CREDIT LOSSES
12D. ACL
Bank Accounting Advisory Series
270
August 2018
12D.
Allowance for Credit Losses
N
EW
Early adopters only
ASU 2016-13 introduces CECL for estimating the ACL. CECL replaces the incurred loss
methodology that is currently used to estimate the ALLL. Under CECL, the ACL is a
valuation account that represents the bank’s estimate of the lifetime expected credit losses. The
ACL is measured as the difference between a financial asset’s amortized cost basis and the
amount expected to be collected.
All of the staff responses included in Subtopic 12D comply with ASU 2016-13. These
responses should not be applied by an institution that has not adopted ASU 2016-13.
Question 1
What is meant by “lifetime” in the context of lifetime expected credit losses?
Staff Response
Lifetime expected credit losses are the amounts the bank does not expect to collect over the
loan’s contractual life. When determining the contractual life, a bank should consider the
impact expected prepayments will have on the contractual term, but is generally precluded
from extending the contractual term for expected extensions, renewals, or modifications. The
life of a loan should only extend beyond the contractual maturity date when
the bank
reasonably expects that the loan will be modified as a TDR. For more information on TDRs
under CECL, see Topic 12B.
Question 2
How should a bank measure lifetime expected credit losses?
Staff Response
A bank will need to apply judgment to select an estimation method(s) that is appropriate and
practical for its circumstances to measure expected credit losses. Various methods that
reasonably estimate the expected collectibility of the bank’s loans and that are applied
consistently over time can be used. Acceptable methods include, but may not be limited to,
loss rate,
roll-rate, vintage, discounted cash flow, and probability of default/loss given default
methods. No specific method is required for estimating expected credit losses. Additionally, a
bank may utilize different methods for different groups of loans.
CREDIT LOSSES
12D. ACL
Bank Accounting Advisory Series
271
August 2018
Early adopters only
When measuring lifetime expected credit losses, the bank must consider available
information that is relevant to assessing the collectibility of its loans. This information may
include internal information, external information, or a combination
of both relating to past
events, including historical credit loss experience on loans with similar risk characteristics,
current conditions, and reasonable and supportable forecasts that affect the collectibility of
the loans over their remaining contractual terms.
Question 3
When should a loan be charged off?
Staff Response
A loan that meets the federal banking agencies’ loss classification definition should be charged
off in the period in which it is classified as loss. CECL did not affect the loss classification
definition, which states: “Assets classified loss are considered uncollectible and of such little
value that their continuance as bankable assets is not warranted. This classification does not
mean that the asset has absolutely no recovery or salvage value, but rather that it is not
practical or desirable to defer writing off this basically worthless asset
even though partial
recovery may be effected in the future.”
For consumer loans, the loss classification, and thus the timing of the charge-off, typically
follows established thresholds (i.e., a specific number of days past due). For commercial loans,
the loss classification and timing of the charge-off is likely the result of the bank obtaining
specific adverse information about a borrower.
Facts
A bank evaluates an individual commercial real estate loan for expected credit loss as
the loan does not share risk characteristics with other loans in the bank’s portfolio. The loan
was made during a recent boom period for the local real estate industry. The real estate market
has since declined and the borrower is experiencing financial difficulty. Management expects
that loan repayment will come substantially from the eventual sale of the collateral. An
appraisal indicates that the value of the property is 95 percent of the outstanding loan balance.
The properly performed appraisal is dated near the reporting date, the assumptions in the
appraisal remain
reasonable, and the appraisal complies with Interagency Appraisal and
Evaluation Guidelines.
Three real estate cycles have occurred in the last 25 years. In each cycle, local real estate
values fluctuated significantly. Based on these observed cycles, the bank forecasts that local
real estate will experience an additional decline in value of 5 percent between the reporting
date and the date the collateral is ultimately expected to be sold.
N
EW
CREDIT LOSSES
12D. ACL
Bank Accounting Advisory Series
272
August 2018
Early adopters only
Question 4
How should the bank determine the ACL on the loan?
Staff Response
Consistent with the call report instructions, the loan is collateral-dependent because the
borrower is experiencing financial difficulty and repayment of the loan will come substantially
from the eventual sale of the collateral.
To determine the ACL on a
collateral-dependent loan, the bank should use the collateral’s fair
value as of the reporting date, less estimated costs to sell, since the cash flows available to
repay the loan are expected to be reduced by these amounts. The bank should not adjust the
appraised value for expected future changes in the collateral’s fair value; rather, changes in the
fair value of the collateral should be recognized in the period in which the change occurs.
Question 5
When determining the ACL, is it appropriate to both include a loan in a pool of loans as well
as perform an individual assessment of expected credit losses?
Staff Response
No. Including a loan in a pool of loans and performing an individual assessment results in
recording an ACL twice for the same loan. If the loan shares similar risk characteristics with
other loans in
the portfolio, the ACL should be determined using a pool assessment, and no
individual assessment should be performed. If the loan does not share risk characteristics with
other loans in the portfolio, it should not be included in a pool assessment, and the ACL
should be determined using an individual assessment.
Facts
A bank removes a classified loan from a pool of pass-rated loans because
it determines
that the classified loan no longer shares risk characteristics with the pass-rated loans. The bank
estimates expected credit losses on classified loans on an individual basis or with a pool of
other classified loans that share similar risk characteristics. Ultimately, the classified loan is
charged off.
Question 6
Should the bank include the charge-off from the classified loan in the historical loss rate for
the pass-rated loan pool?
N
EW