# FDIC FIL-17-2023: Interagency Policy Statement on Allowances for Credit Losses (Revised April 2023)

> Federal · Agency guidance · In force

URL: https://www.frixlaw.com/law-library/statutes/FDIC_FIL23017

## Section

- **Citation:** FDIC FIL-17-2023
- **Heading:** Interagency Policy Statement on Allowances for Credit Losses (Revised April 2023)
- **Jurisdiction:** Federal
- **Kind:** Agency guidance
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** FDIC Financial Institution Letters / Interagency Policy Statement on Allowances for Credit Losses (Revised April 2023)

## Text

This section of the FEDERAL REGISTER
contains regulatory documents having general
applicability and legal effect, most of which
are keyed to and codified in the Code of
Federal Regulations, which is published under
50 titles pursuant to 44 U.S.C. 1510.
The Code of Federal Regulations is sold by
the Superintendent of Documents.
Rules and Regulations
Federal Register
25479
Vol. 88, No. 81
Thursday, April 27, 2023
1 85 FR 32991 (June 1, 2020).
2 44 U.S.C. 3501–3521.
DEPARTMENT OF THE TREASURY
Office of the Comptroller of the
Currency
12 CFR Part 30
FEDERAL RESERVE SYSTEM
12 CFR Part 208
[Docket No. OP–1680]
FEDERAL DEPOSIT INSURANCE
CORPORATION
12 CFR Part 364
RIN 3064–ZA10
NATIONAL CREDIT UNION
ADMINISTRATION
12 CFR Part 741
RIN 3133–AF05
Interagency Policy Statement on
Allowances for Credit Losses (Revised
April 2023)
AGENCY: Office of the Comptroller of the
Currency (OCC), Treasury; Board of
Governors of the Federal Reserve
System (Board); Federal Deposit
Insurance Corporation (FDIC); and
National Credit Union Administration
(NCUA).
ACTION: Final interagency policy
statement.
SUMMARY: The Office of the Comptroller
of the Currency, the Board of Governors
of the Federal Reserve System, the
Federal Deposit Insurance Corporation,
and the National Credit Union
Administration (collectively, the
agencies) are issuing a revised
interagency policy statement on
allowances for credit losses (ACLs)
(revised statement). The agencies are
issuing the revised statement in
response to changes to U.S. generally
accepted accounting principles (GAAP)
as promulgated by the Financial
Accounting Standards Board (FASB) in
Accounting Standards Update (ASU)
2022–02, Financial Instruments—Credit
Losses (Topic 326): Troubled Debt
Restructurings and Vintage Disclosures
issued in March 2022.
DATES: The interagency policy statement
is available on April 27, 2023.
FOR FURTHER INFORMATION CONTACT:
OCC: Amanda Freedle, Deputy
Comptroller and Chief Accountant,
by the Financial
Accounting Standards Board (FASB) in
Accounting Standards Update (ASU)
2022–02, Financial Instruments—Credit
Losses (Topic 326): Troubled Debt
Restructurings and Vintage Disclosures
issued in March 2022.
DATES: The interagency policy statement
is available on April 27, 2023.
FOR FURTHER INFORMATION CONTACT:
OCC: Amanda Freedle, Deputy
Comptroller and Chief Accountant,
(202) 649–6317; or Ashley Rangel,
Deputy Chief Accountant, (202) 649–
5648, Office of the Chief Accountant; or
Kevin Korzeniewski, Counsel, Chief
Counsel’s Office, (202) 649–5490. If you
are deaf, hard of hearing, or have a
speech disability, please dial 7–1–1 to
access telecommunications relay
services.
Board: Lara Lylozian, Deputy
Associate Director and Chief
Accountant, (202) 475–6656; or Kevin
Chiu, Senior Accounting Policy Analyst,
(202) 912–4608, Division of Supervision
and Regulation; or David Imhoff,
Attorney, (202) 452–2249, Legal
Division, Board of Governors of the
Federal Reserve System, 20th and C
Streets NW, Washington, DC 20551. For
users of telephone systems via text
telephone (TTY) or any TTY-based
Telecommunications Relay Services
(TRS), please call 711 from any
telephone, anywhere in the United
States.
FDIC: Shannon Beattie, Chief
Accountant, (202) 898–3952; or Bryan
Jonasson, Deputy Chief Accountant,
(781) 794–5641; or Andrew Overton,
Assistant Chief Accountant, (202)-898–
8922; Division of Risk Management
Supervision; or Catherine Wood,
Counsel, (202) 898–3788, Legal
Division, Federal Deposit Insurance
Corporation, 550 17th Street NW,
Washington, DC 20429.
NCUA: Technical information: Chris
McGrath, Acting Chief Accountant,
Office of Examination and Insurance,
ty Chief Accountant,
(781) 794–5641; or Andrew Overton,
Assistant Chief Accountant, (202)-898–
8922; Division of Risk Management
Supervision; or Catherine Wood,
Counsel, (202) 898–3788, Legal
Division, Federal Deposit Insurance
Corporation, 550 17th Street NW,
Washington, DC 20429.
NCUA: Technical information: Chris
McGrath, Acting Chief Accountant,
Office of Examination and Insurance,
(703) 518–6611 or Legal information:
Marvin Shaw, Staff Attorney, Office of
General Counsel, (703) 548–2778.
National Credit Union Administration,
1775 Duke Street, Alexandria, VA
22314.
SUPPLEMENTARY INFORMATION:
I. Background
On June 1, 2020, the agencies
published in the Federal Register an
interagency policy statement 1 (original
statement) in response to changes to
GAAP as promulgated by the FASB in
ASU 2016–13, Financial Instruments—
Credit Losses (Topic 326): Measurement
of Credit Losses on Financial
Instruments and subsequent
amendments issued between June 2016
and the date of issuance of the original
statement (collectively, Topic 326).
In March 2022, the FASB further
amended Topic 326 with the issuance of
ASU 2022–02, Financial Instruments—
Credit Losses (Topic 326): Troubled
Debt Restructurings and Vintage
Disclosures (ASU 2022–02). ASU 2022–
02 eliminates the recognition and
measurement accounting guidance for
Troubled Debt Restructurings (TDRs) by
creditors upon adoption of Topic 326.
