During the CECL Methodology Webinar Series (http://web.sageworks.com/cecl-methodology-webinar-series/) questions from attendees have been compiled and answered. Access the recording to hear all the answers and dialogue: http://web.sageworks.com/cecl-methodology-webinar-series/
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Disclaimer
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This presentation may include statements that constitute “forward-looking statements” relative to
publicly available industry data. Forward-looking statements often contain words such as “believe,”
“expect,” “plans,” “project,” “target,” “anticipate,” “will,” “should,” “see,” “guidance,” “confident” and
similar terms. There can be no assurance that any of the future events discussed will occur as
anticipated, if at all, or that actual results on the industry will be as expected. Sageworks is not
responsible for the accuracy or validity of this publicly available industry data, or the outcome of the use
of this data relative to business or investment decisions made by the recipients of this data. Sageworks
disclaims all representations and warranties, express or implied. Risks and uncertainties include risks
related to the effect of economic conditions and financial market conditions; fluctuation in commodity
prices, interest rates and foreign currency exchange rates. No Sageworks employee is authorized to
make recommendations or give advice as to any course of action that should be made as an outcome
of this data. The forward-looking statements and data speak only as of the date of this presentation
and we undertake no obligation to update or revise this information as of a later date.
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Data
Questions related to the amount and type of historical data:
• How much historical data is required?
• How many historical periods do I need to include; do they need to be stored monthly, quarterly, or
annually?
• We have call report data going back n years; do we have enough data?
• We have loan number, balance, and loan term information stored; is this what you’re referring to?
• We have origination information, loan number, loan balance, and loan-level chargeoff data; what
else are we missing?
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Data
Questions related to the amount and type of historical data:
• How much historical data is required?
• How many historical periods do I need to include; do they need to be stored monthly, quarterly,
or annually?
• We have call report data going back n years; do we have enough data?
• We have loan number, balance, and loan term information stored; is this what you’re referring to?
• We have origination information, loan number, loan balance, and loan-level chargeoff data; what
else are we missing?
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Data
How much historical data is required?
How many historical periods do we need to include; do they need to be stored monthly, quarterly, or
annually?
• ASU 326-20-55-20: Community Bank A, after considering underwriting standards and the
contractual terms of loans that existed over the historical period, believes that the most recent 10-
year period is reasonable.
• 2009/2010 to 2019/2020
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Data
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When Will the Amendments Be Effective?
For public business entities that are U.S. Securities and Exchange Commission(SEC) filers, the
amendments in this Update are effective for fiscal years beginning after December 15, 2019,
including interim periods within those fiscal years. For all other public business entities, the
amendments in this Update are effective for fiscal years beginning after December 15, 2020,
including interim periods within those fiscal years. For all other entities, including not-for-profit
entities and employee benefit plans within the scope of Topics 960 through 965 on plan accounting,
the amendments in this Update are effective for fiscal years beginning after December 15, 2020, and
interim periods within fiscal years beginning after December 15, 2021. All entities may adopt the
amendments in this Update earlier as of the fiscal years beginning after December 15, 2018,
including interim periods within those fiscal years. An entity will apply the amendments in this
Update through a cumulative-effect adjustment to retained earnings as of the beginning of the first
reporting period in which the guidance is effective (that is, a modified-retrospective approach).
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Data
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When Will the Amendments Be Effective?
For public business entities that are U.S. Securities and Exchange Commission(SEC) filers, the
amendments in this Update are effective for fiscal years beginning after December 15, 2019,
including interim periods within those fiscal years. For all other public business entities, the
amendments in this Update are effective for fiscal years beginning after December 15, 2020,
including interim periods within those fiscal years. For all other entities, including not-for-profit
entities and employee benefit plans within the scope of Topics 960 through 965 on plan accounting,
the amendments in this Update are effective for fiscal years beginning after December 15, 2020, and
interim periods within fiscal years beginning after December 15, 2021. All entities may adopt the
amendments in this Update earlier as of the fiscal years beginning after December 15, 2018,
including interim periods within those fiscal years. An entity will apply the amendments in this
Update through a cumulative-effect adjustment to retained earnings as of the beginning of the first
reporting period in which the guidance is effective (that is, a modified-retrospective approach).
