CECL - Understanding Data Requirements for Expected Losses
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Economia e finanças
In the webinars, Sageworks presents an overview of data requirements for the expected credit losses. They look at common data pitfalls for community banks and how they can start to bridge data gaps.
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About the Webinar
• We will address as many questions as we
can throughout the presentation or through
direct communication via follow-up email
• Ask questions throughout the session using
the GoToWebinar control panel
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Disclaimer
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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.
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Segmentation
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda
Proper Segmentation (326-20-30-2)
Segmentations or pools should have similar risk
characteristics. These pools should be as granular as
possible while maintaining statistical significance.
Management will need to evaluate pools on an ongoing
basis to ensure that the underlying assets continue to
exhibit similar risk behavior.
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Segmentation
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda
Proper Segmentation (326-20-30-2)
Segmentations or pools should have similar risk
characteristics. These pools should be as granular as
possible while maintaining statistical significance.
Management will need to evaluate pools on an ongoing
basis to ensure that the underlying assets continue to
exhibit similar risk behavior.
Granular
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Segmentation
9
• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda
Proper Segmentation (326-20-30-2)
Segmentations or pools should have similar risk
characteristics. These pools should be as granular as
possible while maintaining statistical significance.
Management will need to evaluate pools on an ongoing
basis to ensure that the underlying assets continue to
exhibit similar risk behavior.
Granular
Statistical Significance
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Segmentation
10
• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda
Proper Segmentation (326-20-30-2)
Segmentations or pools should have similar risk
characteristics. These pools should be as granular as
possible while maintaining statistical significance.
Management will need to evaluate pools on an ongoing
basis to ensure that the underlying assets continue to
exhibit similar risk behavior.
Granular
Statistical Significance
Continue to exhibit similar risk behavior
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Life-of-Loan
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda Determining the Expected Life of Each
Segment (326-20-30-6)
Entities are required to estimate expected credit losses
over the contractual term of the financial asset(s).
Prepayments will need to be considered as a separate
input or embedded in the credit loss experience.
Expected life is a critical component of all methodologies
used to determine loss experience. Prepayment and/or
mortality rates will provide for increased flexibility and
defensibility.
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Life-of-Loan
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda Determining the Expected Life of Each
Segment (326-20-30-6)
Entities are required to estimate expected credit losses
over the contractual term of the financial asset(s).
Prepayments will need to be considered as a separate
input or embedded in the credit loss experience.
Expected life is a critical component of all methodologies
used to determine loss experience. Prepayment and/or
mortality rates will provide for increased flexibility and
defensibility.
contractual term
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Life-of-Loan
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda Determining the Expected Life of Each
Segment (326-20-30-6)
Entities are required to estimate expected credit losses
over the contractual term of the financial asset(s).
Prepayments will need to be considered as a separate
input or embedded in the credit loss experience.
Expected life is a critical component of all methodologies
used to determine loss experience. Prepayment and/or
mortality rates will provide for increased flexibility and
defensibility.
Prepayments
contractual term
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Data Requirements
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda
Now
Historical Loss Rates
• Charge-offs
• Recoveries
• Aggregate pool data
• Beginning balance of
pool
• Ending balance of pool
Future
Expected Loss Rates
• Charge-offs
• Recoveries
• Aggregate pool data
• Beginning balance of
pool
• Ending balance of
pool
• Risk rating by
individual loan
• Loan duration
• Individual loan
balance
• Individual loan
charge-offs and
recoveries
(partial and full)
• Individual loan
segmentation
New
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Data Requirements for Expected Losses
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda
Now
Historical Loss Rates
• Charge-offs
• Recoveries
• Aggregate pool data
• Beginning balance of
pool
• Ending balance of pool
Future
Expected Loss Rates
• Charge-offs
• Recoveries
• Aggregate pool data
• Beginning balance of
pool
• Ending balance of
pool
• Risk rating by
individual loan
• Loan duration
• Individual loan
balance
• Individual loan
charge-offs and
recoveries
(partial and full)
• Individual loan
segmentation
New
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Ways to Capture Loan-Level Data
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda
Considerations:
• Not a viable approach for
most core systems due to
limited data storage.
