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Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending 1 JOIN. ENGAGE. LEAD. HOW TO PREPARE FOR CECL 7 Tips from the RMA Credit Risk Council 2016 Industry Insights

7 Tips to Help You Prepare for CECL

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Page 1: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

1

JOIN. ENGAGE. LEAD.

HOW TO PREPARE FOR CECL

7 Tips from the RMA Credit Risk Council

2016 Industry Insights

Page 2: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

2

JOIN. ENGAGE. LEAD.

Familiarize yourself with

CECL’s requirements.

LEARN ABOUT ITTip 1

Page 3: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

3

JOIN. ENGAGE. LEAD.

HOLD CECL MEETINGSTip 2

Discuss implementation

of CECL with the board

of directors, industry

peers, external auditors,

and supervisory

agencies.

Page 4: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

4

JOIN. ENGAGE. LEAD.

THE DATA GAP IS REALTip 3

Identify data needs

and changes.

Page 5: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

5

JOIN. ENGAGE. LEAD.

THE DATA GAP IS REAL (TIP 3 CONT.)

There are new rules regarding the need for:

Robust data collection methods

Q-factors

Capital adjustments

Page 6: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

6

JOIN. ENGAGE. LEAD.

THE LOOMING CHANGE TO CECL UNDERSCORES

A VERY REAL ISSUE (TIP 3 CONT.)

Many mid- and small-sized banks are not collecting or analyzing enough data.

This data gap hurts their:

Profitability potential

Regulatory compliance

stance

Overall risk management

efforts

Page 7: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

7

JOIN. ENGAGE. LEAD.

YOU’LL NEED MORE LOSS DATA (TIP 3 CONT.)

Banks preparing for the CECL

model are quickly realizing the depth

of the data gap.

Financial Accounting Standards Board (FASB)

says CECL will be effective in 2019.

Page 8: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

8

JOIN. ENGAGE. LEAD.

YOU’LL NEED MORE LOSS DATA (TIP 3 CONT.)

As FASB moves the industry from

a time-specific incurred loss

model for reserves to an over-the-

life-of-the-loan expected loss

model, you will need far more loss

data than you have likely been

collecting.

Page 9: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

9

JOIN. ENGAGE. LEAD.

YOU’LL NEED MORE LOSS DATA (TIP 3 CONT.)

In addition to the fields currently used to calculate

the Allowance for Loan and Lease Losses (ALLL),

CECL will require banks to capture:

Risk ratings

Durations BalancesCharge-offs and

recoveries

Segmenta-tions on individual

loans

Page 10: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

10

JOIN. ENGAGE. LEAD.

To bridge the data gap,

you need to change your

data collection practices.

Change

practices for:

• Closed

credit files.

• Open credit

files.

• Future credit

files.

BRIDGE THE GAPTip 4

Page 11: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

11

JOIN. ENGAGE. LEAD.

CHANGE YOUR DATA COLLECTION PRACTICES

FOR CLOSED CREDIT FILES (TIP 4 CONT.)

Ensure your core processor is

retaining closed credit files

for as far back as allows

you to recreate accurate, historic

averages for your bank’s

life-of-loan losses.

Page 12: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

12

JOIN. ENGAGE. LEAD.

CHANGE YOUR DATA COLLECTION PRACTICES

FOR CLOSED CREDIT FILES (TIP 4 CONT.)

Keep in mind that CECL

compliance requires that this

historic picture be both defensible

and documentable.

Page 13: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

13

JOIN. ENGAGE. LEAD.

CHANGE YOUR DATA COLLECTION PRACTICES

FOR OPEN CREDIT FILES (TIP 4 CONT.)

Cull through credit files currently

on the books and pull the

additional data fields that will be

required for CECL.

Page 14: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

14

JOIN. ENGAGE. LEAD.

CHANGE YOUR DATA COLLECTION PRACTICES

FOR OPEN CREDIT FILES (TIP 4 CONT.)

This work within your existing portfolio

will help your bank estimate the one-

time capital hit it can expect when

CECL goes into effect.

Page 15: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

15

JOIN. ENGAGE. LEAD.

CHANGE YOUR DATA COLLECTION PRACTICES

FOR FUTURE CREDIT FILES (TIP 4 CONT.)

Determine the most effective and

cost efficient way to gather CECL

life-of-loan data upon origination

going forward.

Page 16: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

16

JOIN. ENGAGE. LEAD.

CHANGE YOUR DATA COLLECTION PRACTICES

FOR FUTURE CREDIT FILES (TIP 4 CONT.)

This determination will require

both system and process

reviews.

Page 17: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

17

JOIN. ENGAGE. LEAD.

MORE DATA HAS ITS UPSIDE (TIP 4 CONT.)

More data equals better

decision making, which

leads to more successful

results.

Page 18: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

18

JOIN. ENGAGE. LEAD.

IDENTIFY TECHNOLOGY

NEEDS AND CHANGES

Today’s cloud-based analytics

tools make it more affordable

and feasible for banks of all

sizes to analyze critical data

across their various systems

and functions.

Tip 5

Page 19: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

19

JOIN. ENGAGE. LEAD.

Review existing risk management

practices and identify processes

that can be leveraged for CECL.

LEVERAGE PROCESSESTip 6

Page 20: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

20

JOIN. ENGAGE. LEAD.

PLAN YOUR IMPLEMENTATION

Determine how and

when to begin

collecting the

additional necessary

data.

Tip 7

Page 21: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

21

JOIN. ENGAGE. LEAD.

The Credit Risk Council supports

professionals who are responsible for

establishing, maintaining, or carrying

out credit risk management policies.

The council focuses on funded and

off-balance-sheet risk management,

including capital markets activity, and

other forms of credit intermediation

and risk mitigation.

ABOUT THE RMA

CREDIT RISK COUNCIL

Page 22: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

22

JOIN. ENGAGE. LEAD.

RMA's community bank members

(banks with assets under approximately $10B)

are eligible to join the service.

Find out more about the

RMA Community Bank CECL Service.

Not a member?

Become an Institutional member today.

ABOUT RMA’S COMMUNITY BANK

CECL SERVICE

Page 23: 7 Tips to Help You Prepare for CECL

Enterprise Risk · Credit Risk · Market Risk · Operational Risk · Regulatory Compliance · Securities Lending

23

JOIN. ENGAGE. LEAD.

SHARE THIS PRESENTATION

Visit http://www.rmahq.org for information on risk management

The Risk Management Association (RMA) is a member-driven

professional association whose sole purpose is to advance sound risk

principles in the financial services industry.

RMA helps its members use sound risk principles to improve institutional

performance and financial stability, and enhance the risk competency of

individuals through information, education, peer sharing, and networking.

Become a member today.