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© 2018 Mark H. Smith, Inc. CECL – What To Do Now All rights reserved WWW.MARKHSMITH.COM Page 0 Presented by: Webinar will begin on the hour CECL OVERVIEW AND WHAT TO DO NOW PRESENTED BY: MATT JACOBSEN, V.P. (Webinar will begin on the hour)

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Page 1: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

© 2018 Mark H. Smith, Inc. CECL – What To Do NowAll rights reserved

WWW.MARKHSMITH.COM

Page 0

Presented by:

Webinar will begin on the hour

CECL OVERVIEW AND WHAT TO DO NOW

PRESENTED BY:MATT JACOBSEN, V.P.

(Webinar will begin on the hour)

Page 2: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

© 2018 Mark H. Smith, Inc. CECL – What To Do NowAll rights reserved

WWW.MARKHSMITH.COM

Page 1

OVERVIEW

• The industry has been inundated with CECL

• What should I be focusing on now

• Find a process and methodology that will be right for your credit union

Page 3: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

© 2018 Mark H. Smith, Inc. CECL – What To Do NowAll rights reserved

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Page 2

AGENDA

• CECL Overview• Timeline• Action Plan• Data Assessment• Methodologies• Other Considerations• Credit Union Fit

Page 4: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

© 2018 Mark H. Smith, Inc. CECL – What To Do NowAll rights reserved

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Page 3

WHAT ISFASB is replacing the current “incurred loss” accounting model with a current expected credit loss accounting model – CECL

The new standard requires an estimate at origination / purchase and periodic assessments of the lifetime expected credit losses for all financial assets that are within its scope.

Page 5: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

© 2018 Mark H. Smith, Inc. CECL – What To Do NowAll rights reserved

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WHY THE CHANGE?

Current expected credit loss – CECL• Aligns the accounting with the

economics of the financial asset.• Record the full amount of

expected credit loss at acquisition

• Provides higher transparency and accuracy

• More timely

Criticism of the current

methodology is the losses are

recognized “too little and “too

late”.

Page 6: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

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Page 5

HOW WILL IT WORK?

Estimate the expected loss over the life of the loan using the following:

1. Historical loan data

2. Current conditions

3. Reasonable forecasts

Page 7: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

© 2018 Mark H. Smith, Inc. CECL – What To Do NowAll rights reserved

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TIMELINE01/01/2021 - Credit Union implementation date 12/31/2021 - Credit Union first Call Report date 01/01/2020 - Parallel run encouraged

• comparisons• adjustments• capital analysis

12/15/2018 - Early adoption is allowed (for fiscal years beginning after this date.)

Page 8: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

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Page 7

POLL QUESTION 1

Page 9: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

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• Define who should be involved• include the right people at the right times

• Develop a project plan timeline• Data Assessment• Methodology solution• Adjustments• Consider a CECL committee• Stay flexible – interpretations will continue

Page 10: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

© 2018 Mark H. Smith, Inc. CECL – What To Do NowAll rights reserved

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Data completeness Data integrity Historical data

Review data capture at input level

Purchased asset

considerations

DATA ASSESSMENT FRAMEWORK

http:/www.markhsmith.com/ensuring-data-completeness-integrity

Page 11: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

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DATA ASSESSMENT CONSIDERATIONS

• There is no absolute data set.

• Dependent on the methodology(s)

• More data elements and history

• may allow for better utilization

• different methodology(s)

• Consider the cost/effort versus the benefit

Page 12: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

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Page 11

CREDIT UNION SPECIFIC DATA ELEMENTS

Loan file

Charge off

Page 13: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

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CREDIT UNION SPECIFIC DATA ELEMENTSCOMPREHENSIVE LOAN ANALYSYIS EXAMPLE

Loan IDAccount NumberMember NumberAddress, City, State, ZipCollateral CodeLoan TypeTermMaturity DateBalloon Payment DateBalloon Payment AmountOrigination DateOriginal Balance / Credit Limit Current BalanceLast Payment DateNext Payment Date

Days Past DueCharge Off Amount (loan type, origination date, specific loan)Recovery amount, date, and loan type (recovery expenses)Loss ProbabilitiesCurrent Interest Rate (f/v)Lien PositionOriginal Appraised ValueAppraisal DateOriginal and Current LTVOriginal/Current FICODebt to Income

Page 14: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

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EXTERNAL DATA NEEDED FOR FORECAST• Economic data that correlates best with

credit performance.• Examples:

• Unemployment rate• GDP• Consumer Spending

• Historical economic data available on FRED (Federal Reserve Economic Data).

• Consider regional economic data.• Other considerations

• Regional Home Price Indices (for updating LTVs)

Page 15: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

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Page 14

PEER AND INDUSTRY DATA

The current interpretation of FASB is that credit unions can use external peer data (also use for benchmarking)

Must be representative of the credit union’s experience.

A plan must be in place and progress being made towards using the institutions own data.

Page 16: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

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Page 15

SEGMENTATION

• By loan type at the Call Report level

• Minimum and may be fine for some cu’s

• Better CECL refinement and more loan analysis (pricing / performance) can be obtained by pooling at more refined level.

• Better segmentation will minimize ALLL.

• FICO• Origination Date• Branch

Page 17: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

© 2018 Mark H. Smith, Inc. CECL – What To Do NowAll rights reserved

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Page 16

DATA ASSESSMENT SUMMARY

Primary priority at this time.

• Identify data gaps (even if you are not 100% sure it will be utilized).

• Start capturing and maintaining missing data.

• Better data equals • more methodologies to consider• better analysis • and better support.

