The overarching purpose of the Financial Accounting Standards Board (FASB) financial statement disclosures is to provide investors with insights into the risks of each institution, to be read in conjunction with the financial statements and investment schedules provided. When the financial crisis occurred, there were many surprises for investors, specifically in the area of financial instrument credit risk. The Current Expected Credit Losses (CECL) standard (ASC 326), which will be effective January 1, 2020, for first-wave (calendar year) SEC filers, was designed to provide greater transparency and understanding of credit risk by incorporating estimated, forward-looking data when measuring lifetime Estimated Credit Losses (ECL) and requires enhanced financial statement disclosures.
The magnitude of change driven by the enhanced financial statement disclosures requirements under CECL is significant in terms of the need for additional data; changes to systems, policy and process; and expansion of management’s presentation and analysis that must be prepared by institutions.
It is expected that these changes will result in investors and other financial statement users having a better overall understanding of credit risk within loan and investment portfolios, as well as more transparency into an organization’s risk management practices, loss methodology and key modeling assumptions, and drivers of change in the resulting loss estimates for each financial reporting period. One of the key enhancements regarding CECL is a required articulation of information in the financial statement disclosures not only to allow investors to better understand management’s estimate of lifetime credit loss but also to enhance their own alternative estimates to better evaluate the magnitude of impact using different assumptions from those provided by management.
Analysis of Disclosure Impact
While some of the disclosure changes under CECL are significant and mandate new presentation, such as the amortized cost of financial assets by origination year (vintage), others require more qualitative changes explaining the inputs used to estimate credit losses and greater detail regarding off-balance sheet credit exposures. Many legacy disclosures were retained with minor adjustments. Other legacy disclosures, such as the impaired loans disclosures, will be superseded, since the concept of impairment no longer exists under CECL.
At a high level, the disclosure changes under CECL fall into three general categories:
- ECL estimate methodology and assumptions
- Quantitative information and metrics
- Policy and process explanations
Across these three broad categories, the required disclosures comprise a more prescriptive version of what is currently required in the financial statement footnotes and the Management Discussion and Analysis (MD&A) sections of periodic, public financial statement filings such as forms 10-K (annual) and 10-Q (quarterly)..
Financial Instruments Measured at Amortized Cost
Discussed in the new CECL guidance, financial instruments measured at amortized cost include loans, net investments in leases and held-to-maturity securities. The subtopic ASC 326-20-50 includes guidance on required reporting of credit risk and expected credit loss measurement, as well as determining the appropriate level of detail to support disclosures. Below is a comparison of key topics under CECL versus legacy GAAP.
- Description of credit quality indicator(s)
- Amortized cost basis by credit quality indicator
- Date or date range of last assessment of the credit quality indicator
Additionally, public business entities (PBE) are required to disclose the amortized cost basis by each credit quality indicator and by origination year for up to five (5) historical annual periods. For originations before the fifth annual period, entities may report at the aggregate level.
Note that as of November 9, 2018, the FASB signaled support for an amendment that will require financial institutions to disclose charge-offs and recoveries by vintage year. This information is aligned with the spirit of the original 2016 guidance (and examples provided therein) in that this information is viewed as critical for investor understanding of underlying credit risk management practices and credit trends.
- Beginning and ending amortized cost basis balance of nonaccrual assets
- Interest income recognized during the period on nonaccrual assets
- Amortized cost basis balance for loans 90-plus days past due that are not on nonaccrual status
- Amortized cost basis balance for assets that are nonaccrual where no allowance for credit losses has been booked as of the current reporting period
ASC 326-20-50 also requires disclosure of an entity’s significant accounting policies related to non-accrual, including:
- Nonaccrual policies, including the policies for discontinuing/resuming accrual of interest, recording payments received on nonaccrual assets
- Policy for determining past due or delinquency status
- Policy for recognizing write-offs within the allowance for credit losses
- How expected loss estimates are developed
- Accounting policies and allowance methodology, plus discussion of factors influencing management’s current estimate of ECL such as past event, current conditions, and notably, reasonable, and supportable forecasts about the future
- Risk characteristics relevant to each portfolio segment
- Changes in factors influencing management’s estimated ECL and reason for changes
- Changes to accounting policy and allowance methodology, including rationale and quantitative impact
- Reasons for significant changes in write-offs
- Discussion and rationale for the reversion method used for the period beyond the reasonable and supportable forecast period
- Amount of significant purchases or sale of financial assets
- Amount of significant sales of financial assets or reclassifications of loans held for sale
Additionally, under CECL — specifically, ASC 326-20-5-13 — financial institutions are required to provide a rollforward presentation of the allowance for credit losses by portfolio segment and major security type, including net investments in leases and HTM securities. For each presentation, the following items are required:
- Beginning balance of ECL
- Current period provision for ECL
- Initial allowance for credit losses recognized on financial assets accounted for as Purchase Credit Deteriorated (PCD) assets (if applicable)
- Write-offs charged against the ECL
Current GAAP and related guidance do not require a rollforward presentation of allowance for credit losses.
Available for Sale Securities
Discussed in ASC 326-30-50, available for sale (AFS) securities disclosure requirements remain generally the same as under current guidance. AFS debt securities disclosures should clarify for users the inherent credit risk, management’s estimate of credit losses and changes in credit losses. Following is a comparison of key topics under CECL versus legacy GAAP.
Prior to adoption of CECL, it is key for institutions to provide key stakeholders such as investors, the board, auditors and regulators with sufficient information to understand the change to the reserve estimate as well as the methodology and assumptions utilized to calculate the reserve estimate, and to ensure that the process and results can stand up to external audit scrutiny. By effectively discussing CECL implementation progress in the financial statement disclosures prior to implementation, institutions can enable stakeholder understanding of the prospective CECL financial statement impact, particularly understanding the impact of the methodology change to CECL from the incurred loss approach versus actual underlying changes in credit risk.
Post adoption, CECL disclosure templates and required data need to be created and in place to meet the January 1, 2020, CECL effective date for first-wave (calendar year) SEC filers. The increased CECL disclosures requirements also create data, system, process and policy demands on numerous functions and departments to provide the detailed disclosures related to ECL estimate methodology and assumptions, quantitative information and metrics, and policy.
An assessment of an institution’s existing credit loss-related financial statement footnote disclosures and MD&A analysis compared to the requirements of CECL is imperative to identify superseded as well as required changes to disclosures, or new disclosures. As part of this assessment, institutions will need to inventory data points necessary to satisfy the disclosure requirements, inclusive of the qualitative comments required by CECL.
Additionally, changes to data warehouses or other repositories may be required so that vintage data is available for presentation. In conjunction with data-mapping assessments, institutions should assess the sufficiency of their current-state internal controls, as well as revisions required to ensure the accuracy, integrity and completeness of their credit-related data. A close working relationship, including information exchanges at critical milestone dates with the institution’s external and internal auditors, is one of many keys to success.
How Protiviti Can Help
Protiviti’s CECL team brings together professionals with deep experience in financial services, loss reserving, modeling, internal audit, IT and implementation to help your organization meet CECL implementation timelines.
We provide support across the CECL implementation lifecycle and can help your organization:
- Source and utilize data/create reporting.
- Perform CECL readiness and pre-implementation gap assessments across functional areas.
- Provide professional project management (PMO) resources.
- Develop, validate and document CECL quantitative models.
- Design and document a qualitative-factor framework and methodology.
- Prepare GAAP-compliant financial statements footnotes and MD&A disclosures.
- Assist with external audit readiness and facilitate the auditor/client liaison function.
- Design and document SOX processes and controls.
- Perform CECL internal audits and create internal audit plans.