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Ways to Capture Loan-Level Data
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda
Considerations:
• Preserves optionality later in
the project. Consider
consistency and coherency.
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Ways to Capture Loan-Level Data
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda
Considerations:
• Significantly reduced risk and
offers most optionality for
use.
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Data Adequacy
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda The data is labeled appropriately (headers consistently applied and are understandable)
Data does not contain duplicates (fields, rows or entities)
There are no inconsistencies in values (e.g., truncated by 000’s vs. not truncated)
Data is stored in the right format (e.g., numbers stored as numbers, zip codes stored as text)
The file extracted from the core system is stored as the right file type
File creation is automated; not requiring manual file creation
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Data Adequacy
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda Data is reliable and standardized throughout the institution, across all departments
Data fields are standardized and governed to ensure consistency going forward
Data storage does not have an archiving time limit (e.g., 13 months)
Data is accessible (usable format like exportable Excel files, integrates with other solutions)
Archiving function captures data points required to perform range of robust methodologies
Questions?
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Data Deep Dive: Data Adequacy
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda 100%
55%
37%
21%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
3 Years 4 Years 5 Years 6+ Years
Years of Data by 2019
Sageworks Clients as of 11/10/16
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Data Deep Dive: Data Adequacy
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100%
55%
37%
21%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
3 Years 4 Years 5 Years 6+ Years
Years of Data by 2019
Sageworks Clients as of 11/10/16
• Of more than 1,000 Sageworks
clients, how many have 12+
quarters of loan-level balance
and loss information?
• At EOY 2019, for clients with
an integration, how many
clients would have loan-level
balance and loss data for:
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Data Deep Dive: Origination Date
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda
95%*
Average
*But as low as 65%
at some institutions
• Among clients, on average,
what percentage of loans
have true origination date
information stored in
Sageworks?
• Has it changed during the
life of the loan?
• Was it changed at renewal? This should never change!
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Data Deep Dive: Renewal Date & Balance
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda • Impacts life of loan
• Impacts vintage
disclosures
• What percentage of
clients have accurate
Renewal Date and
Renewal Balance
archived? START NOW
2.6%
Renewal Date
0.86%
Renewal Balance
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Data Deep Dive: Renewal Date & Balance
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda Your borrower is
past due
Bank adjusts for credit
risk
Bank Reports
Delinquency to Agencies
Credit agencies report a
drop in credit score
• Commercial Risk Ratings
• Delinquency Data
(consumer)
• Consider FICO
Consider Risk Rating
alternatives
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Data Deep Dive: Customer/Contract vs.
Book/GL Balance
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda
Among clients, what percentage provide
separate fields for Contract/Customer-
Facing Balance and GL/Book Balance?
5%
Important to have a time series to determine
expected future cash flows against the book balance.
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Data Deep Dive: Codes
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda
1%
5%
13%
22%
33%
25%
0%
5%
10%
15%
20%
25%
30%
35%
40%
3 4 5 6 7 8
Number of Loan Codes Successfully
Mapped
(Out of 8 Possible)
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Data Deep Dive: Codes
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1%
5%
13%
22%
33%
25%
0%
5%
10%
15%
20%
25%
30%
35%
40%
3 4 5 6 7 8
Number of Loan Codes Successfully
Mapped
(Out of 8 Possible)
• Among clients, on average,
how many loan “codes”
are being populated?
• E.g., Call Code, Collateral
Code, Loan Type Code,
Product Code, Purpose
Code, MSA Code, Industry
Code, Postal Code
Segmentation is the highest-leverage
decision in future guidance.
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Data Deep Dive: Amortization Structure
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda Lines of Credit Amortizing Loans
• Revolving line?
• Paydown / draw speeds?
• Probability of funding?
• Assumptions for principal
wind-down?
• When is payment amount
calculated?
