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1 BankersHub.net March 2015 Newsletter Page - 1 Newsletter Article March, 2015 LOAN LOSS EXPENSE AND THE LOAN LOSS RESERVE Editorial Content By Paul Sanchez, CPA, CBA, CFSA, Reprinted with permission from Feb 2015 Ideas and Analysis Letter: Sanchez Take ABOUT THE AUTHOR Paul J. Sanchez conducts a CPA practice in Port Washington, New York. He is also owner of Professional Service Associates (PSA), a consulting and professional training and development business servicing corporate clients (auditors, controllers, etc.), CPA firms, associations and others. Prior to PSA, he was VP-Professional Development for the Audit Division of a regional bank and Director of Professional Practices and VP of a money-center bank, where he directed the professional practice development and training for internal auditors. Estimates - An Important Part of the GAAP Financial Statements Every accountant in every industry must deal with estimates of certain amounts for inclusion in the GAAP financial statements. Estimates are never exact. They are approximations. They are reasonably created amounts that are needed to complete the GAAP picture. Some estimates cross industry lines and some don't. Some are somewhat rudimentary and others are complicated. They cover a wide range of areas, including estimated useful lives and estimated salvage values. They include depreciation of fixed assets; estimated current and deferred income tax amounts; estimated valuation balances for deferred tax assets; estimated fair values for certain investments in marketable securities; estimated impairmentlosses etc. Some estimates are unique to particular industries such as estimates of: Reserve for inventory obsolescence for companies with inventories of a fashion or non-staple nature Reserve for inventory markdowns for retailers Reserve for warranty costs for sellers of returnable or refundable merchandise Proved reserves for inventories in the extractive industry (e.g. oil, gas, gold, silver) The Significant Estimate for the Depository Institution Accountant The Loan Loss Estimate Depository institutions (banks, thrifts, credit unions) have one significant estimate that their accountants wrestle with. It is the estimate for the Provision for Loan and Lease Losses and the Allowance for Loan and Lease Losses. ABOUT BankersHub BankersHub was founded in 2012 by Michael Beird and Erin Handel, 2 Financial Services professionals dedicated to educating and informing banks, credit unions, solution providers and consultants in the U.S. and worldwide. BankersHub delivers best practices, research insights, opinions, economic trends and consumer views through online web education, virtual events and conferences, live streaming activities, custom training and content development.

2 BankersHub.net March 2015 Newsletter Page - 2 Refresher Loans should be carried at Net Realizable Value (NRV) which is the gross amount due from the customer less an allowance or reserve for estimated loan losses. The allowance represents management s best estimate of the gross amount due that will not be collected. Generally, the NRV is the present value of the expected cash to be collected. In some circumstances it is the value of the collateral for a loan that is collateral dependent. Sometimes, it is the market value of the loan if a market value can be determined. Accounting guidance for the calculation of the a bank's allowance for loan and lease losses is provided in: FASB Accounting Standards Update (ASU) Loss Contingencies (SFAS 5) FASB Accounting Standards Update (ASU) Receivables Overall - Subsequent Measurement (SFAS 114) Financial Institutions Letter (FIL) Allowance for Loan and Lease Losses Revised Policy Statement and Frequently Asked Questions Determination of the Allowance Balance All banks use the same general methodology for calculating reserves. The specific calculations, however, differ in many ways. The first consideration is the ASU or SFAS 5 reserve for loss contingencies. SFAS 5 Analysis ASC deals with uncertainty. It requires a probability threshold for recognition of a loss contingency. The amount of the loss recorded must be probable and reasonably estimable. In other words, no provision is recorded unless the loan loss is probable and the amount can be reasonably estimated. If both of those recognition criteria are met, and the reasonably estimable loss is within a range, the amount that appears to be a better estimate within the range is used. If no amount within the range is a better estimate, then the minimum (not maximum) amount in the range is used. Loss reserves for small balance homogenous loans (e.g. retail loans, 1-4 family residential mortgages) is determined based on analysis of the pools of similar loans with similar credit characteristics. Most banks manage retail loan credit risk on a portfolio basis so reserves by portfolio are determined using analytical models that incorporate various factors such as: Historical delinquency rates Experienced loss frequencies Expected loss severities Generally, reserves for such loans reflect inherent losses in the portfolio that are expected to be recognized over the loan s next twelve months. The method for determining the allowance has become somewhat of an art form, and the degree of judgment allowed to management has been criticized. Nevertheless, the approach should be consistent and should use qualitative factors such as the following that can be properly supported:

3 BankersHub.net March 2015 Newsletter Page Lending Policies 2. Local Economic Conditions 3. Loan Volume 4. Staffing Changes 5. Credit Quality of Borrowers 6. Loan Review Systems in Place 7. Collateral Values 8. Concentrations of Credit Risk Many banks use only some of these qualitative factors and the factors are often best estimates or best guesses. They often are not supported by hard (or even soft ) evidence. Sometimes, they are merely hunches. In addition to the small homogeneous loan groupings, banks also grade their commercial loans on a likelihood of repayment basis. Different banks use different systems. Usually the relationship manager responsible for the loans assigns to each loan a grade number based on objective and subjective measures. These grade numbers are audited by a loan review function and by bank regulators. For example a 16-point grading system such as the following is typical: Loans assigned a grade of 14, 15 or 16 are often called criticized or classified loans. A careful review of the pools of classified loans is used to determine the reserve amount for ASU or SFAS 5 loans. Future Direction of the SFAS 5 Allowance Right now the FASB is attempting to finalize a new approach to determining the SFAS 5 portion of the allowance. The new approach is called the Current Expected Credit Loss (CECL) Model. It will be based on expected credit losses - not on inherent losses - that exist in the portfolio of loans. The new model will be a countercyclical approach whereby allowance amounts will be set-up during periods of relatively, stable business activity. When established, the estimate of the loan losses will be based on philosophy that is exactly opposite of the allowance philosophy that is currently used. Currently, under GAAP, loan losses are booked when there is an actual loss in the current loan portfolio. When the economic climate is not favorable and lending is soft, the accountants pile on the losses. The

4 BankersHub.net March 2015 Newsletter Page - 4 opposite should be happening. When the climate is unfavorable, reserves should be used or drawn upon, not piled on. The new CECL model will promote booking losses when times are good (i.e. put away reserves for a rainy day). Details of the proposed CECL model are beyond the scope of this Take. SFAS 14 Analysis After completing all evaluations for the ASC loans (small homogeneous loans, commercial loans graded etc.), the bank then analyzes those loans that were specifically identified as loans subject to the SFAS 114 (ASU ) impairment determination. A bank should use its normal loan review procedures to determine loans to be evaluated under ASC Sources of information useful in identifying loans for the ASC evaluation include the following: A specific materiality criterion Regulatory reports of examination Internally generated listings such as watch lists, past due reports, overdraft listings, and listings of loans to insiders Management reports of total loan amounts by borrower Historical loss experience by type of loan Loan files lacking current financial data related to borrowers and guarantors Borrowers experiencing problems such as operating losses, marginal working capital, inadequate cash flow, or business interruptions Loans secured by collateral that is not readily marketable or that is susceptible to deterioration in realizable value Loans to borrowers in industries or countries experiencing economic instability Loan documentation and compliance exception reports. Reserves are established only for those individually selected loans considered impaired. What is an Impaired Loan? A loan is considered impaired when, based on current information and events, it is probable that a creditor (the bank) will be unable to collect all contractual interest and contractual principal amounts due according to the contractual terms of the original loan agreement. In other words the loan will not "pan out" as originally planned. Those specifically identified commercial loans not deemed to be impaired are put into the pool of SFAS 5 evaluated loans. At that point the accountant can summarize what has been done as follows:

