CECL s Forward-Looking Requirements: The Impact Could Be Substantial

Transcription

1 CECL s Forward-Looking Requirements: The Impact Could Be Substantial Cristian deritis PhD, Senior Director, Economics Timothy Daly, Director, Sales Manager

2 Presenters Dr. Cristian deritis Senior Director, Consumer Credit Analytics Cristian deritis, PhD, is a Senior Director with Moody s Analytics specializing in consumer credit analysis, policy and U.S. economic conditions. Timothy Daly Director, Sales Manager of Economics and Consumer Credit Analytics Tim Daly, is a Director with Moody s Analytics specializing in helping clients meet their economic and consumer credit needs.

3 This changes everything. Source: FASB

4 CECL in a What s it all about?» The CECL standard will change how firms estimate their allowance for loan and lease losses (ALLL).» Addresses too little too late loss provisioning that occurred during the financial crisis.» Replaces the current incurred loss standards commonly known as FAS-5 and FAS-114.» Applies to any entity issuing credit, including banks, credit unions and holding companies filing under GAAP accounting standards.» CECL will go into effect starting December 15, 2019, for public business entities that are U.S. SEC filers. CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

5 Conceptual Differences» Under the incurred loss model, banks recognize losses when they reach a probable threshold of loss.» CECL removes the probable loss threshold and requires a lifetime credit loss allowance to be established on day one of each exposure.» Forecasting losses under CECL requires - More granular data - Enhanced credit models - Forward-looking information or scenarios CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

6 Biggest Change: Forecasting Losses» Currently, losses are forecast over a loss emergence period.» CECL is a lifetime loss estimate. - Forecast losses over a reasonable and supportable horizon - Extrapolate beyond this horizon using historical averages over the remaining life» CECL standards are principles-based. - Not prescriptive in how institutions address specific modeling challenges - Flexibility to account for firms of different size and complexity» Require increased transparency in assumptions and more disclosures to support the allowance estimate.» Selection of forecasts and assumptions will need quantitative support. CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

7 Cost to Estimate ALLL Will Increase» CECL is more computationally intensive than the current method. - Under the current standard, only a small subset of loans in the portfolio with a high probability of loss are modeled» Under CECL standard, we need to estimate and account for the potential losses from all loans. CECL adds a probabilistic component.» Given additional complexity, need efficiency gains to meet financial reporting deadlines: - Better data management (centralized, scrubbed, QC checks) - Enhanced execution performance (hardware, cloud) - Models fit to purpose (optimize to produce required outputs) - Specialization and outsourcing (buy vs. build trade-off) CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

8 Dispelling Some CECL Myths Allowances will double Allowances will fall You must build all of your own models You can only forecast under one economic scenario You must forecast under multiple economic scenarios Auditors will demand more conservative estimates CECL will force banks to only make short-term loans CECL will cause all banks to be undercapitalized CECL will push all lending to the shadow system CECL will destroy the economy CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

9 How Will CECL Impact My Allowance?» Depends on a number of factors including - Portfolio composition (longer-dated loans impacted more) - Credit quality - Geography - Forward-looking forecast assumptions - Stage of economic cycle» As an exercise, we consider FDIC historical data on charge-offs and allowances for all commercial banks» Assume perfect foresight (that is, no model forecast error)» Use residential mortgage vintage performance to calibrate lifetime loss performance for CECL» Just a thought exercise. Bank-specific results will vary! CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

10 Estimating the Impact: Default Rates Vary by Vintage Cohort 5-yr cumulative net loss rate for first mortgage by origination qtr Avg=2.6% Sources: CreditForecast.com, Moody s Analytics CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

11 Charge-Offs Depend on Volume and Performance Net loan and lease charge-offs at commercial banks, $ bil Poor quality and high orig. volume in By default yr By origination yr Sources: FDIC, Moody s Analytics CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

12 Provision Expenses Front-Load With CECL Provision for loan and lease losses at commercial banks, $ bil Would provisions have changed behavior? Actual CECL estimate Sources: FDIC, Moody s Analytics CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

13 Allowance Balance (ALLL) Allowance for loan and lease losses at commercial banks, $ bil 300 Actual CECL estimate ALLL should better align with credit quality Sources: FDIC, Moody s Analytics CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

