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CECL – Accounting for Acquired Loans
Non-PCI/PCD & PCI/PCD
Neekis Hammond, CPA
Advisory Services
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4
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.
Disclaimer
CPE Credit
5
1) Write down the 6-digit code
2) Look for an email from Sageworks this afternoon
3) Enter email address and 6-digit code
4) Complete course survey provided in email
CPE Code - Part 1
6
2018 CECL Transition Workshops
Locations:
» Atlanta, GA – March 14
» New York, NY – April 12
» Nashville, TN – June 14
» Los Angeles, CA – July 12
Agenda includes recommendations for a Practical CECL
Transition as well as hands-on case studies:
» Review CECL principles
» Data, segmentation, methodology, average life, forecasting
» Executing the practical CECL transition methodology
Practical CECL Case Studies and Learning
» Chicago, IL – August 9
» Washington, DC – October 11
» Austin, TX – November 8
Sageworks.com/cecl-workshops
Poll Question
I: Applicable Guidance & Updates
II: Transition Resource Group (TRG)
III: Illustrations
IV: Summary
9
Current GAAP
10
This Subtopic provides recognition, measurement, and
disclosure guidance regarding loans acquired with
evidence of deterioration of credit quality since
origination acquired by completion of a transfer for which
it is probable, at acquisition, that the investor will be
unable to collect all contractually required payments
receivable.
• Guidance
• TRG
• Illustration
• Summary
Current GAAP
11
Deterioration may be evidenced by such sources as Fair
Isaac Company (FICO) scores (an automated process
for all credit reports), downgrading, decline in collateral
value, or past due status.
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
12
Acquired individual financial assets (or acquired groups
of financial assets with similar risk characteristics) that,
as of the date of acquisition, have experienced a more-
than-insignificant deterioration in credit quality since
origination, as determined by an acquirer’s assessment.
See paragraph 326-20-55-5 for more information on the
meaning of similar risk characteristics for assets
measured on an amortized cost basis.
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
13
An entity shall record the allowance for credit losses for
purchased financial assets with credit deterioration in
accordance with paragraphs 326-20-30-2 through 30-10
and 326-20-30-12. An entity shall add the allowance for
credit losses at the date of acquisition to the purchase
price to determine the initial amortized cost basis for
purchased financial assets with credit deterioration…
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
14
An entity shall record the allowance for credit losses for
purchased financial assets with credit deterioration in
accordance with paragraphs 326-20-30-2 through 30-10
and 326-20-30-12. An entity shall add the allowance for
credit losses at the date of acquisition to the purchase
price to determine the initial amortized cost basis for
purchased financial assets with credit deterioration…
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
15
… Any noncredit discount or premium resulting from
acquiring a pool of purchased financial assets with credit
deterioration shall be allocated to each individual asset.
At the acquisition date, the initial allowance for credit
losses determined on a collective basis shall be
allocated to individual assets to appropriately allocate
any noncredit discount or premium.
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
16
… Any noncredit discount or premium resulting from
acquiring a pool of purchased financial assets with credit
deterioration shall be allocated to each individual asset.
At the acquisition date, the initial allowance for credit
losses determined on a collective basis shall be
allocated to individual assets to appropriately allocate
any noncredit discount or premium.
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
17
If an entity estimates expected credit losses using a
discounted cash flow method, the entity shall discount
expected credit losses at the rate that equates the
present value of the purchaser’s estimate of the asset’s
future cash flows with the purchase price of the asset…
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
18
… If an entity estimates expected credit losses using a
method other than a discounted cash flow method, the
entity shall estimate expected credit losses on the basis
of the unpaid principal balance (face value) of the
financial asset(s).
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
19
An entity shall account for purchased financial assets
that do not have a more-than-insignificant deterioration in
credit quality since origination in a manner consistent
with originated financial assets in accordance with
paragraphs 326-20-30-1 through 30-10 and 326-20-30-
12. An entity shall not apply the guidance in paragraphs
326-20-30-13 through 30-14 for purchased financial
assets that do not have a more-than-insignificant
deterioration in credit quality since origination.
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
20
An entity shall account for purchased financial assets
that do not have a more-than-insignificant deterioration in
credit quality since origination in a manner consistent
with originated financial assets in accordance with
paragraphs 326-20-30-1 through 30-10 and 326-20-30-
12. An entity shall not apply the guidance in paragraphs
326-20-30-13 through 30-14 for purchased financial
assets that do not have a more-than-insignificant
deterioration in credit quality since origination.
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
21
… For example, if an entity uses a loss-rate method, the
numerator would include the expected credit losses of
the amortized cost basis (that is, amounts that are not
expected to be collected in cash or other consideration,
or recognized in income). In addition, when an entity
expects to accrete a discount into interest income, the
discount should not offset the entity’s expectation of
credit losses…
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
22
This Subtopic does not address how a creditor shall
recognize interest income. See paragraphs 310-10-35-
53A through 35-53C for guidance on recognition of
interest income on purchased financial assets with credit
deterioration.
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
23
When recognizing interest income on purchased
financial assets with credit deterioration within the scope
of Topic 326, an entity shall not recognize as interest
income the discount embedded in the purchase price
that is attributable to the acquirer’s assessment of
expected credit losses at the date of acquisition.
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
24
… The entity shall accrete or amortize as interest income
the non-credit-related discount or premium of a
purchased financial asset with credit deterioration in
accordance with existing applicable guidance in Section
310-20-35 or 325-40-35.
