The ramifications of CECL on Financial Institutions has in large part focused on Banks, but as we addressed in a recent paper, “Current Expected Credit Loss: Why the Expectations Are Different,” this new accounting treatment extends to a much larger universe. An example of this are the captives that finance American’s love affair with cars; their portfolios of leases and loans have become much larger and the implications of CECL more significant.
As with other institutions, data, platforms, and modeling make up the challenges that captives will have to address. But unlike other types of institutions captives have more concentrated portfolios, which may aid in “pooling” exercises, but may be inadvertently affected by scenario modeling. A basic tenet for all institutions is the life-of-loan estimate and the use of reasonable and supportable forecasts. While some institutions may have had “challenger” models in the past that moved in this direction, captives have not tended to utilize this type of approach in the past.
The growth of captives portfolios and the correlation to a number of macro-economic factors (e.g. interest rates, commodity prices, tariffs, etc.) call for data and scenarios that require a different level of modeling and forecasting. Because FASB does not provide template methodologies or calculations it will be necessary to develop these scenarios with the mindset of the “reasonable and supportable” requirement. While different approaches will likely be adopted, those that utilize transaction level data have the ability to provide a higher level of accuracy over time, resulting in the goals laid out in the new guidelines. As might be imagined the ability to leverage experience in the development and deployment of these types of models can’t be overemphasized.
We have found that having the ability to manage the following functional components of the platform are critical to building a flexible platform that can manage the changing needs of the users:
- Scenario Management
- Input Data Mapping and Registry
- Configuration Management
- Model Management
Experience has taught that there are significant considerations in implementing CECL, but there are also some improvements that can be realized for institutions that develop a well-structured plan. Captives are advised to use this as an opportunity to realize efficiencies, primarily in technology and existing models. Considerations around data, platforms, and the models themselves should leverage available resources to ensure that investments made to address this change provide as much benefit as possible, both now and into the future.