14 The Biggest Change Ever to Accounting FASB s 3 key considerations in estimating CECL Current Conditions Lifetime Losses Supportable Forecasts» Recognition of credit losses will shift to an earlier point in the credit cycle» Current conditions will differ by market (and type)» The impact of conditions also differ measurably» Lack of data or lack of quantitative support for management estimates» Lifetime losses must be recognized at origination, rather than when default is deemed likely» Cumulative losses are nonlinear how to measure?» Prepayments are difficult to measure, especially for commercial portfolios» Differences by loan types» Need to generate economic scenarios» Also, to appropriately link scenarios to credit losses» Ability to forecast beyond a year or two into the future is a challenge» Unreliable forecasts will mean greater volatility in loss provisions Biggest implementation challenge: Generating forward-looking scenarios CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

15 Manage Risk With Scenario Analysis Scenario service, monthly updates with narratives and probability weights Real GDP, % change yr ago Source: Moody s Analytics Baseline S1 S2 S3 S4 S5 S6 Available Scenarios Standard-Driven S1 Stronger Near-Term Rebound BL Baseline Forecast S2 Slower Near-Term Recovery S3 Moderate Recession S4 Protracted Slump S5 Below-Trend Long-Term Growth S6 Stagflation S7 Next-Cycle Recession (U.S. Only) S8 Low Oil Price CS Constant Severity CB Consensus Baseline (U.S. Only) Compliance-Driven FB Fed Baseline FA Fed Adverse FS Severely Adverse Scenario BC Bank Specific Scenario CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

16 Moody s Analytics Scenarios Reasonable and supportable forecasts from Moody s Analytics Key Features» Baseline forecast + eight alternative scenarios with probability weights» Available for the U.S., all state and metro areas, as well as 60+ countries» Coverage of more than 1,800 economic, financial and demographic variables» Forecasts updated monthly, history updated in real-time, 30-year horizon» Fully documented model methodology; scenario assumptions published monthly» Back-testing, tracking and model validation reports available CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

17 What Makes a Good Economic Forecast? Key considerations: Based on sound, generally accepted economic and statistical theory Incorporates inter-relationships and feedback effects among variables such that a shock to one factor impacts all other factors over time Provide information at varying levels of geographic aggregation to capture local economic effects Our economic forecasting model meets these criteria. CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

18 Structural Forecast Model Methodology Approach used by use by Federal Reserve, IMF, Central Banks Banking sector 10-yr yield Consumption Wages and salaries Monetary policy rate Investment Labor force Prices Exchange rates Government Exports Employment Unemployment rate Population Import prices Imports GDP Global prices Global GDP Potential GDP CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

19 Macro to Regional Linkages Interrelationships between all key variables US MACRO MODEL Cost of Doing Business Population/Households Output by Industry Employment by Industry Housing Personal Income Labor Force/Unemployment Consumer Credit Quality CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

20 Want to Create Your Own Scenarios? Use our collaborative forecasting platform» Web-based application to develop your own scenarios» Uses Moody s Analytics validated macro models» Forecast governance built into the application core Audit trail of edits to forecast assumptions Test edits in a sandbox environment before committing them to the master forecast Transparency of equations and assumptions» Collaborate with colleagues and/or Moody s Analytics on the same forecast Simultaneous read/write access CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

21 How Many Scenarios Do You Need? Leverage percentile distributions using multiple scenarios» No specific guidance at least one forward look Could interpret as Baseline or Consensus scenario» IFRS9 analogue to CECL Multiple, probability-weighted scenarios» Measure loss under multiple scenarios Generate a distribution» Given distribution of losses is skewed, multiple scenarios preferred Average economic forecast won t generate the average level of losses Multiple scenarios approximate the distribution CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

22 Single, Consensus Unemployment Forecasts Unemployment rate, % Initial forecast Realized Update 1 Update Sources: BLS, Moody s Analytics X-axis: mo from start of forecast CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

23 Single Scenario: Loss Forecasts Volatile Under Consensus Loss rate, % Consensus Update 1 Update X-axis: mo on book (age) Sources: BLS, Moody s Analytics CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

24 Multiple Scenarios: Probability Weighted Forecasts Loss rate, % % wgt 40% wgt 30% wgt Baseline S1: Optimistic S3: Pessimistic Prob Weighted Sources: BLS, Moody s Analytics X-axis: mo on book (age) CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