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
25
For instruments within the scope of this Subtopic, this
Section provides the following disclosure guidance on
credit risk and the measurement of expected credit
losses:
a. Credit quality information
b. Allowance for credit losses
c. Past-due status
d. Nonaccrual status
e. Purchased financial assets with credit deterioration
f. Collateral-dependent financial assets
g. Off-balance-sheet credit exposures
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
26
When disclosing credit quality indicators of financing
receivables and net investment in leases (except for
reinsurance receivables and funded or unfunded
amounts of line-of-credit arrangements, such as credit
cards), an entity shall present the amortized cost basis
within each credit quality indicator by year of origination
(that is, vintage year)…
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
27
… For purchased financing receivables and net
investment in leases an entity shall use the initial date of
issuance to determine the year of origination, not the
date of acquisition. For origination years before the fifth
annual period, an entity may present the amortized cost
basis of financing receivables and net investments in
leases in the aggregate. For interim period disclosures,
the current year-to-date originations in the current
reporting
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
28
Furthermore, to enable a financial statement user to
understand the activity in the allowance for credit losses
for each period, an entity shall separately provide by
portfolio segment and major security type the
quantitative disclosures of the activity in the allowance
for credit losses for financial assets within the scope of
this Subtopic, including all of the following:…
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
29
…
a. The beginning balance in the allowance for credit losses
b. Current-period provision for expected credit losses
c. The initial allowance for credit losses recognized on financial assets accounted for
as purchased financial assets with credit deterioration (including beneficial
interests that meet the criteria in paragraph 325-40-30-1A), if applicable
d. Writeoffs charged against the allowance
e. Recoveries of amounts previously written off, if applicable
• Guidance
• TRG
• Illustration
• Summary
ASU 2016-13 (Topic 326)
30
To the extent an entity acquired purchased financial
assets with credit deterioration during the current
reporting period, an entity shall provide a reconciliation of
the difference between the purchase price of the financial
assets and the par value of the assets, including:
a. The purchase price
b. The allowance for credit losses at the acquisition date based on the acquirer’s
assessment
c. The discount (or premium) attributable to other factors
d. The par value.
• Guidance
• TRG
• Illustration
• Summary
CPE Code - Part 2
31
I: Applicable Guidance & Updates
II: Transition Resource Group (TRG)
III: Illustrations
IV: Summary
32
Transition Resource Group
33
TRG Memos are “prepared for discussion at a public meeting of the Transition
Resource Group for Credit Losses. It does not purport to represent the views of any
individual members of the Board or staff. Comments on the application of generally
accepted accounting principles (GAAP) do not purport to set out acceptable or
unacceptable application of GAAP. Stakeholders are strongly encouraged to listen to
feedback about this staff paper from TRG members and Board members during the
TRG meeting and to read the meeting summary, which will be prepared by the staff
after the meeting.”
• Guidance
• TRG
• Illustration
• Summary
Transition Resource Group
34
Stakeholder Feedback (summarized):
• Stakeholder questions focus on whether the election to maintain pools accounted
for under Subtopic 310-30 at adoption provides an exemption from the requirement
to collectively evaluate assets with similar risk characteristics in paragraph 326-20-
30-2 at adoption only or both at adoption and on an ongoing basis.
• If the election to maintain pools applies both at adoption and on an ongoing basis,
stakeholders have also asked for clarity on whether the pool unit of account would
continue to apply as it does under Subtopic 310-30, which means a pool unit of
account may apply for purposes of writeoff determination or TDR identification in
addition to credit loss measurement.
• Guidance
• TRG
• Illustration
• Summary
Transition Resource Group
35
Staff Views (summarized):
• Maintain the Subtopic 310-30 pool at the time of adoption only. Under this view,
after adoption entities may only continue to maintain the pools for credit loss
measurement purposes to the extent the risk characteristics of the underlying
assets are similar in accordance with paragraph 326-20-30-2
• Maintain the Subtopic 310-30 pool both at the time of adoption and on an ongoing
basis. Under this view, an entity would maintain the integrity of the pool consistent
with the guidance in Subtopic 310-30 for all applicable areas of accounting which
may include credit loss measurement, interest income recognition, writeoff
determination, and TDR identification. Regarding interest income recognition, the
prospective transition approach for PCD assets would be applied at a pool level
which would freeze the effective interest rate of the pool.