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Data
Questions related to the amount and type of historical data:
• How much historical data is required?
• How many historical periods do we need to include; do they need to be stored monthly, quarterly,
or annually?
• We have call report data going back n years; do we have enough data?
• We have loan number, balance, and loan term information stored; is this what you’re referring to?
• We have origination information, loan number, loan balance, and loan-level chargeoff data; what
else are we missing?
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Data
Questions related to the amount and type of historical data:
• How much historical data is required?
• How many historical periods do we need to include; do they need to be stored monthly, quarterly,
or annually?
• We have call report data going back n years; do we have enough data?
• We have loan number, balance, and loan term information stored; is this what you’re referring
to?
• We have origination information, loan number, loan balance, and loan-level chargeoff data; what
else are we missing?
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Data
Questions related to the amount and type of historical data:
• How much historical data is required?
• How many historical periods do we need to include; do they need to be stored monthly, quarterly,
or annually?
• We have call report data going back n years; do we have enough data?
• We have loan number, balance, and loan term information stored; is this what you’re referring to?
• We have origination information, loan number, loan balance, and loan-level chargeoff data; what
else are we missing?
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Data
ASU 326:
• 20-55-10 through 14 “addresses the meaning of the term portfolio segment
• 20-55-15 through 16 “addresses the application of the term credit quality indicator
• “as of the balance sheet date, the entity should use the most current information it has obtained”
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http://www.fasb.org/jsp/FASB/FASBContent_C/CompletedProjectPage&cid=1176168232014
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Contractual Life
Questions related to determination and utilization of contractual life:
• How do you calculate the average life for the loan? Can you go into more details on how it is
related to attrition analysis?
• Is attrition count based or dollar based?
• When do we use a prepayment rate such as CPR or SMM and when do we use expected life?
• How do you calculate the prepayment rate? Can you go into more detail on how it is calculated?
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Contractual Life
Questions related to determination and utilization of contractual life:
• How do you calculate the average life for the loan? Can you go into more detail on how it is
related to attrition analysis?
• Is attrition count based or dollar based?
• When do we use a prepayment rate such as CPR or SMM and when do we use expected life?
• How do you calculate the prepayment rate? Can you go into more detail on how it is calculated?
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Contractual Life
Questions related to determination and utilization of contractual life:
• How do you calculate the average life for the loan? Can you go more details on how it is related to
attrition analysis?
• Is attrition count based or dollar based?
• When do we use a prepayment rate such as CPR or SMM and when do we use expected life?
• How do you calculate the prepayment rate? Can you go into more detail on how it is calculated?
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Contractual Life
Is attrition count based or dollar based?
• In a sample of N equally likely outcomes mathematicians assign a chance (or weight) of 1/N to
each outcome
• The probability of an event is defined as the number of certain outcomes divided by the total
number of equally likely outcomes in the sample space of the experiment.
• Using a dollar based approach implies an already determined (supportable) correlation to attrition
rates.
• 11 Loans; 10 @ $1, and 1 @ $90. $90 exits the portfolio over the analysis period. Should we then assume 9 of the
remaining 10 loans will exit in the following quarter?
• If dollars are correlated to behavior, that implies a risk variance between loans within a pool that is, by definition,
intended to contain loans with similar risk characteristics
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Contractual Life
Questions related to determination and utilization of contractual life:
• How do you calculate the average life for the loan? Can you go more details on how it is related to
attrition analysis?
• Is attrition count based or dollar based?
• When do we use a prepayment rate such as CPR or SMM and when do we use expected life?
• How do you calculate the prepayment rate? Can you go into more detail on how it is calculated?
