SlideShare a Scribd company logo
Presented by:
Ed Bayer, Senior Risk Management Consultant
Mike Lubansky, Director of Consulting Services






Financial information company that provides
credit and risk management solutions to
financial institutions
Data and applications used by thousands of
financial institutions and accounting firms
across North America
Awards
◦ Named to Inc. 500 list of fastest growing privately
held companies in the U.S.
◦ Named to Deloitte’s Technology Fast 500


Ed Bayer
◦ Ed Bayer is a senior risk management consultant at
Sageworks, where he serves as a specialist in assisting
financial institutions with accurately interpreting and
applying federal accounting guidance.



Mike Lubansky


Mike Lubansky is a director of consulting services at
Sageworks and serves as the in-house ALLL expert. He has
led the implementation of an automated ALLL solution for
more than 70 financial institutions ranging in size from $37
million to $20 billion in assets.


FASB = Financial Accounting Standards Board
◦ Since 1973, the designated organization in the
private sector for establishing standards of financial
accounting that govern the preparation of financial
reports by nongovernmental entities.



IASB = International Accounting Standards
Board
◦ The independent standard-setting body of the
International Financial Reporting Standards (IFRS)
Foundation.


October 2002: Norwalk Agreement
◦
◦
◦
◦
◦
◦



Joint projects
Short-term convergence project
IASB member on site at FASB offices
FASB monitoring of IASB projects
Convergence research project
Consideration of convergence potential in all Board agenda
decisions

Previous joint proposals


July 2012: The boards split on the
impairment model for loan losses
◦ According to FASB Chair Leslie Seidman, “..we believe it is
essential that we address the questions that have been
raised in the U.S. before moving forward with an exposure
draft..”



FASB’s CECL Model vs. IASB’s Credit
Deterioration Model


Exposure draft issued December 2012



Accounting Standards Update (ASU) Financial



CECL = Current Expected Credit Losses



Comment period extended to May 31, 2013

Instruments-Credit Losses (Subtopic 825-15)


Forward-looking requirements
“Probable” threshold removed
Longer loss horizon
Time value of money plays a role
Collateral definitions



Impact on ALLL:







◦ Speculation that it may increase 10 to 50 percent
◦ Could lead to one-time adjustment


Issued March 2013



Exposure Draft (ED) Financial Instruments:



Comment period ends July 5, 2013

Expected Credit Losses


Amount
◦ Bucket 1: Financial instruments whose credit quality
has not significantly deteriorated since initial
recognition
◦ Bucket 2: Financial instruments whose credit quality
has significantly deteriorated since initial
recognition
◦ Bucket 3: Financial instruments for which there is
objective evidence of an impairment as of the
reporting date



Recognition









Interest changes
Purchased or originated credit-impaired
financial assets
Simplified approach for trade and lease
receivables
New disclosures – incl. reconciliation and
explanation of assumptions

Impact on ALLL:
◦ Likely would cause an increase, probably less than
CECL model


CECL Model:
◦ Forward-looking
◦ Immediate write-offs
◦ Improved definitions on interest income, collateral
dependent, etc.



Credit Deterioration Model:
◦
◦
◦
◦

Also forward-looking
Immediate write-offs
Not requiring lifetime losses for pass-rated loans
Includes financial guarantee contracts


CECL Model
◦ How to calculate future expected losses
◦ Large, immediate increase in ALLL
◦ IASB feels this approach states originated assets as
below fair value



Credit Deterioration Model
◦ How to calculate future expected losses
◦ Ambiguity surrounding Stage 2 classification
◦ CECL Model seems to be clearer in terms of PCI


Data requirements



New disclosures



Assumptions


Will there be a re-convergence?



Timeline/Expectations


Sageworks’ Risk Management Consultants
◦ 919-851-7474
◦ surety@sageworks.com





Future ALLL Webinars
Whitepaper on FASB vs. IASB will be available
Sageworks Blog
◦ How the CECL model could affect allowance levels
◦ What are financial institutions saying about FASB’s
CECL model?

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FASB vs. IASB Proposals: Can't We "ALLL" Just Get Along?