• Guidance
• TRG
• Illustration
• Summary
Transition Resource Group
36
Staff Recommendation (summarized):
• The staff does not have a recommendation for this issue. The staff notes that
based on the guidance as written, View A appears to be more consistent with the
Board’s original intent. However, depending on feedback from the TRG members
about the level of incremental cost relief and whether the drawbacks would be
manageable, the staff notes that it may be appropriate for the Board to consider
clarifying the guidance to allow View B
• The staff adds that based on the varying degrees of sophistication among entities
that apply Subtopic 310-30 accounting, where systems may range from
spreadsheets to more complex models, the balance of cost relief and other
implications may vary significantly by entity. Therefore, a discussion among the
TRG members on the question in this memo will be helpful for the Board to
determine what, if any, action may be needed to address the issue
• Guidance
• TRG
• Illustration
• Summary
I: Applicable Guidance & Updates
II: Transition Resource Group (TRG)
III: Illustrations
IV: Summary
37
38
• Guidance
• TRG
• Illustration
• Summary
Valuation Item Amount
UPB (Face) 100,000
Fair Value 99,000
Valuation Adj. (Day 1) (1000)
Non-PCI/PCD
Day 1/Pre-Transition Date
Positions Amount
UPB (Face) 100,000
ALLL (Notional) (900)
Valuation Adj. (Rem.) (1,000)
ALLL (Recorded) 0
Day 2/Pre-Transition Date
39
• Guidance
• TRG
• Illustration
• Summary
Valuation Item Amount
UPB (Face) 100,000
Fair Value 99,000
Valuation Adj. (Day 1) (1000)
Day 1/Pre-Transition Date
Positions Amount
UPB (Face) 100,000
ALLL (Notional) (900)
Valuation Adj. (Rem.) (1,000)
ALLL (Recorded) 0
Day 2/Pre-Transition Date
Positions Amount
UPB (Face) 100,000
Coupon 5%
EIR (Prepayment) 5.69%
PD/LGD 2.5%/15%
NPV 98,343
ALLL (Recorded) (657)/.66%
Day 2/Post-Transition Date
Non-PCI/PCD
Month Balance Cash Flow
0 100,000 (99,000) << Basis
1 96,869 3,341
2 93,768 3,303
… … …
40
• Guidance
• TRG
• Illustration
• Summary
Valuation Item Amount
UPB (Face) 100,000
Fair Value 99,000
Valuation Adj. (Day 1) (1000)
Day 1/Pre-Transition Date
Positions Amount
UPB (Face) 100,000
ALLL (Notional) (900)
Valuation Adj. (Rem.) (1,000)
ALLL (Recorded) 0
Day 2/Pre-Transition Date
Positions Amount
UPB (Face) 100,000
Coupon 5%
EIR (Prepayment) 5.69%
PD/LGD 2.5%/15%
NPV 98,343
ALLL (Recorded) (657)/.66%
Day 2/Post-Transition Date
Non-PCI/PCD
Month Balance Cash Flow
0 100,000 (99,000) << Basis
1 96,869 3,341
2 93,768 3,303
… … …
41
• Guidance
• TRG
• Illustration
• Summary
Valuation Item Amount
UPB (Face) 100,000
Fair Value 99,000
Valuation Adj. (Day 1) (1000)
Day 1/Pre-Transition Date
Positions Amount
UPB (Face) 100,000
ALLL (Notional) (900)
Valuation Adj. (Rem.) (1,000)
ALLL (Recorded) 0
Day 2/Pre-Transition Date
Positions Amount
UPB (Face) 100,000
Coupon 5%
EIR (Prepayment) 5.69%
PD/LGD 2.5%/15%
NPV 98,343
ALLL (Recorded) (657)/.66%
Day 2/Post-Transition Date
Non-PCI/PCD
Month Balance Cash Flow
0 100,000 (99,000) << Basis
1 96,869 3,341
2 93,768 3,303
… … …
42
• Guidance
• TRG
• Illustration
• Summary
Valuation Item Amount
UPB (Face) 100,000
Fair Value 99,000
Valuation Adj. (Day 1) (1000)
PCI/PCD
Day 1/Pre-Transition Date
Positions Amount
UPB (Face) 100,000
Impairment 0
Valuation Adj. (Rem.) (1,000)
Accretable Yield 7,952
Effective Yield 5.22%
Day 2/Pre-Transition Date
43
• Guidance
• TRG
• Illustration
• Summary
Valuation Item Amount
UPB (Face) 100,000
Fair Value 99,000
Valuation Adj. (Day 1) (1000)
PCI/PCD
Day 1/Pre-Transition Date
Positions Amount
UPB (Face) 100,000
Impairment 0
Valuation Adj. (Rem.) (1,000)
Accretable Yield 7,952
Effective Yield 5.22%
Day 2/Pre-Transition Date
Positions Amount
UPB (Face) 100,000
Fair Value 99,000
Valuation Adj. (Day 1) (1000)
Day 1/Post-Transition Date
44
• Guidance
• TRG
• Illustration
• Summary
Valuation Item Amount
UPB (Face) 100,000
Fair Value 99,000
Valuation Adj. (Day 1) (1000)
PCI/PCD
Day 1/Pre-Transition Date
Positions Amount
UPB (Face) 100,000
Impairment 0
Valuation Adj. (Rem.) (1,000)
Accretable Yield 7,952
Effective Yield 5.22%
Day 2/Pre-Transition Date
Positions Amount
UPB (Face) 100,000
Fair Value 99,000
Valuation Adj. (Day 1) (1000)
Day 1/Post-Transition Date
Year Balance Credit Loss Cash Flow
0 100,000 567 (PV) (99,000) << Basis
1 96,869 31 3,341
2 93,768 30 3,303
… … … …
Positions Amount
UPB (Face) 100,000
EIR (Prepayment) 5.69%
Non-Credit Discount (433)/.43%
Credit Discount/ALLL (567)/.57%
Day 2/Post-Transition Date
45
• Guidance
• TRG
• Illustration
• Summary
Valuation Item Amount
UPB (Face) 100,000
Fair Value 99,000
Valuation Adj. (Day 1) (1000)
PCI/PCD
Day 1/Pre-Transition Date
Positions Amount
UPB (Face) 100,000
Impairment 0
Valuation Adj. (Rem.) (1,000)
Accretable Yield 7,952
Effective Yield 5.22%
Day 2/Pre-Transition Date
Positions Amount
UPB (Face) 100,000
Fair Value 99,000
Valuation Adj. (Day 1) (1000)
Day 1/Post-Transition Date
Year Balance Credit Loss Cash Flow
0 100,000 (99,567) << Basis
1 96,869 31 3,341
2 93,768 30 3,303
… … … …
Positions Amount
UPB (Face) 100,000
EIR (Prepayment) 5.69%
Non-Credit Discount (433)/.43%
Credit Discount/ALLL (567)/.57%