II. Current Actions
To maintain conformance with GAAP
following the issuance of ASU 2022–02,
the agencies are revising the original
statement to remove references to TDRs.
The agencies are also correcting a
citation to a regulation in footnote 4 of
the original statement. No other changes
are being made to the original statement.
Through this notice, the agencies are
publishing the revised statement
Actions
To maintain conformance with GAAP
following the issuance of ASU 2022–02,
the agencies are revising the original
statement to remove references to TDRs.
The agencies are also correcting a
citation to a regulation in footnote 4 of
the original statement. No other changes
are being made to the original statement.
Through this notice, the agencies are
publishing the revised statement.
Consistent with the original
statement, the revised statement
continues to describe the measurement
of expected credit losses under the
current expected credit losses (CECL)
methodology and the accounting for
impairment on available-for-sale debt
securities in accordance with Topic 326;
the design, documentation, and
validation of expected credit loss
estimation processes, including the
internal controls over these processes;
the maintenance of appropriate ACLs;
the responsibilities of boards of
directors and management; and
examiner reviews of ACLs.
III. Paperwork Reduction Act
In accordance with the requirements
of the Paperwork Reduction Act of 1995
(PRA),2 the agencies may not conduct or
sponsor, and the respondent is not
required to respond to, an information
collection unless it displays a currently
valid Office of Management and Budget
(OMB) control number.
The revised statement does not create
any new or revise any existing
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sor, and the respondent is not
required to respond to, an information
collection unless it displays a currently
valid Office of Management and Budget
(OMB) control number.
The revised statement does not create
any new or revise any existing
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Federal Register / Vol. 88, No. 81 / Thursday, April 27, 2023 / Rules and Regulations
1 The FASB issued Accounting Standards Update
(ASU) 2016–13 on June 16, 2016. The following
updates were published after the issuance of ASU
2016–13: ASU 2018–19—Codification
Improvements to Topic 326, Financial
Instruments—Credit Losses; ASU 2019–04—
Codification Improvements to Topic 326, Financial
Instruments—Credit Losses, Topic 815, Derivatives
and Hedging, and Topic 825, Financial
Instruments; ASU 2019–05—Financial
Instruments—Credit Losses (Topic 326): Targeted
Transition Relief; ASU 2019–10—Financial
Instruments—Credit Losses (Topic 326), Derivatives
and Hedging (Topic 815), and Leases (Topic 842):
Effective Dates; ASU 2019–11—Codification
Improvements to Topic 326, Financial
Instruments—Credit Losses; and ASU 2022–02,
Financial Instruments—Credit Losses (Topic 326):
Troubled Debt Restructurings and Vintage
Disclosures. Additionally, institutions may refer to
FASB Staff Q&A-Topic 326, No. 1, Whether the
Weighted-Average Remaining Maturity Method is
an Acceptable Method to Estimate Expected Credit
Losses, and FASB Staff Q&A-Topic 326, No. 2,
Developing an Estimate of Expected Credit Losses
on Financial Assets.
2 U.S. branches and agencies of foreign banking
organizations may choose to, but are not required
to, maintain ACLs on a branch or agency level.
These institutions should refer to the instructions
for the FFIEC 002, Report of Assets and Liabilities
of U.S
mate Expected Credit
Losses, and FASB Staff Q&A-Topic 326, No. 2,
Developing an Estimate of Expected Credit Losses
on Financial Assets.
2 U.S. branches and agencies of foreign banking
organizations may choose to, but are not required
to, maintain ACLs on a branch or agency level.
These institutions should refer to the instructions
for the FFIEC 002, Report of Assets and Liabilities
of U.S. Branches and Agencies of Foreign Banks;
Supervision and Regulation (SR) Letter 95–4,
Allowance for Loan and Lease Losses for U.S.
Branches and Agencies of Foreign Banking
Organizations; and SR Letter 95–42, Allowance for
Loan and Lease Losses for U.S. Branches and
Agencies of Foreign Banking Organizations.
3 As noted in Accounting Standards Update
2019–10, FASB ASC Topic 326 is effective for fiscal
years beginning after December 15, 2019, including
interim periods within those fiscal years, for public
business entities that meet the definition of a
Securities Exchange Commission (SEC) filer,
excluding entities eligible to be small reporting
companies as defined by the SEC. FASB ASC Topic
326 is effective for all other entities for fiscal years
beginning after December 15, 2022, including
interim periods within those fiscal years. For all
entities, early application of FASB ASC Topic 326
is permitted as set forth in ASU 2016–13.
4 For FDIC-insured depository institutions,
section 37(a) of the Federal Deposit Insurance Act
(12 U.SC. 1831n(a)) states that, in general, the
accounting principles applicable to the
Consolidated Reports of Condition and Income (Call
Report) ‘‘shall be uniform and consistent with
generally accepted accounting principles.’’ Section
202(a)(6)(C) of the Federal Credit Union Act (12
U.S.C
3.
4 For FDIC-insured depository institutions,
section 37(a) of the Federal Deposit Insurance Act
(12 U.SC. 1831n(a)) states that, in general, the
accounting principles applicable to the
Consolidated Reports of Condition and Income (Call
Report) ‘‘shall be uniform and consistent with
generally accepted accounting principles.’’ Section
202(a)(6)(C) of the Federal Credit Union Act (12
U.S.C. 1782(a)(6)(C)) establishes the same standard
for federally insured credit unions with assets of
$10 million or greater, providing that, in general,
the ‘‘[a]ccounting principles applicable to reports or
statements required to be filed with the [NCUA]
Board by each insured credit union shall be
uniform and consistent with generally accepted
accounting principles.’’ Furthermore, regardless of
asset size, all federally insured credit unions must
comply with GAAP for certain financial reporting
requirements relating to charges for loan losses. See
12 CFR 702.113(d).
5 FDIC-insured depository institutions should
refer to the Interagency Guidelines Establishing
Standards for Safety and Soundness adopted by
their primary federal regulator pursuant to section
39 of the Federal Deposit Insurance Act (12 U.S.C.
