Find out how banks and credit unions calculate the required reserve for impaired loans in the loan portfolio. This session reviews the three most common methods for impairment analysis: Present Value of Future Cash Flow, Market Value of Collateral and Loan Pricing. Visit www.sageworks.com for more resources on the allowance for banks.
2. About Sageworks
• Thought leader for
institutions and examiners
• Regularly featured in
national and trade media
• Lending, Credit Risk and
Portfolio Risk Solutions
• More than 1,100 financial
institution clients
• Founded in 1998
3. Agenda
• Estimation of the ALLL
• Classification of loans – FAS 5 (ASC 450-20) & FAS 114 (ASC 310-10-35)
• Three valuation methods for impaired loans
• Common challenges with impairment
• When to move a loan from FAS 114 back to FAS 5 status
• Questions
3
“The Allowance for Loan and Lease Losses (ALLL) is one of the
most important estimations in a financial institution...”
4. Estimation of the ALLLL
• Loan losses will happen
• ALLL level adequate to absorb estimated credit losses
» Overstated vs. understated
• Source of confusion: Classification of loans
4
“Every national bank must have a program to establish
and regularly review the adequacy of its allowance. . .”
5. Classification of Loans
• FAS 5 (ASC 450-20) = Non-impaired
• FAS 114 (ASC 310-10-35) = Impaired
5
“Calculations should be based on a comprehensive, well
documented, and consistently applied methodology . . .”
6. Classification of Loans: FAS 5
• FAS 5 (ASC 450-20) pool = Non-impaired
» Classified as FAS 5 if they are not otherwise impaired
» Homogenous pools
» Historical data
» Qualitative and environmental factors
» Examples
6
“Segment loans into pools with similar characteristics,
such as risk classification, type of loan, industry, etc.. . .”
7. Classification of Loans: FAS 114
• FAS 114 (ASC 310-10-35) = Impaired
» When is a loan considered impaired?
» Evaluated on individual basis
» Three valuation methods
» Often includes:
• Substandard loans
• TDR loans
• Nonaccrual loans
• Loans > 90 days past due
7
“Under FAS 114, a loan is impaired when it is probable that
the bank will be unable to collect all amounts due. . .”
8. Impaired vs. Impairment
• Impaired loans
• Calculated impairment
• You can have an impaired loan but no calculated impairment reserve
• Example
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9. 3 Valuation Methods for FAS 114
1. Fair Market Value of Collateral
2. Present Value of Future Cash Flows
3. Loan Pricing
9
“The allowance is a valuation reserve maintained to
cover losses that are probable and estimable. . .”
10. Fair Market Value of Collateral
• Most widely used method
• Collateral dependent loans
» “A loan is collateral dependent if repayment of the loan is expected to be
provided solely by the underlying collateral.”
- Interagency Policy Statement on the ALLL
• Need current appraisal values and subject dates
• Specific impairment
10
“Collateral dependent – the only source of repayment expected
is the underlying collateral and no other cash flows. . .”
11. Fair Market Value of Collateral
11
Appraised collateral value minus discounts and/or liquidation costs = Fair Value/Valuation Amount
The valuation amount exceeds the Total Recorded Investment, therefore no reserve is required.
“FAS 114 requires that the measure of impairment be
based on the fair value of the collateral. . .”
$0
12. Fair Market Value of Collateral
12
Appraised collateral value minus discounts and/or liquidation costs = Fair Value/Valuation Amount
Total Recorded Investment exceeds the valuation amount. Therefore, the difference between them is the reserve amount.
“FAS 114 requires that the measure of impairment be
based on the fair value of the collateral. . .”
$100,000
13. Fair Market Value of Collateral
13
The valuation amount exceeds the total recorded investment; therefore no reserve is required.
“FAS 114 requires that the measure of impairment be based on the fair
value of the collateral. . .”
14. Fair Market Value of Collateral
14
“FAS 114 requires that the measure of impairment be based on the fair
value of the collateral. . .”
The Total Recorded Investment exceeds the valuation amount.
Therefore, the difference between them is the reserve amount.
15. Fair Market Value of Collateral
15
“FAS 114 requires that the measure of impairment be based on the fair
value of the collateral. . .”