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Contractual Life
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LOAN NUMBER 4.A CAPITAL EXPENDITURES
GL Balance 115,000,000.00
Segment 4.a CapEx
Subsegment Pass
Date 12/31/2015
Interest Rate 5.50%
Discount Rate 1.53%
Payment Type Balloon
Payment Amt 3,472,528.71
Mat Date 1/31/2020
Nper 36
Renewal Assumption (months) -
CPR (Conditional Prepayment Rate) 33.00%
SMM (Standard Monthly Mortality) 3.28%
PD (Probability of Default) 2.47%
CDR (Constant Default Rate) 0.21%
LGD (Loss Given Default) 25.44%
Recovery Delay (Foreclosure Lag) 12
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Contractual Life
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LOAN NUMBER 4.A CAPITAL EXPENDITURES
GL Balance 115,000,000.00
Segment 4.a CapEx
Subsegment Pass
Date 12/31/2015
Interest Rate 5.50%
Discount Rate 1.53%
Payment Type Balloon
Payment Amt 3,472,528.71
Mat Date 1/31/2020
Nper 36
Renewal Assumption (months) -
CPR (Conditional Prepayment Rate) 33.00%
SMM (Standard Monthly Mortality) 3.28%
PD (Probability of Default) 2.47%
CDR (Constant Default Rate) 0.21%
LGD (Loss Given Default) 25.44%
Recovery Delay (Foreclosure Lag) 12
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Contractual Life
Questions related to determination and utilization of contractual life:
• How do you calculate the average life for the loan? Can you go more details on how it is related to
attrition analysis?
• Is attrition count based or dollar based?
• When do we use a prepayment rate such as CPR or SMM and when do we use expected life?
• How do you calculate the prepayment rate? Can you go into more detail on how it is calculated?
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Segmentation
Questions related to segmentation and sub-segmentation:
• We presently segregate our pooled loans by loan type (collateral) and then by risk rating. Under
CECL, would you anticipate segregating by product type, then collateral type and then risk rating?
• Can we simply break out our loan pools by call code?
• If FICO is considered a risk identifier then isn’t the most current FICO the important indicator &
thus 5 years of data with only 2 years of FICO works?
• FICO, as referenced in this question, is analogous with risk rating or any other credit quality indicator
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Segmentation
Questions related to segmentation and sub-segmentation:
• We presently segregate our pooled loans by loan type (collateral) and then by risk rating. Under
CECL, would you anticipate segregating by product type, then collateral type and then risk
rating?
• Can we simply break out our loan pools by call code?
• If FICO is considered a risk identifier then isn’t the most current FICO the important indicator &
thus 5 years of data with only 2 years of FICO works?
• FICO, as referenced in this question, is analogous with risk rating or any other credit quality indicator
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Segmentation
ASU 326-20-55-5,12,15
• Payment Structure
• Interest Only, Balloon, Amortizing, etc.
• Contract Term
• 30 yr., 15 yr., 3/1 or 5/1 ARM, Revolving, etc.
• Interest Rate
• Fixed/Variable
• Exposure/Loan Type
• Call Code, Product Type, Loan Purpose, etc.
• Example: 1.c.2.a, 4.a, 1st Lien Residential, 2nd Lien Residential, HELOC, New Auto, Used Auto, Unsecured, commercial
equipment, etc.
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Segmentation
Questions related to segmentation and sub-segmentation:
• We presently segregate our pooled loans by loan type (collateral) and then by risk rating. Under
CECL, would you anticipate segregating by product type, then collateral type and then risk rating?
• Can we simply break out our loan pools by call code?
• If FICO is considered a risk identifier then isn’t the most current FICO the important indicator &
thus 5 years of data with only 2 years of FICO works?
• FICO, as referenced in this question, is analogous with risk rating or any other credit quality indicator
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Methodology
Questions related to calculating historical loss experience:
• Vintage
• Do you need to have both the origination date and renewal date? Is it ok to replace the first origination date with the
renewal date when it happens?
• Regarding extensions/renewed loans, do you count the extended/renewed life as part of the life of the loan?
• Migration
• What's optimal for loss rate calculation? 36 months? Longer? Shorter?
