FASB vs. IASB Proposals: Can't We "ALLL" Just Get Along?
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Transcript of FASB vs. IASB Proposals: Can't We "ALLL" Just Get Along?
Presented by:
Ed Bayer, Senior Risk Management Consultant
Mike Lubansky, Director of Consulting Services
Financial information company that provides credit and risk management solutions to financial institutions
Data and applications used by thousands of financial institutions and accounting firms across North America
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held companies in the U.S.
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Ed Bayer ◦ Ed Bayer is a senior risk management consultant at
Sageworks, where he serves as a specialist in assisting financial institutions with accurately interpreting and applying federal accounting guidance.
Mike Lubansky Mike Lubansky is a director of consulting services at
Sageworks and serves as the in-house ALLL expert. He has led the implementation of an automated ALLL solution for more than 70 financial institutions ranging in size from $37 million to $20 billion in assets.
FASB = Financial Accounting Standards Board ◦ Since 1973, the designated organization in the
private sector for establishing standards of financial accounting that govern the preparation of financial reports by nongovernmental entities.
IASB = International Accounting Standards Board ◦ The independent standard-setting body of the
International Financial Reporting Standards (IFRS) Foundation.
October 2002: Norwalk Agreement ◦ Joint projects
◦ Short-term convergence project
◦ IASB member on site at FASB offices
◦ FASB monitoring of IASB projects
◦ Convergence research project
◦ Consideration of convergence potential in all Board agenda decisions
Previous joint proposals
July 2012: The boards split on the impairment model for loan losses ◦ According to FASB Chair Leslie Seidman, “..we believe it is
essential that we address the questions that have been raised in the U.S. before moving forward with an exposure draft..”
FASB’s CECL Model vs. IASB’s Credit Deterioration Model
Exposure draft issued December 2012
Accounting Standards Update (ASU) Financial Instruments-Credit Losses (Subtopic 825-15)
CECL = Current Expected Credit Losses
Comment period extended to May 31, 2013
Forward-looking requirements
“Probable” threshold removed
Longer loss horizon
Time value of money plays a role
Collateral definitions
Impact on ALLL: ◦ Speculation that it may increase 10 to 50 percent
◦ Could lead to one-time adjustment
Issued March 2013
Exposure Draft (ED) Financial Instruments: Expected Credit Losses
Comment period ends July 5, 2013
Amount ◦ Bucket 1: Financial instruments whose credit quality
has not significantly deteriorated since initial recognition
◦ Bucket 2: Financial instruments whose credit quality has significantly deteriorated since initial recognition
◦ Bucket 3: Financial instruments for which there is objective evidence of an impairment as of the reporting date
Recognition
Interest changes
Purchased or originated credit-impaired financial assets
Simplified approach for trade and lease receivables
New disclosures – incl. reconciliation and explanation of assumptions
Impact on ALLL: ◦ Likely would cause an increase, probably less than
CECL model
CECL Model: ◦ Forward-looking
◦ Immediate write-offs
◦ Improved definitions on interest income, collateral dependent, etc.
Credit Deterioration Model: ◦ Also forward-looking
◦ Immediate write-offs
◦ Not requiring lifetime losses for pass-rated loans
◦ Includes financial guarantee contracts
CECL Model ◦ How to calculate future expected losses
◦ Large, immediate increase in ALLL
◦ IASB feels this approach states originated assets as below fair value
Credit Deterioration Model ◦ How to calculate future expected losses
◦ Ambiguity surrounding Stage 2 classification
◦ CECL Model seems to be clearer in terms of PCI
Data requirements
New disclosures
Assumptions
Will there be a re-convergence?
Timeline/Expectations
Sageworks’ Risk Management Consultants ◦ 919-851-7474
Future ALLL Webinars
Whitepaper on FASB vs. IASB will be available
Sageworks Blog ◦ How the CECL model could affect allowance levels
◦ What are financial institutions saying about FASB’s CECL model?