“In general, any portion of the recorded investment in a collateral-dependent loan
(including any capitalized accrued interest, net deferred loan fees or costs, and
unamortized premium or discount) in excess of the fair value of the collateral that
can be identified as uncollectible, and is therefore deemed a confirmed loss, should
be promptly charged off against the ALLL.”
-Interagency Policy Statement on the ALLL
16. Fair Market Value of Collateral
16
“collateral dependent – the only source of repayment expected is the
underlying collateral and no other cash flows. . .”
DOCUMENTATION – SUBSTANTIATION!
How was fair value determined? (E.g., Appraisals, valuation assumptions, and
calculations)
Supporting rationale for adjustments to appraised values, if any
Determinations of costs to sell, if applicable
Appraisal quality and the expertise and independence of the appraiser
17. Present Value of Future Cash Flows
Method
17
“.. discounting the expected future cash flows from the present value
using the loan’s effective interest rate. . .”
Used when there is an expectation of cash payments (TDRs, etc.)
Cash flows should be the institution's best estimate based on reasonable and
supportable assumptions and projections.
Consider the likelihood of the possible outcomes
Discount rate = “Effective”, originally contracted interest rate
Month-to-month payment schedule for analysis
19. Present Value of Future Cash Flows
Method
19
Calculated Reserve: $170,494.31
No Calculated Reserve
20. Loan Pricing Method
• Rarely used
• How is the value derived?
• Primary challenge – defending and documenting the amount, source and date of
the observable market price
20
21. Common Challenges with Impairment
• Determining the most appropriate valuation method to be used
• What to include in Total Recorded Investment
• PV FCF can be somewhat subjective
• Examiners wary of excessive optimism
• Documentation is a must
• Switching valuation methods – documenting/defending the change
• When is it appropriate to move back to FAS 5 (ASC 450-20)?
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22. Moving a Loan Back to FAS 5
• Smaller balance loans?
• Impaired loans with zero calculated impairment?
• Nonaccruals that return to performing status?
• TDRs?
• What if I evaluate all my substandard loans individually at first?
22
23. Additional resources:
» Whitepapers, archived webinars and more: sageworks.com
» LinkedIn: ALLL Forum for Bankers
» ALLL.com
Additional Resources & Contact Info
Notes de l'éditeur
Ed
In intro, make sure to note your role, Ed. You’ll be moderating the discussion and adding commentary throughout.
Ed
1. All attendees are on listen-only mode, so no need to worry about background noise on your end.
2. Slides – You each should have received a link in the GoToWebinar panel on your screen, whereby you may access a pdf download of today’s slides.
3. Questions & Comments – we encourage questions throughout the presentation and will do our best to address as many of those questions as time permits at the conclusion of the presentation. To ask questions, please utilize the GoToWebinar panel on your screen, where you may type in those questions.
4. Polls – We will have a couple live interactive polls throughout the presentation, which we invite you each to participate in. This may be accomplished by simply utilizing your mouse to click on your respective selection.
Regan
Need to update roles – inconsistent w/ first title slide, and inconsistent here.
Regan – then transition to Chuck
Not sure about this slide?
Chuck
Chuck
Garrett – Mention the WP
Chuck
Garrett
Ed will do the poll question first, then Chuck will continue w/ this slide.
**Poll question at beginning of this slide**
When performing an impairment analysis using the fair market value of collateral, what aspect troubles your institution the most? *Be sure to mention writing in another option using the questions box*
-Selling Costs
-Accurate Appraisals
-Calculating proper reserve for relationships w/ shared & unshared collateral
-Calculating proper reserve for partial guarantee loans
-Documenting & defending your reserve calculation
**If other, please specify**
Chuck?
Chuck?
Chuck
Chuck
Ed will facilitate the poll question, then turn over to Garrett
**Poll question at beginning of this slide**
When performing an impairment analysis using the PV of FCF method, which aspect troubles your institution most?
-Using the effective original interest rate for the discount
-Determining/justifying the EXPECTED Monthly Payment
-If/when to generate a balloon payment in the cashflow schedule
-Generate an accurate present value cashflow schedule
Garrett?
Garrett?
Garrett?
Using the effective original interest rate for the discount
Determining/justifying the EXPECTED Monthly Payment
If/when to generate a balloon payment in the cashflow schedule
Generate an accurate present value cashflow schedule
Garrett
Garrett
Garrett
Chuck
Chuck??
Regan – Narrate the two final poll questions, before turning over for questions.