The Federal Deposit Insurance Corporation (FDIC) approved a measure that will allow a three-year phase in of the impact of CECL on regulatory capital yesterday (12/18/18). This change will also delay the impact on bank stress tests until 2020. The change does not affect the rule itself but now allows banks the option to phase in impacts of CECL on regulatory capital over a three-year period. The details of this change can be found in the FDIC memorandum released yesterday. The memorandum also adjusts how reserves for “bad loans” will be accounted for in regulatory capital.
The Financial Risk Group is recommending that banks utilize this time to better understand the impact, and the opportunities, that result from the mandated changes. “Time to implementation has been a limiting factor for some institutions to explore the identification of additional stakeholder value, but this should no longer be the case,” stated John Bell, FRG’s managing partner. FRG has (and is currently) partnered with clients of all types on a number of assessments and implementations of CECL. The lessons to date regarding CECL are available in a number of our publications, including: CECL-Considerations, Developments, and Opportunities and Current Expected Credit Loss-Why The Expectations Are Different.