NPV 98,893
ALLL (674)/.67%
Day 2/Post-Transition Date
46
• Guidance
• TRG
• Illustration
• Summary
Valuation Item Amount
UPB (Face) 100,000
Fair Value 99,000
Valuation Adj. (Day 1) (1000)
PCI/PCD
Day 1/Pre-Transition Date
Positions Amount
UPB (Face) 100,000
Impairment 0
Valuation Adj. (Rem.) (1,000)
Accretable Yield 7,952
Effective Yield 5.22%
Day 2/Pre-Transition Date
Positions Amount
UPB (Face) 100,000
Fair Value 99,000
Valuation Adj. (Day 1) (1000)
Day 1/Post-Transition Date
Year Balance Credit Loss Cash Flow
0 100,000 (99,567) << Basis
1 96,869 31 3,341
2 93,768 30 3,303
… … … …
Positions Amount
UPB (Face) 100,000
EIR (Prepayment) 5.69%
Non-Credit Discount (433)/.43%
Credit Discount/ALLL (567)/.57%
NPV 98,893
ALLL (674)/.67%
Day 2/Post-Transition Date
47
• Guidance
• TRG
• Illustration – ASU 2016-13 Examples
• Summary
PCI/PCD
48
• Guidance
• TRG
• Illustration
• Summary
Day 2 - ALLL, Yield, and Accretion
IRR/Yield 15.46%
Year Balance Cash Flow
0 2,176,204 (1,918,559)
1 1,119,794 1,186,982
2 0 1,186,982
Valuation Item Amount
UPB (Face) 2,176,204
Fair Value 1,918,559
Valuation Adj. (Day 1) 257,645
Balance ALLL Discount Basis
2,176,204 (217,620) (257,645) 1,918,559
Year Discount Accretion Discount
1 (257,645) 165,941 (91,704)
2 (91,704) 91,704 0
Non-PCI/PCD
Day 1
49
• Guidance
• TRG
• Illustration
• Summary
Day 2 - ALLL, Yield, and Accretion
Valuation Item Amount
UPB (Face) 2,176,204
Fair Value 1,918,559
Valuation Adj. (Day 1) 257,645
PCI/PCD – Loss Rate
Day 1
IRR/Yield 7.33%
ALLL 2,176,204 10% 217,620
Year Discount Accretion Discount
1 (40,025) 26,103 (13,922)
2 (13,922) 13,922 0
Year Balance Cash Flow
0 2,176,204 (2,136,179)
1 1,119,794 1,186,982
2 0 1,186,982
50
• Guidance
• TRG
• Illustration
• Summary
Day 2 - ALLL, Yield, and Accretion
Valuation Item Amount
UPB (Face) 2,176,204
Fair Value 1,918,559
Valuation Adj. (Day 1) 257,645
PCI/PCD – Discounted Cash Flow
Day 1
IRR/Yield 8.46%
Balance ALLL Discount Basis
2,176,204 (185,012) (72,633) 2,103,571
Year Discount Accretion Discount
1 (72,633) 47,285 (25,348)
2 (25,348) 25,348 0
Year Balance Cash Flow Loss
0 2,176,204 (1,918,559) 0
1 1,119,794 1,186,982 0
2 217,620 969,362 217,620
I: Applicable Guidance & Updates
II: Transition Resource Group (TRG)
III: Illustrations
IV: Summary
51
52
• Guidance
• TRG
• Illustration
• Summary
Summary
• Non-PCD: Entire discount is part of the amortized cost
basis and may not be reclassified to ALLL
• PCI: May not re-evaluate “purchased impaired” status
at transition
• PCI: TRG working through pooling considerations
• PCD: Credit component of remaining discount
reclassified to ALLL
• PCD: Say goodbye to re-estimations, impairment, and
rigorous accretion calculations
CPE Code - Part 3
53
Poll Question
2018 CECL Transition Workshops
Locations:
» Atlanta, GA – March 14
» New York, NY – April 12
» Nashville, TN – June 14
» Los Angeles, CA – July 12
Agenda includes recommendations for a Practical CECL
Transition as well as hands-on case studies:
» Review CECL principles
» Data, segmentation, methodology, average life, forecasting
» Executing the practical CECL transition methodology
Practical CECL Case Studies and Learning
» Chicago, IL – August 9
» Washington, DC – October 11
» Austin, TX – November 8
Sageworks.com/cecl-workshops
Q&A

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CECL - Accounting for Acquired Loans

  • 1. Download the presentation PDFs are available to download through the Handouts tab The easiest way to listen is through your computer’s speakers or headphones Ensure your device speakers are on, or calling in is an option. Submit your questions Have questions for the presenter? Submit them using the Questions box. For Upcoming and Archived sessions, visit www.sageworks.com Sageworks ALLL & CECL Forum for Bankers Commercial Credit Risk Professionals @sageworks Before the Webinar More Resources Connect With Us
  • 2. 2 CECL – Accounting for Acquired Loans Non-PCI/PCD & PCI/PCD Neekis Hammond, CPA Advisory Services
  • 3. Download the presentation PDFs are available to download through the Handouts tab The easiest way to listen is through your computer’s speakers or headphones Ensure your device speakers are on, or calling in is an option. Submit your questions Have questions for the presenter? Submit them using the Questions box. For Upcoming and Archived sessions, visit www.sageworks.com Sageworks ALLL & CECL Forum for Bankers Commercial Credit Risk Professionals @sageworks Making the Most of the Session More Resources Connect With Us
  • 4. 4 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. Disclaimer
  • 5. CPE Credit 5 1) Write down the 6-digit code 2) Look for an email from Sageworks this afternoon 3) Enter email address and 6-digit code 4) Complete course survey provided in email
  • 6. CPE Code - Part 1 6
  • 7. 2018 CECL Transition Workshops Locations: » Atlanta, GA – March 14 » New York, NY – April 12 » Nashville, TN – June 14 » Los Angeles, CA – July 12 Agenda includes recommendations for a Practical CECL Transition as well as hands-on case studies: » Review CECL principles » Data, segmentation, methodology, average life, forecasting » Executing the practical CECL transition methodology Practical CECL Case Studies and Learning » Chicago, IL – August 9 » Washington, DC – October 11 » Austin, TX – November 8 Sageworks.com/cecl-workshops