• Balloon Dates and Payments?
• Pre-payments?
• Payment Amounts – P&I Only?
A time-series of balances permits
inference of key parameters
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Data Deep Dive: Available Credit
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda • Important for your lines
• Two paths:
• Compute a lifetime loss rate against funded
balances and apply a probability of funding (extra
lever)
• Compute a lifetime loss rate against commitment
and apply to commitment
“Disclaimer” is severely applicable here, but
archive this data.
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Measurement - Expected Losses
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda
Unadjusted
historical
lifetime loss
experience
Adjustments
for past
events and
current
conditions
Adjustments
for
reasonable
and
supportable
forecasts
Estimate of
expected
credit losses
• Choice of methods include:
• Loss-rate methods
• PD/LGD
• Migration analysis
• Vintage analysis
• Any reasonable approach may be used – guidance is not prescriptive
Source: “Loss Data, Data Analysis, and the Current Expected Credit Loss (CECL) Model”, Fed Perspectives Webinar, 10/30/15
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Measurement - Implementation
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• Segmentation
• Life-of-Loan
• Data
• Measurement
• Q&A
Agenda
• For a PBE that is NOT an SEC filer, the credit losses standard is
effective for fiscal years beginning after December 15, 2020,
including interim periods within those fiscal years.
• Standard effective January 1, 2021
• First application reflected in financial statements and regulatory
reports for the quarter ended March 31, 2021
Source: “FAQ on New Accounting Standard on Financial Instruments – Credit Losses” OCC 12/19/2016
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How Sageworks Can Help
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Advisory Services
CECL Transition
Assistance
Data Quality Audit Advanced Analytics
Sageworks ALLL
Automation to
spend 80% less
time
Supported by risk
management
experts
Dedicated
integration project
manager
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Sageworks Advisory Services
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Utilize Sageworks’ Advisory Services Group as a partner and an
extension of your team.
Our consultants work with institutions to optimize processes to align
with strategy, goals, and mission. Our services enable firms to
proactively monitor trends and drive efficiencies in the lending cycle.
P O R T F O L I O M A N A G E M E N T S E R V I C E S
Services Include
• Model Transition and Validation
Services
• CECL Transition Services
• Prepayment, Curtailment, Funding,
and Cash Flow modeling
• Risk Rating Policies and Backtesting
• Profitability Analytics
O P T I M I Z A T I O N
I N S T I T U T I O N
D A T A
S A G E W O R K S
S O L U T I O N S
• Valuation Services
• Economic Modeling
• Process Optimization
• Professional Education
• DFAST Support
• ALM Support
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Expert consultants will structure and lead a project to:
• Perform a Readiness Fit-Gap analysis
and remediate issues
• Create and support execution of a
Transition Project Plan
• Review segmentation strategy and
impact
• Execute appropriate measurement
scenarios and provide a Model
Selection Impact Analysis
• Execute preparatory and transitional
measurements
• Train users on model configuration
and execution
• Analyze portfolio data to provide
strongly supported, bottom-up
estimations for important model
inputs
Initial measurements
& model selection Stabilization
Parallel
A D V I S O R Y S E R V I C E S
C E C L T R A N S I T I O N A S S I S TA N C E
TRANSITION
2 0 1 7 2 0 1 8 2 0 1 9 Monitor
• Create peer/industry benchmarks for
model inputs where institutional loss
experience cannot be relied on
• Create statistical models for economic
forecasting
Sageworks Advisory Services
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Question & Answer
50
Resources
• ALLL.com – join to network, discuss and learn about
the ALLL
• SageworksAnalyst.com – access whitepapers and the
webinar archive
• Risk Management Summit 2017 – September 25-27
in Denver, CO
• Q&A
Garver Moore
Principal - Advisory Services
Garver.Moore@Sageworks.com
Contact Us:
Tim McPeak
Senior Risk Management Consultant
Tim.McPeak@Sageworks.com
David Kistler
Marketing Manager
David.Kistler@Sageworks.com