25 Multiple Scenarios: Loss Forecast Updates Less Volatile Loss rate, % Prob Weighted Update 1 Update X-axis: mo on book (age) Sources: BEA, Moody s Analytics CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

26 Recommendations Different approaches for different situations 1. For the largest institutions:» Multiple custom economic scenarios provide a wide range of estimates.» Estimates less sensitive to decisions on forecast period and mean reversion.» Multiple scenarios reduce volatility in quarter-to-quarter updates. 2. For midsize institutions:» Standardized economic forecasts provide a reasonable solution.» Multiple, risk-weighted scenarios provide a quantitative, defensible approach.» Multiple scenarios reduce volatility in quarter-to-quarter updates. 3. For smaller institutions:» A single scenario approach is reasonable.» Reasonable and supportable forecast horizon at 2-3 years with gradual reversion..» Run periodic sensitivity analysis to disclose potential volatility/risks to the forecast. CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

27 Moody s Analytics CECL Solution Suite CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

28 United States 121 North Walnut Street Suite 500 West Chester PA United Kingdom One Canada Square Canary Wharf London E14 5FA Australia Level 10 1 O'Connell Street Sydney, NSW, 2000 Australia, Prague Washingtonova Prague 1 Czech Republic moodysanalytics.com

29 2018 Moody s Corporation, Moody s Investors Service, Inc., Moody s Analytics, Inc. and/or their licensors and affiliates (collectively, MOODY S ). All rights reserved. CREDIT RATINGS ISSUED BY MOODY'S INVESTORS SERVICE, INC. AND ITS RATINGS AFFILIATES ( MIS ) ARE MOODY S CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES, AND MOODY S PUBLICATIONS MAY INCLUDE MOODY S CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES. MOODY S DEFINES CREDIT RISK AS THE RISK THAT AN ENTITY MAY NOT MEET ITS CONTRACTUAL, FINANCIAL OBLIGATIONS AS THEY COME DUE AND ANY ESTIMATED FINANCIAL LOSS IN THE EVENT OF DEFAULT. CREDIT RATINGS DO NOT ADDRESS ANY OTHER RISK, INCLUDING BUT NOT LIMITED TO: LIQUIDITY RISK, MARKET VALUE RISK, OR PRICE VOLATILITY. CREDIT RATINGS AND MOODY S OPINIONS INCLUDED IN MOODY S PUBLICATIONS ARE NOT STATEMENTS OF CURRENT OR HISTORICAL FACT. MOODY S PUBLICATIONS MAY ALSO INCLUDE QUANTITATIVE MODEL-BASED ESTIMATES OF CREDIT RISK AND RELATED OPINIONS OR COMMENTARY PUBLISHED BY MOODY S ANALYTICS, INC. CREDIT RATINGS AND MOODY S PUBLICATIONS DO NOT CONSTITUTE OR PROVIDE INVESTMENT OR FINANCIAL ADVICE, AND CREDIT RATINGS AND MOODY S PUBLICATIONS ARE NOT AND DO NOT PROVIDE RECOMMENDATIONS TO PURCHASE, SELL, OR HOLD PARTICULAR SECURITIES. NEITHER CREDIT RATINGS NOR MOODY S PUBLICATIONS COMMENT ON THE SUITABILITY OF AN INVESTMENT FOR ANY PARTICULAR INVESTOR. MOODY S ISSUES ITS CREDIT RATINGS AND PUBLISHES MOODY S PUBLICATIONS WITH THE EXPECTATION AND UNDERSTANDING THAT EACH INVESTOR WILL, WITH DUE CARE, MAKE ITS OWN STUDY AND EVALUATION OF EACH SECURITY THAT IS UNDER CONSIDERATION FOR PURCHASE, HOLDING, OR SALE. MOODY S CREDIT RATINGS AND MOODY S PUBLICATIONS ARE NOT INTENDED FOR USE BY RETAIL INVESTORS AND IT WOULD BE RECKLESS AND INAPPROPRIATE FOR RETAIL INVESTORS TO USE MOODY S CREDIT RATINGS OR MOODY S PUBLICATIONS WHEN MAKING AN INVESTMENT DECISION. IF IN DOUBT YOU SHOULD CONTACT YOUR FINANCIAL OR OTHER PROFESSIONAL ADVISER. ALL INFORMATION CONTAINED HEREIN IS PROTECTED BY LAW, INCLUDING BUT NOT LIMITED TO, COPYRIGHT LAW, AND NONE OF SUCH INFORMATION MAY BE COPIED OR OTHERWISE REPRODUCED, REPACKAGED, FURTHER TRANSMITTED, TRANSFERRED, DISSEMINATED, REDISTRIBUTED OR RESOLD, OR STORED FOR SUBSEQUENT USE FOR ANY SUCH PURPOSE, IN WHOLE OR IN PART, IN ANY FORM OR MANNER OR BY ANY MEANS WHATSOEVER, BY ANY PERSON WITHOUT MOODY S PRIOR WRITTEN CONSENT. All information contained herein is obtained by MOODY S from sources believed by it to be accurate and reliable. Because of the possibility of human or mechanical error as well as other factors, however, all information contained herein is provided AS IS without warranty of any kind. MOODY'S adopts all necessary measures so that the information it uses in assigning a credit rating is of sufficient quality and from sources MOODY'S considers to be reliable including, when appropriate, independent third-party sources. However, MOODY S is not an auditor and cannot in every instance independently verify or validate information received in the rating process or in preparing the Moody s publications. To the extent permitted by law, MOODY S and its directors, officers, employees, agents, representatives, licensors and suppliers disclaim liability to any person or entity for any indirect, special, consequential, or incidental losses or damages whatsoever arising from or in connection with the information contained herein or the use