Page 18: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

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Page 17

POLL QUESTION 2

Page 19: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

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Page 18

METHODOLOGIES

HISTORICAL LOSS RATE

PROBABILITY OF DEFAULT / LOSS GIVEN DEFAULT

PD / LGD

VINTAGE ANALYSIS(Inherent economic conditions built in)

DISCOUNTED CASH FLOW METHOD

(DCF)

Different methodologies can be used for different financial asset types

Page 20: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

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HISTORICAL LOSS RATE

• Cumulative loss rate over expected life• Historical lifetime loss experience (1.5%)• +/- Adjustments (past events and current

conditions) (+.10% due to property value decline)

• +/- Adjustments for forecasts (reasonable and supportable) (+.05% due to a forecasted increase in the unemployment rate)

• = Loss Rate 1.65%

Page 21: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

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PROBABILITY OF DEFAULT / LOSS GIVEN DEFAULTPD / LGD

• Probability of default: average percentage of loans that default over a given time period (0.50%) x

• Loss given default: percentage of exposureif the loan defaults (20.0%) +

• Qualitative Adjustments (0.40%)

• = Loss Rate +.50%

Loan pools that are statistically too small, haven’t experienced a material amount of default in the loan data available, or new loan types that may need to utilize industry/peer data.

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VINTAGE PREDICTABLE LOSSES BASED ON SEASONING OF STATIC POOLS

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DISCOUNTED CASHFLOW

• May benefit longer average life assets• Industry-level PD and LGD can be

incorporated• Expected cash flows, including the

consideration for current conditions, reasonable and supportable forecasts, are discounted at a rate that equates the purchase price with the cash flows expected.

• Utilized prepayment speeds to derive estimated cash flows.

Page 24: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

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Page 23

ADJUSTMENTSAdjustments may be quantitative or qualitative

1. Based on external current conditions 1. Credit cycle

2. Economic

3. Other external industry adjustments

2. Based on internal current information1. Current FICO and/or credit rating

2. Current LTV

3. Reasonable forecast

Page 25: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

© 2018 Mark H. Smith, Inc. CECL – What To Do NowAll rights reserved

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Page 24

POLL QUESTION 3

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CAPITAL ANALYSIS• Initial adjustment – one-time charge to capital

and the ALLL account, not a flow through on the income statement.

• Subsequent entries will be through the income statement.

• Some are thinking 10% to 50% higher than current reserves.

• The weighted average life of the loan portfolio will be a factor.

Page 27: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

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Page 26

LINES OF CREDIT• Revocable without cause or notice to be

excluded.

• Would the credit union actually cancel a line without cause.

• Forecasting line of credit usage in different credit and economic cycle forecasts.

• Example - credit card balances continue to grow and economic cycle turns

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INVESTMENTS

• Included in scope

• Easier to assess expected credit loss in the investment portfolio for most credit unions

• FASB CECL update – An entity is not required to measure expected credit losses on assets where “potential default is greater than zero, but expected nonpayment is zero.”

• Equity in CUSOs and Corporates?

Page 29: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

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Prepayment speeds

Weighted Average

Remaining Maturity

More Complex

Disclosures

OTHER ITEMS OF CONSIDERATION

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Page 29

MORE COMPREHENSIVE LOAN ANALYTICS

• Make better decisions• Improve

• Loan offerings• Underwriting• Pricing• Credit management

• Trends and factors• Concentrations• Risk Migration

• Affordable to all CUs

• Understand loan portfolio performance better

Page 31: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

BEST SOLUTION FOR YOUR CREDIT UNION• Affordable• Does the job

(flexible, options, comparability, support)• Understands our credit union• Fits our resources available for CECL

MHSI INTRODUCING A CECL ONLY AND COMPREHENSIVE LOAN

PORTFOLIO ANALYSIS SOLUTION

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CONSIDERATIONS

• Have an action plan

• Be adaptable to change

• Stay focused

• Best implementation for your credit union

OBSERVATIONS

• Continue to unfold

• FASB interpretations

• Regulators

• Auditors

Page 33: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

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REMEMBER FASB AND REGULATORS

ACKNOWLEDGE THE SOLUTION SHOULD BE

COMMENSURATE WITH THE SIZE AND COMPLEXITY OF

THE CREDIT UNION

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If you have not already, it is definitely time to assess where you are at in this process, plan, and prepare.

Reminds me a lot of Y2K for those of you that remember. There was a lot involved to get ready, but it came and went without the world ending.

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Page 34

WHAT IS APPROPRIATE FOR MY CREDIT UNION

There has been a lot put out there about CECL and what you will need and I expect it will continue.

In your planning and development I would strongly urge you to continually be thinking about what are the right questions, answers, and solutions for your credit union?

We have emphasized that throughout this presentation because it is definitely not going to be a one size fits all.

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HOW DO I WANT TO COMMIT MY CREDIT UNION RESOURCES?

IN-HOUSE

• Develop inhouse• Purchase a solution

that we run• “Help line” function• Responsive and

dedicated to CU support

• Internal personnel resources

OUTSOURCE

• Not all solutions are the same

• Various costs• Methodologies and

Options• Support differences• One shoe does not fit

all

Page 37: CECL Overview and What To Be Considering Now - Read-Only · 2018-04-03 · There has been a lot put out there about CECL and what you will need and I expect it will continue. In your

THANK YOU FOR ATTENDINGWOULD YOU LIKE TO KNOW MORE ABOUT OUR SERVICES?

CECL SOLUTIONCOMPREHENSIVE LOAN ANALYSIS SOLUTION

IRR/ALM OUTSOURCED SOLUTIONSIRR/ALM MODEL REVIEW/VALIDATION

PEER ANALYSIS

PLEASE CONTACT US800.268.7795

[email protected]