1831p–1) as follows: For national banks and federal
savings associations, Appendix A to 12 CFR part 30;
for state member banks, Appendix D to 12 CFR part
208; and for state nonmember banks, state savings
associations, and insured state-licensed branches of
foreign banks, Appendix A to 12 CFR part 364.
Federally insured credit unions should refer to
section 206(b)(1) of the Federal Credit Union Act
(12 U.S.C. 1786) and 12 CFR 741.3.
6 FASB ASC Topic 326 defines the amortized cost
basis as the amount at which a financing receivable
or investment is originated or acquired, adjusted for
applicable accrued interest, accretion, or
amortization of premium, discount, and net
deferred fees or costs, collection of cash, write-offs,
foreign exchange, and fair value hedge accounting
adjustments
(12 U.S.C. 1786) and 12 CFR 741.3.
6 FASB ASC Topic 326 defines the amortized cost
basis as the amount at which a financing receivable
or investment is originated or acquired, adjusted for
applicable accrued interest, accretion, or
amortization of premium, discount, and net
deferred fees or costs, collection of cash, write-offs,
foreign exchange, and fair value hedge accounting
adjustments.
7 See the final guidance attached to OCC Bulletin
2012–18, Guidance on Due Diligence Requirements
in Determining Whether Securities Are Eligible for
Investment (for national banks and federal savings
associations), 12 CFR part 1, Investment Securities
(for national banks), and 12 CFR part 160, Lending
and Investment (for federal savings associations).
Federal credit unions should refer to 12 CFR part
703, Investment and Deposit Activities. Federally
insured, state-chartered credit unions should refer
to applicable state laws and regulations, as well as
12 CFR 741.219 (‘‘investment requirements’’).
collections of information under the
PRA. Therefore, no information
collection request will be submitted to
the OMB for review.
IV. Final Interagency Policy Statement
on Allowances for Credit Losses
The text of the final interagency
Policy Statement is as follows:
Interagency Policy Statement on
Allowances for Credit Losses (Revised
April 2023)
Purpose
The Office of the Comptroller of the
Currency (OCC), the Board of Governors
of the Federal Reserve System (FRB), the
Federal Deposit Insurance Corporation
(FDIC), and the National Credit Union
Administration (NCUA) (collectively,
the agencies) are issuing this
Interagency Policy Statement on
Allowances for Credit Losses (hereafter,
the policy statement) to promote
consistency in the interpretation and
application of Financial Accounting
Standards Board (FASB) Accounting
Standards Update 2016–13, Financial
Instruments—Credit Losses (Topic 326):
Measurement of Credit Losses on
Financial Instruments, as well as the
amendments issued since
this
Interagency Policy Statement on
Allowances for Credit Losses (hereafter,
the policy statement) to promote
consistency in the interpretation and
application of Financial Accounting
Standards Board (FASB) Accounting
Standards Update 2016–13, Financial
Instruments—Credit Losses (Topic 326):
Measurement of Credit Losses on
Financial Instruments, as well as the
amendments issued since June 2016.1
These updates are codified in
Accounting Standards Codification
(ASC) Topic 326, Financial
Instruments—Credit Losses (FASB ASC
Topic 326). FASB ASC Topic 326
applies to all banks, savings
associations, credit unions, and
financial institution holding companies
(collectively, institutions), regardless of
size, that file regulatory reports for
which the reporting requirements
conform to U.S. generally accepted
accounting principles (GAAP).2 This
policy statement describes the
measurement of expected credit losses
in accordance with FASB ASC Topic
326; the design, documentation, and
validation of expected credit loss
estimation processes, including the
internal controls over these processes;
the maintenance of appropriate
allowances for credit losses (ACLs); the
responsibilities of boards of directors
and management; and examiner reviews
of ACLs.
This policy statement is effective at
the time of each institution’s adoption
of FASB ASC Topic 326.3 The following
policy statements are no longer effective
for an institution upon its adoption of
FASB ASC Topic 326: the December
2006 Interagency Policy Statement on
the Allowance for Loan and Lease
Losses; the July 2001 Policy Statement
on Allowance for Loan and Lease Losses
Methodologies and Documentation for
Banks and Savings Institutions; and the
NCUA’s May 2002 Interpretive Ruling
and Policy Statement 02–3, Allowance
for Loan and Lease Losses
Methodologies and Documentation for
Federally Insured Credit Unions
(collectively, ALLL Policy Statements)
e Allowance for Loan and Lease
Losses; the July 2001 Policy Statement
on Allowance for Loan and Lease Losses
Methodologies and Documentation for
Banks and Savings Institutions; and the
NCUA’s May 2002 Interpretive Ruling
and Policy Statement 02–3, Allowance
for Loan and Lease Losses
Methodologies and Documentation for
Federally Insured Credit Unions
(collectively, ALLL Policy Statements).
After FASB ASC Topic 326 is effective
for all institutions, the agencies will
rescind the ALLL Policy Statements.
The principles described in this
policy statement are consistent with
GAAP, applicable regulatory reporting
requirements,4 safe and sound banking
practices, and the agencies’ codified
guidelines establishing standards for
safety and soundness.5 The operational
and managerial standards included in
those guidelines, which address such
matters as internal controls and
information systems, an internal audit
system, loan documentation, credit
underwriting, asset quality, and
earnings, should be appropriate for an
institution’s size and the nature, scope,
and risk of its activities.
Scope
This policy statement describes the
current expected credit losses (CECL)
methodology for determining the ACLs
applicable to loans held-for-investment,
net investments in leases, and held-to-
maturity debt securities accounted for at
amortized cost.6 It also describes the
estimation of the ACL for an available-
for-sale debt security in accordance with
FASB ASC Subtopic 326–30
es.
Scope
This policy statement describes the
current expected credit losses (CECL)
methodology for determining the ACLs
applicable to loans held-for-investment,
net investments in leases, and held-to-
maturity debt securities accounted for at
amortized cost.6 It also describes the
estimation of the ACL for an available-
for-sale debt security in accordance with
FASB ASC Subtopic 326–30. This
policy statement does not address or
supersede existing agency requirements
or guidance regarding appropriate due
diligence in connection with the
purchase or sale of assets or determining
whether assets are permissible to be
purchased or held by institutions.7
The CECL methodology described in
FASB ASC Topic 326 applies to
financial assets measured at amortized
cost, net investments in leases, and off-
balance-sheet credit exposures
(collectively, financial assets) including:
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8 Refer to FASB ASC Subtopic 326–30, Financial
Instruments—Credit Losses—Available-for-Sale
Debt Securities (FASB ASC Subtopic 326–30).
