fit all firms, providing clients with an experienced perspective on more fully utilizing their specific investment in CECL allows them to make decisions for the business that might otherwise never be considered, thereby optimizing the investment in CECL and truly ensuring you receive the full value from your CECL buck.
More information on how you can prepare for—and drive additional value through—your CECL preparation is available on our website and includes:
White Paper – CECL: Why the expectations are different
White Paper – CECL Scenarios: Considerations, Development and Opportunities
Blog – Data Management: The Challenges