of or inability to use any such information, even if MOODY S or any of its directors, officers, employees, agents, representatives, licensors or suppliers is advised in advance of the possibility of such losses or damages, including but not limited to: (a) any loss of present or prospective profits or (b) any loss or damage arising where the relevant financial instrument is not the subject of a particular credit rating assigned by MOODY S. To the extent permitted by law, MOODY S and its directors, officers, employees, agents, representatives, licensors and suppliers disclaim liability for any direct or compensatory losses or damages caused to any person or entity, including but not limited to by any negligence (but excluding fraud, willful misconduct or any other type of liability that, for the avoidance of doubt, by law cannot be excluded) on the part of, or any contingency within or beyond the control of, MOODY S or any of its directors, officers, employees, agents, representatives, licensors or suppliers, arising from or in connection with the information contained herein or the use of or inability to use any such information. NO WARRANTY, EXPRESS OR IMPLIED, AS TO THE ACCURACY, TIMELINESS, COMPLETENESS, MERCHANTABILITY OR FITNESS FOR ANY PARTICULAR PURPOSE OF ANY SUCH RATING OR OTHER OPINION OR INFORMATION IS GIVEN OR MADE BY MOODY S IN ANY FORM OR MANNER WHATSOEVER. Moody s Investors Service, Inc., a wholly-owned credit rating agency subsidiary of Moody s Corporation ( MCO ), hereby discloses that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred stock rated by Moody s Investors Service, Inc. have, prior to assignment of any rating, agreed to pay to Moody s Investors Service, Inc. for appraisal and rating services rendered by it fees ranging from $1,500 to approximately $2,500,000. MCO and MIS also maintain policies and procedures to address the independence of MIS s ratings and rating processes. Information regarding certain affiliations that may exist between directors of MCO and rated entities, and between entities who hold ratings from MIS and have also publicly reported to the SEC an ownership interest in MCO of more than 5%, is posted annually at under the heading Investor Relations Corporate Governance Director and Shareholder Affiliation Policy. Additional terms for Australia only: Any publication into Australia of this document is pursuant to the Australian Financial Services License of MOODY S affiliate, Moody s Investors Service Pty Limited ABN AFSL and/or Moody s Analytics Australia Pty Ltd ABN AFSL (as applicable). This document is intended to be provided only to wholesale clients within the meaning of section 761G of the Corporations Act By continuing to access this document from within Australia, you represent to MOODY S that you are, or are accessing the document as a representative of, a wholesale client and that neither you nor the entity you represent will directly or indirectly disseminate this document or its contents to retail clients within the meaning of section 761G of the Corporations Act MOODY S credit rating is an opinion as to the creditworthiness of a debt obligation of the issuer, not on the equity securities of the issuer or any form of security that is available to retail investors. It would be reckless and inappropriate for retail investors to use MOODY S credit ratings or publications when making an investment decision. If in doubt you should contact your financial or other professional adviser. Additional terms for Japan only: Moody's Japan K.K. ( MJKK ) is a wholly-owned credit rating agency subsidiary of Moody's Group Japan G.K., which is wholly-owned by Moody s Overseas Holdings Inc., a wholly-owned subsidiary of MCO. Moody s SF Japan K.K. ( MSFJ ) is a wholly-owned credit rating agency subsidiary of MJKK. MSFJ is not a Nationally Recognized Statistical Rating Organization ( NRSRO ). Therefore, credit ratings assigned by MSFJ are Non-NRSRO Credit Ratings. Non-NRSRO Credit Ratings are assigned by an entity that is not a NRSRO and, consequently, the rated obligation will not qualify for certain types of treatment under U.S. laws. MJKK and MSFJ are credit rating agencies registered with the Japan Financial Services Agency and their registration numbers are FSA Commissioner (Ratings) No. 2 and 3 respectively. MJKK or MSFJ (as applicable) hereby disclose that most issuers of debt securities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred stock rated by MJKK or MSFJ (as applicable) have, prior to assignment of any rating, agreed to pay to MJKK or MSFJ (as applicable) for appraisal and rating services rendered by it fees ranging from JPY200,000 to approximately JPY350,000,000. MJKK and MSFJ also maintain policies and procedures to address Japanese regulatory requirements. CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