9 Consistent with FASB ASC Topic 326, an
institution’s determination of the contractual term
should reflect the financial asset’s contractual life
adjusted for prepayments and renewal and
extension options that are not unconditionally
cancellable by the institution. For more
information, see the ‘‘Contractual Term of a
Financial Asset’’ section in this policy statement.
10 Recoveries are a component of management’s
estimation of the net amount expected to be
collected for a financial asset. Expected recoveries
of amounts previously written off or expected to be
written off that are included in ACLs may not
exceed the aggregate amounts previously written off
or expected to be written off
ractual Term of a
Financial Asset’’ section in this policy statement.
10 Recoveries are a component of management’s
estimation of the net amount expected to be
collected for a financial asset. Expected recoveries
of amounts previously written off or expected to be
written off that are included in ACLs may not
exceed the aggregate amounts previously written off
or expected to be written off. In some
circumstances, the ACL for a specific portfolio or
loan may be negative because the amount expected
to be collected, including expected recoveries,
exceeds the financial asset’s amortized cost basis.
11 Consistent with FASB ASC Topic 326, this
policy statement uses the verbs ‘‘write off’’ and
‘‘written off’’ and the noun ‘‘write-off.’’ These terms
are used interchangeably with ‘‘charge off,’’
‘‘charged off,’’ and ‘‘charge-off,’’ respectively, in the
agencies’ regulations, guidance, and regulatory
reporting instructions.
12 Various loss-rate methods may be used to
estimate expected credit losses under the CECL
methodology. These include the weighted-average
remaining maturity (WARM) method, vintage
analysis, and the snapshot or open pool method.
• Financing receivables such as loans
held-for-investment;
• Overdrawn deposit accounts (i.e.
overdrafts) that are reclassified as held-
for-investment loans;
• Held-to-maturity debt securities;
• Receivables that result from
revenue transactions within the scope of
Topic 606 on revenue from contracts
with customers and Topic 610 on other
income, which applies, for example, to
the sale of foreclosed real estate;
• Reinsurance recoverables that result
from insurance transactions within the
scope of Topic 944 on insurance;
• Receivables related to repurchase
agreements and securities lending
agreements within the scope of Topic
860 on transfers and servicing;
• Net investments in leases
recognized by a lessor in accordance
with Topic 842 on leases; and
• Off-balance-sheet credit exposures
including off-balance-sheet loan
commitments
from insurance transactions within the
scope of Topic 944 on insurance;
• Receivables related to repurchase
agreements and securities lending
agreements within the scope of Topic
860 on transfers and servicing;
• Net investments in leases
recognized by a lessor in accordance
with Topic 842 on leases; and
• Off-balance-sheet credit exposures
including off-balance-sheet loan
commitments, standby letters of credit,
financial guarantees not accounted for
as insurance, and other similar
instruments except for those within the
scope of Topic 815 on derivatives and
hedging.
The CECL methodology does not
apply to the following financial assets:
• Financial assets measured at fair
value through net income, including
those assets for which the fair value
option has been elected;
• Available-for-sale debt securities; 8
• Loans held-for-sale;
• Policy loan receivables of an
insurance entity;
• Loans and receivables between
entities under common control; and
• Receivables arising from operating
leases.
Measurement of ACLs for Loans,
Leases, Held-to-Maturity Debt
Securities, and Off-Balance-Sheet
Credit Exposures
Overview of ACLs
An ACL is a valuation account that is
deducted from, or added to, the
amortized cost basis of financial assets
to present the net amount expected to be
collected over the contractual term 9 of
the assets. In estimating the net amount
expected to be collected, management
should consider the effects of past
events, current conditions, and
reasonable and supportable forecasts on
the collectibility of the institution’s
financial assets.10 FASB ASC Topic 326
requires management to use relevant
forward-looking information and
expectations drawn from reasonable and
supportable forecasts when estimating
expected credit losses.
ACLs are evaluated as of the end of
each reporting period. The methods
used to determine ACLs generally
should be applied consistently over
time and reflect management’s current
expectations of credit losses
SC Topic 326
requires management to use relevant
forward-looking information and
expectations drawn from reasonable and
supportable forecasts when estimating
expected credit losses.
ACLs are evaluated as of the end of
each reporting period. The methods
used to determine ACLs generally
should be applied consistently over
time and reflect management’s current
expectations of credit losses. Changes to
ACLs resulting from these periodic
evaluations are recorded through
increases or decreases to the related
provisions for credit losses (PCLs).
When available information confirms
that specific loans, securities, other
assets, or portions thereof, are
uncollectible, these amounts should be
promptly written off 11 against the
related ACLs.
Estimating appropriate ACLs involves
a high degree of management judgment
and is inherently imprecise. An
institution’s process for determining
appropriate ACLs may result in a range
of estimates for expected credit losses.
An institution should support and
record its best estimate within the range
of expected credit losses.
Collective Evaluation of Expected Losses
FASB ASC Topic 326 requires
expected losses to be evaluated on a
collective, or pool, basis when financial
assets share similar risk characteristics.
Financial assets may be segmented
based on one characteristic, or a
combination of characteristics.
Examples of risk characteristics
relevant to this evaluation include, but
are not limited to:
• Internal or external credit scores or
credit ratings;
• Risk ratings or classifications;
• Financial asset type;
• Collateral type;
• Size;
• Effective interest rate;
• Term;
• Geographical location;
• Industry of the borrower; and
• Vintage.
Other risk characteristics that may be
relevant for segmenting held-to-maturity
debt securities include issuer, maturity,
coupon rate, yield, payment frequency,
source of repayment, bond payment
structure, and embedded options
ions;
• Financial asset type;
• Collateral type;
• Size;
• Effective interest rate;
• Term;
• Geographical location;
• Industry of the borrower; and
• Vintage.
Other risk characteristics that may be
relevant for segmenting held-to-maturity
debt securities include issuer, maturity,
coupon rate, yield, payment frequency,
source of repayment, bond payment
structure, and embedded options.