  • 9. I: Applicable Guidance & Updates II: Transition Resource Group (TRG) III: Illustrations IV: Summary 9
  • 10. Current GAAP 10 This Subtopic provides recognition, measurement, and disclosure guidance regarding loans acquired with evidence of deterioration of credit quality since origination acquired by completion of a transfer for which it is probable, at acquisition, that the investor will be unable to collect all contractually required payments receivable. • Guidance • TRG • Illustration • Summary
  • 11. Current GAAP 11 Deterioration may be evidenced by such sources as Fair Isaac Company (FICO) scores (an automated process for all credit reports), downgrading, decline in collateral value, or past due status. • Guidance • TRG • Illustration • Summary
  • 12. ASU 2016-13 (Topic 326) 12 Acquired individual financial assets (or acquired groups of financial assets with similar risk characteristics) that, as of the date of acquisition, have experienced a more- than-insignificant deterioration in credit quality since origination, as determined by an acquirer’s assessment. See paragraph 326-20-55-5 for more information on the meaning of similar risk characteristics for assets measured on an amortized cost basis. • Guidance • TRG • Illustration • Summary
  • 13. ASU 2016-13 (Topic 326) 13 An entity shall record the allowance for credit losses for purchased financial assets with credit deterioration in accordance with paragraphs 326-20-30-2 through 30-10 and 326-20-30-12. An entity shall add the allowance for credit losses at the date of acquisition to the purchase price to determine the initial amortized cost basis for purchased financial assets with credit deterioration… • Guidance • TRG • Illustration • Summary
  • 14. ASU 2016-13 (Topic 326) 14 An entity shall record the allowance for credit losses for purchased financial assets with credit deterioration in accordance with paragraphs 326-20-30-2 through 30-10 and 326-20-30-12. An entity shall add the allowance for credit losses at the date of acquisition to the purchase price to determine the initial amortized cost basis for purchased financial assets with credit deterioration… • Guidance • TRG • Illustration • Summary
  • 15. ASU 2016-13 (Topic 326) 15 … Any noncredit discount or premium resulting from acquiring a pool of purchased financial assets with credit deterioration shall be allocated to each individual asset. At the acquisition date, the initial allowance for credit losses determined on a collective basis shall be allocated to individual assets to appropriately allocate any noncredit discount or premium. • Guidance • TRG • Illustration • Summary
  • 16. ASU 2016-13 (Topic 326) 16 … Any noncredit discount or premium resulting from acquiring a pool of purchased financial assets with credit deterioration shall be allocated to each individual asset. At the acquisition date, the initial allowance for credit losses determined on a collective basis shall be allocated to individual assets to appropriately allocate any noncredit discount or premium. • Guidance • TRG • Illustration • Summary
  • 17. ASU 2016-13 (Topic 326) 17 If an entity estimates expected credit losses using a discounted cash flow method, the entity shall discount expected credit losses at the rate that equates the present value of the purchaser’s estimate of the asset’s future cash flows with the purchase price of the asset… • Guidance • TRG • Illustration • Summary
  • 18. ASU 2016-13 (Topic 326) 18 … If an entity estimates expected credit losses using a method other than a discounted cash flow method, the entity shall estimate expected credit losses on the basis of the unpaid principal balance (face value) of the financial asset(s). • Guidance • TRG • Illustration • Summary
  • 19. ASU 2016-13 (Topic 326) 19 An entity shall account for purchased financial assets that do not have a more-than-insignificant deterioration in credit quality since origination in a manner consistent with originated financial assets in accordance with paragraphs 326-20-30-1 through 30-10 and 326-20-30- 12. An entity shall not apply the guidance in paragraphs 326-20-30-13 through 30-14 for purchased financial assets that do not have a more-than-insignificant deterioration in credit quality since origination. • Guidance • TRG • Illustration • Summary
  • 20. ASU 2016-13 (Topic 326) 20 An entity shall account for purchased financial assets that do not have a more-than-insignificant deterioration in credit quality since origination in a manner consistent with originated financial assets in accordance with paragraphs 326-20-30-1 through 30-10 and 326-20-30- 12. An entity shall not apply the guidance in paragraphs 326-20-30-13 through 30-14 for purchased financial assets that do not have a more-than-insignificant deterioration in credit quality since origination. • Guidance • TRG • Illustration • Summary