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7 BankersHub.net March 2015 Newsletter Page - 7 To summarize, the allowance is maintained by management at a level (i.e. estimated amount) believed adequate to absorb probable losses inherent in the loan portfolio. Determination of the allowance is inherently subjective. It requires significant estimates, including the amounts and timing of expected future cash flows on impaired loans, estimated losses on pools of homogenous loans based on historical loss experience and consideration of economic trends, all of which may be susceptible to significant change. Credit losses are charged off against the allowance while recoveries of amounts previously charged off are credited to the allowance. Evaluations are conducted at least quarterly and more often if deemed necessary. The components of the allowance for credit losses represent an estimation done pursuant to FASB guidance in Accounting Standards Codification ( ASC ) Topic 310 Receivables, and ASC Topic 450 Contingencies. The allowance for credit losses is based on a combination of the higher of the Bank s historical loss experience or the peer group average historical loss experience plus qualitative factors for specific types of loans. Individual loans deemed impaired are separated from the respective loan portfolios and a specific reserve allocation is assigned to them. The qualitative factors include levels and trends in delinquencies and non-accruals; trends in volumes and terms of loans; effects of any changes in lending policies; the experience, ability and depth of management; national and local economic trends and conditions; concentrations of credit; quality of the bank s loan review system; and, external factors, such as competition, legal and regulatory requirements. Soft Estimates One can see that the loan loss estimates are quite flexible and at best are soft estimates. The final numbers are very difficult to verify. Often that is why the numbers for Loan Losses are criticized and sometimes called manipulative. Some believe the estimated reserve for public companies is treated as a free credit that can be manipulated at will, without much serious consideration as to correctness, in order to influence reported earnings. What s the Fuss? Bank accountants, analysts, management and others make a fuss about the estimated loan loss provision and loan loss reserve. But, what exactly are they fussing about. A brief review of the Uniform Bank Holding Company Performance Report (UBHCPR) for the ninety (90) Peer Group 1 Bank Holding Companies with consolidated assets equal to or greater then $10 billion at 12/31/14 reveals the following. The 2014 provision for loan losses is only 0.14% of average assets. Certainly, not an estimate to lose sleep over. In fact it has been relatively small for recent years (e.g. 0.19%, 0.33%, 0.49%, and 1.10% for calendar years 2013, 2012, 2011, and 2010.) Even in the dreadfully poor loan year 2010 it barely surpasses 1% of average total assets. As a percentage of total equity, the allowance, although not a small amount, is still only about 5% of equity. Over recent years it was only 5.29%, 5.30%, 5.20%, 5.26%, and 5.41% for 2014, 2013, 2012, 2011, and 2010, respectively). Even as a percentage of total loans and leases not held for sale, the allowance or reserve estimate is relatively small (1.24%, 1.42%, 1.64%, 12.13%, and 2.67%).

8 BankersHub.net March 2015 Newsletter Page - 8 Overall, the provision and allowance seem to be relatively small in relation to assets, equity and loans. Perhaps it s a fuss about minor amounts. On the other hand, maybe the overall reserve amounts simply are too small. For example, the estimated reserve balance may not be enough to absorb the junk, (i.e. restructured loans, non-accrual loans and OREO.) Those junk assets are huge in relation to the reserve balance. At 12/31/14, the junk is %, %, %, %, and % of the Peer Group 1 total allowance for 2014, 2013, 2012, 2011 and This may suggest that the behemoths in Peer Group 1 may need a serious injection of reserves to absorb losses from the restructured loans, non-accrual loans and OREO. Such a lot of fuss about such soft numbers is par for the course in bank accounting circles. A revisit to the loan loss provisions and reserve estimation process is overdue. Soon we will see how the new (CECL) approach fares when it soon becomes the norm. Maybe then the numbers will become larger and more solid. Time will tell BankersHub and Bstuff LLC all rights reserved Visit us at

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