FASB ASC Topic 326 does not
prescribe a process for segmenting
financial assets for collective evaluation.
Therefore, management should exercise
judgment when establishing appropriate
segments or pools. Management should
evaluate financial asset segmentation on
an ongoing basis to determine whether
the financial assets in the pool continue
to share similar risk characteristics. If a
financial asset ceases to share risk
characteristics with other assets in its
segment, it should be moved to a
different segment with assets sharing
similar risk characteristics if such a
segment exists.
If a financial asset does not share
similar risk characteristics with other
assets, expected credit losses for that
asset should be evaluated individually.
Individually evaluated assets should not
be included in a collective assessment
of expected credit losses.
Estimation Methods for Expected Credit
Losses
FASB ASC Topic 326 does not require
the use of a specific loss estimation
method for purposes of determining
ACLs. Various methods may be used to
estimate the expected collectibility of
financial assets, with those methods
generally applied consistently over
time. The same loss estimation method
does not need to be applied to all
financial assets. Management is not
precluded from selecting a different
method when it determines the method
will result in a better estimate of ACLs
s of determining
ACLs. Various methods may be used to
estimate the expected collectibility of
financial assets, with those methods
generally applied consistently over
time. The same loss estimation method
does not need to be applied to all
financial assets. Management is not
precluded from selecting a different
method when it determines the method
will result in a better estimate of ACLs.
Management may use a loss-rate
method,12 probability of default/loss
given default (PD/LGD) method, roll-
rate method, discounted cash flow
method, a method that uses aging
schedules, or another reasonable
method to estimate expected credit
losses. The selected method(s) should
be appropriate for the financial assets
being evaluated, consistent with the
institution’s size and complexity.
Contractual Term of a Financial Asset
FASB ASC Topic 326 requires an
institution to measure estimated
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13 For banks and savings associations, adversely
classified or graded loans are loans rated
‘‘substandard’’ (or its equivalent) or worse under
the institution’s loan classification system. For
credit unions, adversely graded loans are loans
included in the more severely graded categories
under the institution’s credit grading system, i.e.,
those loans that tend to be included in the credit
union’s ‘‘watch lists.’’ Criteria related to the
classification of an investment security may be
found in the interagency policy statement Uniform
Agreement on the Classification and Appraisal of
Securities Held by Depository Institutions issued by
the FDIC, Board, and OCC in October 2013.
expected credit losses over the
contractual term of its financial assets,
considering expected prepayments
’s ‘‘watch lists.’’ Criteria related to the
classification of an investment security may be
found in the interagency policy statement Uniform
Agreement on the Classification and Appraisal of
Securities Held by Depository Institutions issued by
the FDIC, Board, and OCC in October 2013.
expected credit losses over the
contractual term of its financial assets,
considering expected prepayments.
Renewals, extensions, and
modifications are excluded from the
contractual term of a financial asset for
purposes of estimating the ACL unless
the renewal and extension options are
part of the original or modified contract
and are not unconditionally cancellable
by the institution. If such renewal or
extension options are present,
management must evaluate the
likelihood of a borrower exercising
those options when determining the
contractual term.
Historical Loss Information
Historical loss information generally
provides a basis for an institution’s
assessment of expected credit losses.
Historical loss information may be
based on internal information, external
information, or a combination of both.
Management should consider whether
the historical loss information may need
to be adjusted for differences in current
asset specific characteristics such as
differences in underwriting standards,
portfolio mix, or when historical asset
terms do not reflect the contractual
terms of the financial assets being
evaluated as of the reporting date.
Management should then consider
whether further adjustments to
historical loss information are needed to
reflect the extent to which current
conditions and reasonable and
supportable forecasts differ from the
conditions that existed during the
historical loss period. Adjustments to
historical loss information may be
quantitative or qualitative in nature and
should reflect changes to relevant data
(such as changes in unemployment
rates, delinquency, or other factors
associated with the financial assets)
extent to which current
conditions and reasonable and
supportable forecasts differ from the
conditions that existed during the
historical loss period. Adjustments to
historical loss information may be
quantitative or qualitative in nature and
should reflect changes to relevant data
(such as changes in unemployment
rates, delinquency, or other factors
associated with the financial assets).
Reasonable and Supportable Forecasts
When estimating expected credit
losses, FASB ASC Topic 326 requires
management to consider forward-
looking information that is both
reasonable and supportable and relevant
to assessing the collectibility of cash
flows. Reasonable and supportable
forecasts may extend over the entire
contractual term of a financial asset or
a period shorter than the contractual
term. FASB ASC Topic 326 does not
prescribe a specific method for
determining reasonable and supportable
forecasts nor does it include bright lines
for establishing a minimum or
maximum length of time for reasonable
and supportable forecast period(s).
Judgment is necessary in determining an
appropriate period(s) for each
institution. Reasonable and supportable
forecasts may vary by portfolio segment
or individual forecast input. These
forecasts may include data from internal
sources, external sources, or a
combination of both. Management is not
required to search for all possible
information nor incur undue cost and
effort to collect data for its forecasts.
However, reasonably available and
relevant information should not be
ignored in assessing the collectibility of
cash flows. Management should
evaluate the appropriateness of the
reasonable and supportable forecast
period(s) each reporting period,
consistent with other inputs used in the
estimation of expected credit losses.
Institutions may develop reasonable
and supportable forecasts by using one
or more economic scenarios
evant information should not be
ignored in assessing the collectibility of
cash flows. Management should
evaluate the appropriateness of the
reasonable and supportable forecast
period(s) each reporting period,
consistent with other inputs used in the
estimation of expected credit losses.
Institutions may develop reasonable
and supportable forecasts by using one
or more economic scenarios. FASB ASC
Topic 326 does not require the use of
multiple economic scenarios; however,
institutions are not precluded from
considering multiple economic
scenarios when estimating expected
credit losses.
Reversion
When the contractual term of a
financial asset extends beyond the
reasonable and supportable period,
FASB ASC Topic 326 requires reverting
to historical loss information, or an
appropriate proxy, for those periods
beyond the reasonable and supportable
forecast period (often referred to as the
reversion period). Management may
revert to historical loss information for
each individual forecast input or based
on the entire estimate of loss.