30 Selected Case Studies INSTITUTION Large Multinational GSIB (Asset Size = $386B) CCAR Bank (Asset Size = $180B) Merchant Services (Asset Size = $33B) Captive Finance (Asset Size = $180B) DFAST Bank (Asset Size = $26B) OVERVIEW Produced stressed BHC scenario based on counterparty default and three Fed scenarios through a network of ~1000 macroeconomic and global financial market factors. Footprint: International, Market Risk, U.S. subnational specialty Met with C suite to assess client s risk profile including C&I concentrations and retail mix. Proposed three idiosyncratic scenarios for their CCAR submission (ex yield curve inverts, Fed tightens monetary policy too soon, nuclear reactor accident) Footprint: U.S. and select States Partnered with client s risk management team to build IFRS 9 compliant models for all of their portfolios and provided access to our probability-weighted scenarios for use in the models. CECL modeling to start in Footprint: U.S., select States and Metros, International Assisted with scenario and model development for IFRS 9 providing access to off-the-shelf scenarios and built IFRS 9 compliant model for auto loan portfolio. Footprint: Canada, select Provinces and Metros in Canada Partnering with client s CECL working group and stress-test team to provide off-the-shelf scenarios highlighting key risks in CRE, C&I, and mortgages. Footprint: U.S., select States and Metros in the Midwest CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

31 CECL Scope and Timeline» Scope: financial instruments measured at amortized cost basis Loans held for investment Debt securities held to maturity Net investment in leases Off balance sheet exposures (loan commitments, letters of credit) Other (trade and reinsurance receivables, off-balance-sheet exposures)» AFS OTTI model is changed to Allowance model» Measure expected credit losses over the life of financial asset based on: Past events, including historical experience Current conditions Reasonable and supportable forecasts» New disclosure requirements: amortized cost by credit quality indicators and vintage» Current processes can be leveraged, but there are a number of considerations Internal credit risk systems Incurred loss ALLL processes DFAST processes 2017 Project Plan/ Governance Structure Mid-2017 Gap Analysis Preliminary Decisions Mid-2018 Models and Methodology 2018 End-To-End Solution Implementation 2019 Parallel Run 2019 Early Adoption? 2020 SEC Filers CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

32 Key Decisions for Computing CECL Data and Methodology Which methods are acceptable? Can I leverage existing models? Lifetime Definition Contractual or behavioral life? Life of revolving account? Model Backtesting and Benchmarking What s required? Best practice? What are options for retail credit? Economic Scenarios Which scenario is defensible? How many? Source: Moody s Analytics CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan

33 Industry Survey: What Is the Most Significant Challenge Anticipated? Model-related issues consistently rank high February % 10% August % 11% 32% 35% 18% 27% Data availability ECL quantification Scenario design Qualitative overlay methodology Performance (i.e. speed of execution) Data and process governance 37% 18% Data availability Scenario selection, design and support Expected credit loss methodology Process governance and controls CECL s Forward-Looking Requirements: The Impact Could Be Substantial, Jan