• When we are talking about migration analysis, are we only concerned with the beginning credit quality indicator and
how much of that pool moved to loss OR are we following the pool through all grade changes through the life of the
loan?
• Why are you using 3-year old data? Why not use 2014-2016? Sure, you'll have some loans that weren't in existence
for the entire 3-year life of the pool, but that will be the case for any pool. It would seem that 2011-2013 loss data for
setting loss rates for 2017 and forward is nearly worthless?
• The outputs are measuring loss rates, not the migration from one risk rating to another. In my institution loss typically
occur once a credit gets to a specific risk rating. Therefore, loss rates in every risk rating category, except that one, will
essentially be 0. Am I understanding that correctly?
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Methodology
Questions related to calculating historical loss experience:
• Vintage
• Do you need to have both the origination date and renewal date? Is it ok to replace the first origination date with
the renewal date when it happens?
• Regarding extensions/renewed loans, do you count the extended/renewed life as part of the life of the loan?
• Migration
• What's optimal for loss rate calculation? 36 months? Longer? Shorter?
• When we are talking about migration analysis, are we only concerned with the beginning credit quality indicator and
how much of that pool moved to loss OR are we following the pool through all grade changes through the life of the
loan?
• Why are you using 3-year old data? Why not use 2014-2016? Sure, you'll have some loans that weren't in existence
for the entire 3-year life of the pool, but that will be the case for any pool. It would seem that 2011-2013 loss data for
setting loss rates for 2017 and forward is nearly worthless?
• The outputs are measuring loss rates, not the migration from one risk rating to another. In my institution loss typically
occur once a credit gets to a specific risk rating. Therefore, loss rates in every risk rating category, except that one, will
essentially be 0. Am I understanding that correctly?
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Methodology
Questions related to calculating historical loss experience:
• Vintage
• Do you need to have both the origination date and renewal date? Is it ok to replace the first origination date with the
renewal date when it happens?
• Regarding extensions/renewed loans, do you count the extended/renewed life as part of the life of the loan?
• Migration
• What's optimal for loss rate calculation? 36 months? Longer? Shorter?
• When we are talking about migration analysis, are we only concerned with the beginning credit quality indicator and
how much of that pool moved to loss OR are we following the pool through all grade changes through the life of the
loan?
• Why are you using 3-year old data? Why not use 2014-2016? Sure, you'll have some loans that weren't in existence
for the entire 3-year life of the pool, but that will be the case for any pool. It would seem that 2011-2013 loss data for
setting loss rates for 2017 and forward is nearly worthless?
• The outputs are measuring loss rates, not the migration from one risk rating to another. In my institution loss typically
occur once a credit gets to a specific risk rating. Therefore, loss rates in every risk rating category, except that one, will
essentially be 0. Am I understanding that correctly?
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Methodology
Regarding extensions/renewed loans, do you count the extended/renewed life as part of the life of
the loan?
ASU 326-20-6, 326-20-50-7, 310-20-35-9,10,11,12
In most cases, a renewal would result in a "new loan" for vintage or any life-of-loan analysis. The
guidance contained within the new standard (ASU 326/CECL) points to a "more than minor" test
contained within ASC 310-20: "This condition would be met if the new loan’s effective yield is at least
equal to the effective yield for such loans and modifications of the original debt instrument are more
than minor."
In practice, more than minor has been determined to be >10% change in NPV. Also, short-term
extensions that facilitate administrative needs are ignored and/or do not meet the "more than
minor" test. For example, a 90-day extension would likely not constitute a new loan while a full 3-
year renewal would.
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Methodology
Questions related to calculating historical loss experience:
• Vintage
• Do you need to have both the origination date and renewal date? Is it ok to replace the first origination date with the
renewal date when it happens?
• Regarding extensions/renewed loans, do you count the extended/renewed life as part of the life of the loan?
• Migration
• What's optimal for loss rate calculation? 36 months? Longer? Shorter?