FASB ASC Topic 326 does not require
the application of a specific reversion
technique or use of a specific reversion
period. Reversion to historical loss
information may be immediate, occur
on a straight-line basis, or use any
systematic, rational method.
Management may apply different
reversion techniques depending on the
economic environment or the financial
asset portfolio. Reversion techniques are
not accounting policy elections and
should be evaluated for appropriateness
each reporting period, consistent with
other inputs used in the estimation of
expected credit losses.
FASB ASC Topic 326 does not specify
the historical loss information that is
used in the reversion period. This
historical loss information may be based
on long-term average losses or on losses
that occurred during a particular
historical period(s). Management may
use multiple historical periods that are
not sequential
t with
other inputs used in the estimation of
expected credit losses.
FASB ASC Topic 326 does not specify
the historical loss information that is
used in the reversion period. This
historical loss information may be based
on long-term average losses or on losses
that occurred during a particular
historical period(s). Management may
use multiple historical periods that are
not sequential. Management should not
adjust historical loss information for
existing economic conditions or
expectations of future economic
conditions for periods beyond the
reasonable and supportable period.
However, management should consider
whether the historical loss information
may need to be adjusted for differences
in current asset specific characteristics
such as differences in underwriting
standards, portfolio mix, or when
historical asset terms do not reflect the
contractual terms of the financial assets
being evaluated as of the reporting date.
Qualitative Factor Adjustments
The estimation of ACLs should reflect
consideration of all significant factors
relevant to the expected collectibility of
the institution’s financial assets as of the
reporting date. Management may begin
the expected credit loss estimation
process by determining its historical
loss information or obtaining reliable
and relevant historical loss proxy data
for each segment of financial assets with
similar risk characteristics. Historical
credit losses (or even recent trends in
losses) generally do not, by themselves,
form a sufficient basis to determine the
appropriate levels for ACLs.
Management should consider the
need to qualitatively adjust expected
credit loss estimates for information not
already captured in the loss estimation
process. These qualitative factor
adjustments may increase or decrease
management’s estimate of expected
credit losses. Adjustments should not be
made for information that has already
been considered and included in the
loss estimation process
gement should consider the
need to qualitatively adjust expected
credit loss estimates for information not
already captured in the loss estimation
process. These qualitative factor
adjustments may increase or decrease
management’s estimate of expected
credit losses. Adjustments should not be
made for information that has already
been considered and included in the
loss estimation process.
Management should consider the
qualitative factors that are relevant to
the institution as of the reporting date,
which may include, but are not limited
to:
• The nature and volume of the
institution’s financial assets;
• The existence, growth, and effect of
any concentrations of credit;
• The volume and severity of past
due financial assets, the volume of
nonaccrual assets, and the volume and
severity of adversely classified or graded
assets; 13
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14 See the ‘‘Collateral-Dependent Financial
Assets’’ section of this policy statement for more
information on collateral-dependent loans.
15 Changes in economic and business conditions
and developments included in qualitative factor
adjustments are limited to those that affect the
collectibility of an institution’s financial assets and
are relevant to the institution’s financial asset
portfolios. For example, an economic factor for
current or forecasted unemployment at the national
or state level may indicate a strong job market based
on low national or state unemployment rates, but
a local unemployment rate, which may be
significantly higher, for example, because of the
actual or forecasted loss of a major local employer
may be more relevant to the collectibility of an
institution’s financial assets
nomic factor for
current or forecasted unemployment at the national
or state level may indicate a strong job market based
on low national or state unemployment rates, but
a local unemployment rate, which may be
significantly higher, for example, because of the
actual or forecasted loss of a major local employer
may be more relevant to the collectibility of an
institution’s financial assets.
16 This list is not all-inclusive, and all of the
factors listed may not be relevant to all institutions.
17 The agencies, at times, prescribe specific
regulatory reporting requirements that fall within a
range of acceptable practice under GAAP. These
specific reporting requirements, such as the
requirement for institutions to apply the practical
expedient in ASC 326–20–35–5 for collateral-
dependent loans, regardless of whether foreclosure
is probable, have been adopted to achieve safety
and soundness and other public policy objectives
and to ensure comparability among institutions.
The regulatory reporting requirement to apply the
practical expedient for collateral-dependent
financial assets is consistent with the agencies’
long-standing practice for collateral-dependent
loans, and it continues to be limited to collateral-
dependent loans. It does not apply to other
financial assets such as held-to-maturity debt
securities that are collateral-dependent.
18 For more information on regulatory
expectations related to the use of appraisals and
evaluations, see the Interagency Appraisal and
Evaluation Guidelines published on December 10,
2010
lateral-dependent
loans, and it continues to be limited to collateral-
dependent loans. It does not apply to other
financial assets such as held-to-maturity debt
securities that are collateral-dependent.
18 For more information on regulatory
expectations related to the use of appraisals and
evaluations, see the Interagency Appraisal and
Evaluation Guidelines published on December 10,
2010. Insured depository institutions should also
refer to the interagency regulations on appraisals
adopted by their primary federal regulator as
follows: For national banks and federal savings
associations, Subpart C of 12 CFR part 34; for state
member banks, 12 CFR parts 208 and 225; for state
nonmember banks, state savings associations, and
insured state-licensed branches of foreign banks, 12
CFR part 323; and for federally insured credit
unions, 12 CFR part 722.
• The value of the underlying
collateral for loans that are not
collateral-dependent; 14
• The institution’s lending policies
and procedures, including changes in
underwriting standards and practices
for collections, write-offs, and
recoveries;
• The quality of the institution’s
credit review function;
• The experience, ability, and depth
of the institution’s lending, investment,
collection, and other relevant
management and staff;
• The effect of other external factors
such as the regulatory, legal and
technological environments;
competition; and events such as natural
disasters; and
• Actual and expected changes in
international, national, regional, and
local economic and business conditions
and developments 15 in which the
institution operates that affect the
collectibility of financial assets
gement and staff;
• The effect of other external factors
such as the regulatory, legal and
technological environments;
competition; and events such as natural
disasters; and
• Actual and expected changes in
international, national, regional, and
local economic and business conditions
and developments 15 in which the
institution operates that affect the
collectibility of financial assets.