  • 1. Presented by: Ed Bayer, Senior Risk Management Consultant Mike Lubansky, Director of Consulting Services
  • 2.    Financial information company that provides credit and risk management solutions to financial institutions Data and applications used by thousands of financial institutions and accounting firms across North America Awards ◦ Named to Inc. 500 list of fastest growing privately held companies in the U.S. ◦ Named to Deloitte’s Technology Fast 500
  • 3.  Ed Bayer ◦ Ed Bayer is a senior risk management consultant at Sageworks, where he serves as a specialist in assisting financial institutions with accurately interpreting and applying federal accounting guidance.  Mike Lubansky  Mike Lubansky is a director of consulting services at Sageworks and serves as the in-house ALLL expert. He has led the implementation of an automated ALLL solution for more than 70 financial institutions ranging in size from $37 million to $20 billion in assets.
  • 4.  FASB = Financial Accounting Standards Board ◦ Since 1973, the designated organization in the private sector for establishing standards of financial accounting that govern the preparation of financial reports by nongovernmental entities.  IASB = International Accounting Standards Board ◦ The independent standard-setting body of the International Financial Reporting Standards (IFRS) Foundation.
  • 5.  October 2002: Norwalk Agreement ◦ ◦ ◦ ◦ ◦ ◦  Joint projects Short-term convergence project IASB member on site at FASB offices FASB monitoring of IASB projects Convergence research project Consideration of convergence potential in all Board agenda decisions Previous joint proposals
  • 6.  July 2012: The boards split on the impairment model for loan losses ◦ According to FASB Chair Leslie Seidman, “..we believe it is essential that we address the questions that have been raised in the U.S. before moving forward with an exposure draft..”  FASB’s CECL Model vs. IASB’s Credit Deterioration Model
  • 7.  Exposure draft issued December 2012  Accounting Standards Update (ASU) Financial  CECL = Current Expected Credit Losses  Comment period extended to May 31, 2013 Instruments-Credit Losses (Subtopic 825-15)
  • 8.  Forward-looking requirements “Probable” threshold removed Longer loss horizon Time value of money plays a role Collateral definitions  Impact on ALLL:     ◦ Speculation that it may increase 10 to 50 percent ◦ Could lead to one-time adjustment
  • 9.  Issued March 2013  Exposure Draft (ED) Financial Instruments:  Comment period ends July 5, 2013 Expected Credit Losses
  • 10.  Amount ◦ Bucket 1: Financial instruments whose credit quality has not significantly deteriorated since initial recognition ◦ Bucket 2: Financial instruments whose credit quality has significantly deteriorated since initial recognition ◦ Bucket 3: Financial instruments for which there is objective evidence of an impairment as of the reporting date  Recognition
  • 11.
  • 12.
  • 13.      Interest changes Purchased or originated credit-impaired financial assets Simplified approach for trade and lease receivables New disclosures – incl. reconciliation and explanation of assumptions Impact on ALLL: ◦ Likely would cause an increase, probably less than CECL model
  • 14.  CECL Model: ◦ Forward-looking ◦ Immediate write-offs ◦ Improved definitions on interest income, collateral dependent, etc.  Credit Deterioration Model: ◦ ◦ ◦ ◦ Also forward-looking Immediate write-offs Not requiring lifetime losses for pass-rated loans Includes financial guarantee contracts
  • 15.  CECL Model ◦ How to calculate future expected losses ◦ Large, immediate increase in ALLL ◦ IASB feels this approach states originated assets as below fair value  Credit Deterioration Model ◦ How to calculate future expected losses ◦ Ambiguity surrounding Stage 2 classification ◦ CECL Model seems to be clearer in terms of PCI
  • 17.  Will there be a re-convergence?  Timeline/Expectations
  • 18.  Sageworks’ Risk Management Consultants ◦ 919-851-7474 ◦ surety@sageworks.com    Future ALLL Webinars Whitepaper on FASB vs. IASB will be available Sageworks Blog ◦ How the CECL model could affect allowance levels ◦ What are financial institutions saying about FASB’s CECL model?