• When we are talking about migration analysis, are we only concerned with the beginning credit quality indicator and
how much of that pool moved to loss OR are we following the pool through all grade changes through the life of the
loan?
• Why are you using 3-year old data? Why not use 2014-2016? Sure, you'll have some loans that weren't in existence
for the entire 3-year life of the pool, but that will be the case for any pool. It would seem that 2011-2013 loss data for
setting loss rates for 2017 and forward is nearly worthless?
• The outputs are measuring loss rates, not the migration from one risk rating to another. In my institution loss typically
occur once a credit gets to a specific risk rating. Therefore, loss rates in every risk rating category, except that one, will
essentially be 0. Am I understanding that correctly?
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Methodology
Questions related to calculating historical loss experience:
• Vintage
• Do you need to have both the origination date and renewal date? Is it ok to replace the first origination date with the
renewal date when it happens?
• Regarding extensions/renewed loans, do you count the extended/renewed life as part of the life of the loan?
• Migration
• What's optimal for loss rate calculation? 36 months? Longer? Shorter?
• When we are talking about migration analysis, are we only concerned with the beginning credit quality indicator
and how much of that pool moved to loss OR are we following the pool through all grade changes through the life
of the loan?
• Why are you using 3-year old data? Why not use 2014-2016? Sure, you'll have some loans that weren't in existence
for the entire 3-year life of the pool, but that will be the case for any pool. It would seem that 2011-2013 loss data for
setting loss rates for 2017 and forward is nearly worthless?
• The outputs are measuring loss rates, not the migration from one risk rating to another. In my institution loss typically
occur once a credit gets to a specific risk rating. Therefore, loss rates in every risk rating category, except that one, will
essentially be 0. Am I understanding that correctly?
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Methodology
Questions related to calculating historical loss experience:
• Vintage
• Do you need to have both the origination date and renewal date? Is it ok to replace the first origination date with the
renewal date when it happens?
• Regarding extensions/renewed loans, do you count the extended/renewed life as part of the life of the loan?
• Migration
• What's optimal for loss rate calculation? 36 months? Longer? Shorter?
• When we are talking about migration analysis are we just concerned with where a loan started, say grade 3 and how
much of that pool moved to loss OR are we following the pool through all grade changes through the life of the loan.
• Why are you using 3-year old data? Why not use 2014-2016? Sure, you'll have some loans that weren't in existence
for the entire 3-year life of the pool, but that will be the case for any pool. It would seem that 2011-2013 loss data
for setting loss rates for 2017 and forward is nearly worthless.
• The outputs are measuring loss rates, not the migration from one risk rating to another. In my institution loss typically
occur once a credit gets to a specific risk rating. Therefore, loss rates in every risk rating category, except that one, will
essentially be 0. Am I understanding that correctly?
67
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Methodology
Questions related to calculating historical loss experience:
• Vintage
• Do you need to have both the origination date and renewal date? Is it ok to replace the first origination date with the
renewal date when it happens?
• Regarding extensions/renewed loans, do you count the extended/renewed life as part of the life of the loan?
• Migration
• What's optimal for loss rate calculation? 36 months? Longer? Shorter?
• When we are talking about migration analysis are we just concerned with where a loan started, say grade 3 and how
much of that pool moved to loss OR are we following the pool through all grade changes through the life of the loan.
• Why are you using 3-year old data? Why not use 2014-2016? Sure, you'll have some loans that weren't in existence
for the entire 3-year life of the pool, but that will be the case for any pool. It would seem that 2011-2013 loss data for
setting loss rates for 2017 and forward is nearly worthless.
• The outputs are measuring loss rates, not the migration from one risk rating to another. In my institution loss
typically occur once a credit gets to a specific risk rating. Therefore, loss rates in every risk rating category, except
that one, will essentially be 0. Am I understanding that correctly?
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Methodology - Continued
Questions related to calculating historical loss experience:
• Probability of Default & Loss Given Default – note that migration principles apply
• We subscribe and/or calculate the probability of default at our institution. Can we use our current probability of
default model?