Management may consider the
following additional qualitative factors
specific to held-to-maturity debt
securities as of the reporting date: 16
• The effect of recent changes in
investment strategies and policies;
• The existence and effect of loss
allocation methods, the definition of
default, the impact of performance and
market value triggers, and credit and
liquidity enhancements associated with
debt securities;
• The effect of structural
subordination and collateral
deterioration on tranche performance of
debt securities;
• The quality of underwriting for any
collateral backing debt securities; and
• The effect of legal covenants
associated with debt securities.
Changes in the level of an institution’s
ACLs may not always be directionally
consistent with changes in the level of
qualitative factor adjustments due to the
incorporation of reasonable and
supportable forecasts in estimating
expected losses. For example, if
improving credit quality trends are
evident throughout an institution’s
portfolio in recent years, but
management’s evaluation of reasonable
and supportable forecasts indicates
expected deterioration in credit quality
of the institution’s financial assets
during the forecast period, the ACL as
a percentage of the portfolio may
increase
asts in estimating
expected losses. For example, if
improving credit quality trends are
evident throughout an institution’s
portfolio in recent years, but
management’s evaluation of reasonable
and supportable forecasts indicates
expected deterioration in credit quality
of the institution’s financial assets
during the forecast period, the ACL as
a percentage of the portfolio may
increase.
Collateral-Dependent Financial Assets
FASB ASC Topic 326 describes a
collateral-dependent asset as a financial
asset for which the repayment is
expected to be provided substantially
through the operation or sale of the
collateral when the borrower, based on
management’s assessment, is
experiencing financial difficulty as of
the reporting date. For regulatory
reporting purposes, the ACL for a
collateral-dependent loan is measured
using the fair value of collateral,
regardless of whether foreclosure is
probable.17
When estimating the ACL for a
collateral-dependent loan, FASB ASC
Topic 326 requires the fair value of
collateral to be adjusted to consider
estimated costs to sell if repayment or
satisfaction of the loan depends on the
sale of the collateral. ACL adjustments
for estimated costs to sell are not
appropriate when the repayment of a
collateral-dependent loan is expected
from the operation of the collateral.
The fair value of collateral securing a
collateral-dependent loan may change
over time. If the fair value of the
collateral as of the ACL evaluation date
has decreased since the previous ACL
evaluation date, the ACL should be
increased to reflect the additional
decrease in the fair value of the
collateral. Likewise, if the fair value of
the collateral has increased as of the
ACL evaluation date, the increase in the
fair value of the collateral is reflected
through a reduction in the ACL. Any
negative ACL that results is capped at
the amount previously written off
revious ACL
evaluation date, the ACL should be
increased to reflect the additional
decrease in the fair value of the
collateral. Likewise, if the fair value of
the collateral has increased as of the
ACL evaluation date, the increase in the
fair value of the collateral is reflected
through a reduction in the ACL. Any
negative ACL that results is capped at
the amount previously written off.
Changes in the fair value of collateral
described herein should be supported
and documented through recent
appraisals or evaluations.18
Purchased Credit-Deteriorated Assets
FASB ASC Topic 326 introduces the
concept of purchased credit-deteriorated
(PCD) assets. PCD assets are acquired
financial assets that, at acquisition, have
experienced more-than-insignificant
deterioration in credit quality since
origination. FASB ASC Topic 326 does
not provide a prescriptive definition of
more-than-insignificant credit
deterioration. The acquiring
institution’s management should
establish and document a reasonable
process to consistently determine what
constitutes a more-than-insignificant
deterioration in credit quality.
When recording the acquisition of
PCD assets, the amount of expected
credit losses as of the acquisition date
is added to the purchase price of the
financial assets rather than recording
these losses through PCLs. This
establishes the amortized cost basis of
the PCD assets. Any difference between
the unpaid principal balance of the PCD
assets and the amortized cost basis of
the assets as of the acquisition date is
the non-credit discount or premium.
The initial ACL and non-credit discount
or premium determined on a collective
basis at the acquisition date are
allocated to the individual PCD assets.
After acquisition, ACLs for PCD assets
should be adjusted at each reporting
date with a corresponding debit or
credit to the PCLs to reflect
management’s current estimate of
expected credit losses
e is
the non-credit discount or premium.
The initial ACL and non-credit discount
or premium determined on a collective
basis at the acquisition date are
allocated to the individual PCD assets.
After acquisition, ACLs for PCD assets
should be adjusted at each reporting
date with a corresponding debit or
credit to the PCLs to reflect
management’s current estimate of
expected credit losses. The non-credit
discount recorded at acquisition will be
accreted into interest income over the
remaining life of the PCD assets on a
level-yield basis.
Financial Assets With Collateral
Maintenance Agreements
Institutions may have financial assets
that are secured by collateral (such as
debt securities) and are subject to
collateral maintenance agreements
requiring the borrower to continuously
replenish the amount of collateral
securing the asset. If the fair value of the
collateral declines, the borrower is
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19 For example, an institution enters into a reverse
repurchase agreement with a collateral maintenance
agreement. Management may not need to record the
expected credit losses at each reporting date as long
as the fair value of the security collateral is greater
than the amortized cost basis of the reverse
repurchase agreement. Refer to ASC 326–20–55–46
for more information.
20 The accounting policy elections related to
accrued interest receivable that are described in this
paragraph also apply to accrued interest receivable
for an available-for-sale debt security that, for
purposes of identifying and measuring an
impairment, exclude the applicable accrued interest
from both the fair value and amortized cost basis
of the securities
55–46
for more information.
20 The accounting policy elections related to
accrued interest receivable that are described in this
paragraph also apply to accrued interest receivable
for an available-for-sale debt security that, for
purposes of identifying and measuring an
impairment, exclude the applicable accrued interest
from both the fair value and amortized cost basis
of the securities.
21 Management should not rely solely on credit
rating agencies but should also make its own
assessment based on third party research, default
statistics, and other data that may indicate a decline
in credit rating.