  • 21. ASU 2016-13 (Topic 326) 21 … For example, if an entity uses a loss-rate method, the numerator would include the expected credit losses of the amortized cost basis (that is, amounts that are not expected to be collected in cash or other consideration, or recognized in income). In addition, when an entity expects to accrete a discount into interest income, the discount should not offset the entity’s expectation of credit losses… • Guidance • TRG • Illustration • Summary
  • 22. ASU 2016-13 (Topic 326) 22 This Subtopic does not address how a creditor shall recognize interest income. See paragraphs 310-10-35- 53A through 35-53C for guidance on recognition of interest income on purchased financial assets with credit deterioration. • Guidance • TRG • Illustration • Summary
  • 23. ASU 2016-13 (Topic 326) 23 When recognizing interest income on purchased financial assets with credit deterioration within the scope of Topic 326, an entity shall not recognize as interest income the discount embedded in the purchase price that is attributable to the acquirer’s assessment of expected credit losses at the date of acquisition. • Guidance • TRG • Illustration • Summary
  • 24. ASU 2016-13 (Topic 326) 24 … The entity shall accrete or amortize as interest income the non-credit-related discount or premium of a purchased financial asset with credit deterioration in accordance with existing applicable guidance in Section 310-20-35 or 325-40-35. • Guidance • TRG • Illustration • Summary
  • 25. ASU 2016-13 (Topic 326) 25 For instruments within the scope of this Subtopic, this Section provides the following disclosure guidance on credit risk and the measurement of expected credit losses: a. Credit quality information b. Allowance for credit losses c. Past-due status d. Nonaccrual status e. Purchased financial assets with credit deterioration f. Collateral-dependent financial assets g. Off-balance-sheet credit exposures • Guidance • TRG • Illustration • Summary
  • 26. ASU 2016-13 (Topic 326) 26 When disclosing credit quality indicators of financing receivables and net investment in leases (except for reinsurance receivables and funded or unfunded amounts of line-of-credit arrangements, such as credit cards), an entity shall present the amortized cost basis within each credit quality indicator by year of origination (that is, vintage year)… • Guidance • TRG • Illustration • Summary
  • 27. ASU 2016-13 (Topic 326) 27 … For purchased financing receivables and net investment in leases an entity shall use the initial date of issuance to determine the year of origination, not the date of acquisition. For origination years before the fifth annual period, an entity may present the amortized cost basis of financing receivables and net investments in leases in the aggregate. For interim period disclosures, the current year-to-date originations in the current reporting • Guidance • TRG • Illustration • Summary
  • 28. ASU 2016-13 (Topic 326) 28 Furthermore, to enable a financial statement user to understand the activity in the allowance for credit losses for each period, an entity shall separately provide by portfolio segment and major security type the quantitative disclosures of the activity in the allowance for credit losses for financial assets within the scope of this Subtopic, including all of the following:… • Guidance • TRG • Illustration • Summary
  • 29. ASU 2016-13 (Topic 326) 29 … a. The beginning balance in the allowance for credit losses b. Current-period provision for expected credit losses c. The initial allowance for credit losses recognized on financial assets accounted for as purchased financial assets with credit deterioration (including beneficial interests that meet the criteria in paragraph 325-40-30-1A), if applicable d. Writeoffs charged against the allowance e. Recoveries of amounts previously written off, if applicable • Guidance • TRG • Illustration • Summary
  • 30. ASU 2016-13 (Topic 326) 30 To the extent an entity acquired purchased financial assets with credit deterioration during the current reporting period, an entity shall provide a reconciliation of the difference between the purchase price of the financial assets and the par value of the assets, including: a. The purchase price b. The allowance for credit losses at the acquisition date based on the acquirer’s assessment c. The discount (or premium) attributable to other factors d. The par value. • Guidance • TRG • Illustration • Summary
  • 31. CPE Code - Part 2 31
  • 32. I: Applicable Guidance & Updates II: Transition Resource Group (TRG) III: Illustrations IV: Summary 32
  • 33. Transition Resource Group 33 TRG Memos are “prepared for discussion at a public meeting of the Transition Resource Group for Credit Losses. It does not purport to represent the views of any individual members of the Board or staff. Comments on the application of generally accepted accounting principles (GAAP) do not purport to set out acceptable or unacceptable application of GAAP. Stakeholders are strongly encouraged to listen to feedback about this staff paper from TRG members and Board members during the TRG meeting and to read the meeting summary, which will be prepared by the staff after the meeting.” • Guidance • TRG • Illustration • Summary