• Discounted Cash Flow
• We’re approaching $10B and are looking for a solution for DFAST and CECL. Which approach is ideal for cross
application?
• Our institution is only $500MM, we don’t need to do complex modeling such as DCF; correct?
73
Note – This is not a complete list of all methodologies that can be used to determine historical loss experience
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Methodology - Continued
Questions related to calculating historical loss experience:
• Probability of Default & Loss Given Default – note that migration principles apply
• We subscribe and/or calculate the probability of default at our institution. Can we use our current probability of
default model?
• Discounted Cash Flow
• We’re approaching $10B and are looking for a solution for DFAST and CECL. Which approach is ideal for cross
application?
• Our institution is only $500MM, we don’t need to do complex modeling such as DCF; correct?
74
Note – This is not a complete list of all methodologies that can be used to determine historical loss experience
77. Sageworksanalyst.com
Methodology - Continued
Questions related to calculating historical loss experience:
• Probability of Default & Loss Given Default – note that migration principles apply
• We subscribe and/or calculate the probability of default at our institution. Can we use our current probability of
default model?
• Discounted Cash Flow
• We’re approaching $10B and are looking for a solution for DFAST and CECL. Which approach is ideal for cross
application?
• Our institution is only $500MM, we don’t need to do complex modeling such as DCF; correct?
77
Note – This is not a complete list of all methodologies that can be used to determine historical loss experience
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Methodology
83
External Factor (National Data) R Square * Slope ** Lead (months)
Real GDP growth 20.51% -0.02% 18
Nominal GDP growth 27.45% -0.02% 18
Real disposable income growth 0.85% 0.00% 18
Nominal -disposable income growth 2.51% 0.00% 18
Unemployment rate 54.64% 0.05% 3
CPI inflation rate 0.12% 0.00% 6
3-month Treasury rate 9.56% -0.02% 6
5-year Treasury yield 0.62% -0.01% 6
10-year Treasury yield 2.45% 0.02% 6
BBB corporate yield 42.89% 0.07% 12
Mortgage rate 0.59% 0.01% 6
Prime rate 10.71% -0.02% 6
Dow Jones Total Stock Market Index (Level) 31.62% 0.00% 18
House Price Index (Level) 39.44% 0.00% 6
Commercial Real Estate Price Index (Level) 44.19% 0.00% 6
Market Volatility Index (Level) 37.21% 0.01% 18
Multi-Regression Statistics Result
Adjusted R Square 79.65%
Standard Error 0.05%
Observations 49
Regression Utilization Coefficients ***
Intercept 0.04%
Commercial Real Estate Price Index (Level) 0.00%
Unemployment rate 0.03%
BBB corporate yield 0.04%
Market Volatility Index (Level) 0.00%
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Methodology - Continued
Questions related to calculating historical loss experience:
• Probability of Default & Loss Given Default – note that migration principles apply
• We subscribe and/or calculate the probability of default at our institution. Can we use our current probability of
default model?
• Discounted Cash Flow
• We’re approaching $10B and are looking for a solution for DFAST and CECL. Which approach is ideal for cross
application?
• We’re a small institution, we don’t need to do complex modeling such as DCF; correct?
84
Note – This is not a complete list of all methodologies that can be used to determine historical loss experience
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General/Miscellaneous
General questions regarding the new standard and the impact:
• Some claim CECL may drive an increase in reserves, as much as doubling, or more. Should bank
and credit unions worry how their data will be incorporated into stress testing?
• “CECL is being delayed…”
• “New administration will abolish CECL with regulatory reform…”
• “ABA advocating to delay implementation…”
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Credit Unions are particularly vulnerable to the new standard given the industries application of
qualitative and environmental factors and/or the relationship between annual loss rates and reserve
levels:
General/Miscellaneous
94
Greater Than
1 Year in Q&E
46%Less Than 1
Year in Q&E
54% Greater Than
6 months in
Q&E
64%
Less Than 6
months in
Q&E
36%