  • 34. Transition Resource Group 34 Stakeholder Feedback (summarized): • Stakeholder questions focus on whether the election to maintain pools accounted for under Subtopic 310-30 at adoption provides an exemption from the requirement to collectively evaluate assets with similar risk characteristics in paragraph 326-20- 30-2 at adoption only or both at adoption and on an ongoing basis. • If the election to maintain pools applies both at adoption and on an ongoing basis, stakeholders have also asked for clarity on whether the pool unit of account would continue to apply as it does under Subtopic 310-30, which means a pool unit of account may apply for purposes of writeoff determination or TDR identification in addition to credit loss measurement. • Guidance • TRG • Illustration • Summary
  • 35. Transition Resource Group 35 Staff Views (summarized): • Maintain the Subtopic 310-30 pool at the time of adoption only. Under this view, after adoption entities may only continue to maintain the pools for credit loss measurement purposes to the extent the risk characteristics of the underlying assets are similar in accordance with paragraph 326-20-30-2 • Maintain the Subtopic 310-30 pool both at the time of adoption and on an ongoing basis. Under this view, an entity would maintain the integrity of the pool consistent with the guidance in Subtopic 310-30 for all applicable areas of accounting which may include credit loss measurement, interest income recognition, writeoff determination, and TDR identification. Regarding interest income recognition, the prospective transition approach for PCD assets would be applied at a pool level which would freeze the effective interest rate of the pool. • Guidance • TRG • Illustration • Summary
  • 36. Transition Resource Group 36 Staff Recommendation (summarized): • The staff does not have a recommendation for this issue. The staff notes that based on the guidance as written, View A appears to be more consistent with the Board’s original intent. However, depending on feedback from the TRG members about the level of incremental cost relief and whether the drawbacks would be manageable, the staff notes that it may be appropriate for the Board to consider clarifying the guidance to allow View B • The staff adds that based on the varying degrees of sophistication among entities that apply Subtopic 310-30 accounting, where systems may range from spreadsheets to more complex models, the balance of cost relief and other implications may vary significantly by entity. Therefore, a discussion among the TRG members on the question in this memo will be helpful for the Board to determine what, if any, action may be needed to address the issue • Guidance • TRG • Illustration • Summary
  • 37. I: Applicable Guidance & Updates II: Transition Resource Group (TRG) III: Illustrations IV: Summary 37
  • 38. 38 • Guidance • TRG • Illustration • Summary Valuation Item Amount UPB (Face) 100,000 Fair Value 99,000 Valuation Adj. (Day 1) (1000) Non-PCI/PCD Day 1/Pre-Transition Date Positions Amount UPB (Face) 100,000 ALLL (Notional) (900) Valuation Adj. (Rem.) (1,000) ALLL (Recorded) 0 Day 2/Pre-Transition Date
  • 39. 39 • Guidance • TRG • Illustration • Summary Valuation Item Amount UPB (Face) 100,000 Fair Value 99,000 Valuation Adj. (Day 1) (1000) Day 1/Pre-Transition Date Positions Amount UPB (Face) 100,000 ALLL (Notional) (900) Valuation Adj. (Rem.) (1,000) ALLL (Recorded) 0 Day 2/Pre-Transition Date Positions Amount UPB (Face) 100,000 Coupon 5% EIR (Prepayment) 5.69% PD/LGD 2.5%/15% NPV 98,343 ALLL (Recorded) (657)/.66% Day 2/Post-Transition Date Non-PCI/PCD Month Balance Cash Flow 0 100,000 (99,000) << Basis 1 96,869 3,341 2 93,768 3,303 … … …
  • 40. 40 • Guidance • TRG • Illustration • Summary Valuation Item Amount UPB (Face) 100,000 Fair Value 99,000 Valuation Adj. (Day 1) (1000) Day 1/Pre-Transition Date Positions Amount UPB (Face) 100,000 ALLL (Notional) (900) Valuation Adj. (Rem.) (1,000) ALLL (Recorded) 0 Day 2/Pre-Transition Date Positions Amount UPB (Face) 100,000 Coupon 5% EIR (Prepayment) 5.69% PD/LGD 2.5%/15% NPV 98,343 ALLL (Recorded) (657)/.66% Day 2/Post-Transition Date Non-PCI/PCD Month Balance Cash Flow 0 100,000 (99,000) << Basis 1 96,869 3,341 2 93,768 3,303 … … …
  • 41. 41 • Guidance • TRG • Illustration • Summary Valuation Item Amount UPB (Face) 100,000 Fair Value 99,000 Valuation Adj. (Day 1) (1000) Day 1/Pre-Transition Date Positions Amount UPB (Face) 100,000 ALLL (Notional) (900) Valuation Adj. (Rem.) (1,000) ALLL (Recorded) 0 Day 2/Pre-Transition Date Positions Amount UPB (Face) 100,000 Coupon 5% EIR (Prepayment) 5.69% PD/LGD 2.5%/15% NPV 98,343 ALLL (Recorded) (657)/.66% Day 2/Post-Transition Date Non-PCI/PCD Month Balance Cash Flow 0 100,000 (99,000) << Basis 1 96,869 3,341 2 93,768 3,303 … … …
  • 42. 42 • Guidance • TRG • Illustration • Summary Valuation Item Amount UPB (Face) 100,000 Fair Value 99,000 Valuation Adj. (Day 1) (1000) PCI/PCD Day 1/Pre-Transition Date Positions Amount UPB (Face) 100,000 Impairment 0 Valuation Adj. (Rem.) (1,000) Accretable Yield 7,952 Effective Yield 5.22% Day 2/Pre-Transition Date
  • 43. 43 • Guidance • TRG • Illustration • Summary Valuation Item Amount UPB (Face) 100,000 Fair Value 99,000 Valuation Adj. (Day 1) (1000) PCI/PCD Day 1/Pre-Transition Date Positions Amount UPB (Face) 100,000 Impairment 0 Valuation Adj. (Rem.) (1,000) Accretable Yield 7,952 Effective Yield 5.22% Day 2/Pre-Transition Date Positions Amount UPB (Face) 100,000 Fair Value 99,000 Valuation Adj. (Day 1) (1000) Day 1/Post-Transition Date
  • 44. 44 • Guidance • TRG • Illustration • Summary Valuation Item Amount UPB (Face) 100,000 Fair Value 99,000 Valuation Adj. (Day 1) (1000) PCI/PCD Day 1/Pre-Transition Date Positions Amount UPB (Face) 100,000 Impairment 0 Valuation Adj. (Rem.) (1,000) Accretable Yield 7,952 Effective Yield 5.22% Day 2/Pre-Transition Date Positions Amount UPB (Face) 100,000 Fair Value 99,000 Valuation Adj. (Day 1) (1000) Day 1/Post-Transition Date Year Balance Credit Loss Cash Flow 0 100,000 567 (PV) (99,000) << Basis 1 96,869 31 3,341 2 93,768 30 3,303 … … … … Positions Amount UPB (Face) 100,000 EIR (Prepayment) 5.69% Non-Credit Discount (433)/.43% Credit Discount/ALLL (567)/.57% Day 2/Post-Transition Date
  • 45. 45 • Guidance • TRG • Illustration • Summary Valuation Item Amount UPB (Face) 100,000 Fair Value 99,000 Valuation Adj. (Day 1) (1000) PCI/PCD Day 1/Pre-Transition Date Positions Amount UPB (Face) 100,000 Impairment 0 Valuation Adj. (Rem.) (1,000) Accretable Yield 7,952 Effective Yield 5.22% Day 2/Pre-Transition Date Positions Amount UPB (Face) 100,000 Fair Value 99,000 Valuation Adj. (Day 1) (1000) Day 1/Post-Transition Date Year Balance Credit Loss Cash Flow 0 100,000 (99,567) << Basis 1 96,869 31 3,341 2 93,768 30 3,303 … … … … Positions Amount UPB (Face) 100,000 EIR (Prepayment) 5.69% Non-Credit Discount (433)/.43% Credit Discount/ALLL (567)/.57% NPV 98,893 ALLL (674)/.67% Day 2/Post-Transition Date
  • 46. 46 • Guidance • TRG • Illustration • Summary Valuation Item Amount UPB (Face) 100,000 Fair Value 99,000 Valuation Adj. (Day 1) (1000) PCI/PCD Day 1/Pre-Transition Date Positions Amount UPB (Face) 100,000 Impairment 0 Valuation Adj. (Rem.) (1,000) Accretable Yield 7,952 Effective Yield 5.22% Day 2/Pre-Transition Date Positions Amount UPB (Face) 100,000 Fair Value 99,000 Valuation Adj. (Day 1) (1000) Day 1/Post-Transition Date Year Balance Credit Loss Cash Flow 0 100,000 (99,567) << Basis 1 96,869 31 3,341 2 93,768 30 3,303 … … … … Positions Amount UPB (Face) 100,000 EIR (Prepayment) 5.69% Non-Credit Discount (433)/.43% Credit Discount/ALLL (567)/.57% NPV 98,893 ALLL (674)/.67% Day 2/Post-Transition Date
  • 47. 47 • Guidance • TRG • Illustration – ASU 2016-13 Examples • Summary PCI/PCD
  • 48. 48 • Guidance • TRG • Illustration • Summary Day 2 - ALLL, Yield, and Accretion IRR/Yield 15.46% Year Balance Cash Flow 0 2,176,204 (1,918,559) 1 1,119,794 1,186,982 2 0 1,186,982 Valuation Item Amount UPB (Face) 2,176,204 Fair Value 1,918,559 Valuation Adj. (Day 1) 257,645 Balance ALLL Discount Basis 2,176,204 (217,620) (257,645) 1,918,559 Year Discount Accretion Discount 1 (257,645) 165,941 (91,704) 2 (91,704) 91,704 0 Non-PCI/PCD Day 1
  • 49. 49 • Guidance • TRG • Illustration • Summary Day 2 - ALLL, Yield, and Accretion Valuation Item Amount UPB (Face) 2,176,204 Fair Value 1,918,559 Valuation Adj. (Day 1) 257,645 PCI/PCD – Loss Rate Day 1 IRR/Yield 7.33% ALLL 2,176,204 10% 217,620 Year Discount Accretion Discount 1 (40,025) 26,103 (13,922) 2 (13,922) 13,922 0 Year Balance Cash Flow 0 2,176,204 (2,136,179) 1 1,119,794 1,186,982 2 0 1,186,982
  • 50. 50 • Guidance • TRG • Illustration • Summary Day 2 - ALLL, Yield, and Accretion Valuation Item Amount UPB (Face) 2,176,204 Fair Value 1,918,559 Valuation Adj. (Day 1) 257,645 PCI/PCD – Discounted Cash Flow Day 1 IRR/Yield 8.46% Balance ALLL Discount Basis 2,176,204 (185,012) (72,633) 2,103,571 Year Discount Accretion Discount 1 (72,633) 47,285 (25,348) 2 (25,348) 25,348 0 Year Balance Cash Flow Loss 0 2,176,204 (1,918,559) 0 1 1,119,794 1,186,982 0 2 217,620 969,362 217,620
  • 51. I: Applicable Guidance & Updates II: Transition Resource Group (TRG) III: Illustrations IV: Summary 51
  • 52. 52 • Guidance • TRG • Illustration • Summary Summary • Non-PCD: Entire discount is part of the amortized cost basis and may not be reclassified to ALLL • PCI: May not re-evaluate “purchased impaired” status at transition • PCI: TRG working through pooling considerations • PCD: Credit component of remaining discount reclassified to ALLL • PCD: Say goodbye to re-estimations, impairment, and rigorous accretion calculations
  • 53. CPE Code - Part 3 53
  • 55. 2018 CECL Transition Workshops Locations: » Atlanta, GA – March 14 » New York, NY – April 12 » Nashville, TN – June 14 » Los Angeles, CA – July 12 Agenda includes recommendations for a Practical CECL Transition as well as hands-on case studies: » Review CECL principles » Data, segmentation, methodology, average life, forecasting » Executing the practical CECL transition methodology Practical CECL Case Studies and Learning » Chicago, IL – August 9 » Washington, DC – October 11 » Austin, TX – November 8 Sageworks.com/cecl-workshops
  • 56. Q&A