22 The ACL associated with off-balance-sheet
credit exposures is included in the ‘‘Allowance for
credit losses on off-balance-sheet credit exposures’’
in Schedule RC–G—Other Liabilities in the Call
Report and in the Liabilities schedule in NCUA Call
Report Form 5300.
required to provide additional collateral
as specified by the agreement.
FASB ASC Topic 326 includes a
practical expedient for financial assets
with collateral maintenance agreements
where the borrower is required to
provide collateral greater than or equal
to the amortized cost basis of the asset
and is expected to continuously
replenish the collateral. In those cases,
management may elect the collateral
maintenance practical expedient and
measure expected credit losses for these
qualifying assets based on the fair value
of the collateral.19 If the fair value of the
collateral is greater than the amortized
cost basis of the financial asset and
management expects the borrower to
replenish collateral as needed,
management may record an ACL of zero
for the financial asset when the
collateral maintenance practical
expedient is applied
expected credit losses for these
qualifying assets based on the fair value
of the collateral.19 If the fair value of the
collateral is greater than the amortized
cost basis of the financial asset and
management expects the borrower to
replenish collateral as needed,
management may record an ACL of zero
for the financial asset when the
collateral maintenance practical
expedient is applied. Similarly, if the
fair value of the collateral is less than
the amortized cost basis of the financial
asset and management expects the
borrower to replenish collateral as
needed, the ACL is limited to the
difference between the fair value of the
collateral and the amortized cost basis
of the asset as of the reporting date
when applying the collateral
maintenance practical expedient.
Accrued Interest Receivable
FASB ASC Topic 326 includes
accrued interest receivable in the
amortized cost basis of a financial asset.
As a result, accrued interest receivable
is included in the amounts for which
ACLs are estimated. Generally, any
accrued interest receivable that is not
collectible is written off against the
related ACL.
FASB ASC Topic 326 permits a series
of independent accounting policy
elections related to accrued interest
receivable that alter the accounting
treatment described in the preceding
paragraph. These elections are made
upon adoption of FASB ASC Topic 326
and may differ by class of financing
receivable or major security-type level.
The available accounting policy
elections 20 are:
• Management may elect not to
measure ACLs for accrued interest
receivable if uncollectible accrued
interest is written off in a timely
manner. Management should define and
document its definition of a timely
write-off.
• Management may elect to write off
accrued interest receivable by either
reversing interest income, recognizing
the loss through PCLs, or through a
combination of both methods
ement may elect not to
measure ACLs for accrued interest
receivable if uncollectible accrued
interest is written off in a timely
manner. Management should define and
document its definition of a timely
write-off.
• Management may elect to write off
accrued interest receivable by either
reversing interest income, recognizing
the loss through PCLs, or through a
combination of both methods.
• Management may elect to separately
present accrued interest receivable from
the associated financial asset in its
regulatory reports and financial
statements, if applicable. The accrued
interest receivable is presented net of
ACLs (if any).
Financial Assets With Zero Credit Loss
Expectations
There may be certain financial assets
for which the expectation of credit loss
is zero after evaluating historical loss
information, making necessary
adjustments for current conditions and
reasonable and supportable forecasts,
and considering any collateral or
guarantee arrangements that are not
free-standing contracts. Factors to
consider when evaluating whether
expectations of zero credit loss are
appropriate may include, but are not
limited to:
• A long history of zero credit loss;
• A financial asset that is fully
secured by cash or cash equivalents;
• High credit ratings from rating
agencies with no expected future
downgrade; 21
• Principal and interest payments
that are guaranteed by the U.S.
government;
• The issuer, guarantor, or sponsor
can print its own currency and the
currency is held by other central banks
as reserve currency; and
• The interest rate on the security is
recognized as a risk-free rate.
A loan that is fully secured by cash or
cash equivalents, such as certificates of
deposit issued by the lending
institution, would likely have zero
credit loss expectations. Similarly, the
guaranteed portion of a U.S
r
can print its own currency and the
currency is held by other central banks
as reserve currency; and
• The interest rate on the security is
recognized as a risk-free rate.
A loan that is fully secured by cash or
cash equivalents, such as certificates of
deposit issued by the lending
institution, would likely have zero
credit loss expectations. Similarly, the
guaranteed portion of a U.S. Small
Business Administration (SBA) loan or
security purchased on the secondary
market through the SBA’s fiscal and
transfer agent would likely have zero
credit loss expectations if these
financial assets are unconditionally
guaranteed by the U.S. government.
Examples of held-to-maturity debt
securities that may result in
expectations of zero credit loss include
U.S. Treasury securities as well as
mortgage-backed securities issued and
guaranteed by the Government National
Mortgage Association, the Federal Home
Loan Mortgage Corporation, and the
Federal National Mortgage Association.
Assumptions related to zero credit loss
expectations should be included in the
institution’s ACL documentation.
Estimated Credit Losses for Off-Balance-
Sheet Credit Exposures
FASB ASC Topic 326 requires that an
institution estimate expected credit
losses for off-balance-sheet credit
exposures within the scope of FASB
ASC Topic 326 over the contractual
period during which the institution is
exposed to credit risk. The estimate of
expected credit losses should take into
consideration the likelihood that
funding will occur as well as the
amount expected to be funded over the
estimated remaining contractual term of
the off-balance-sheet credit exposures.
Management should not record an
estimate of expected credit losses for
off-balance-sheet exposures that are
unconditionally cancellable by the
issuer.
Management must evaluate expected
credit losses for off-balance-sheet credit
exposures as of each reporting date
as the
amount expected to be funded over the
estimated remaining contractual term of
the off-balance-sheet credit exposures.
Management should not record an
estimate of expected credit losses for
off-balance-sheet exposures that are
unconditionally cancellable by the
issuer.
Management must evaluate expected
credit losses for off-balance-sheet credit
exposures as of each reporting date.
While the process for estimating
expected credit losses for these
exposures is similar to the one used for
on-balance-sheet financial assets, these
estimated credit losses are not recorded
as part of the ACLs because cash has not
yet been disbursed to fund the
contractual obligation to extend credit.
Instead, these loss estimates are
recorded as a liability, separate and
distinct from the ACLs.22 The amount
needed to adjust the liability for
expected credit losses for off-balance-
sheet credit exposures as of each
reporting date is reported in net income.
Measurement of the ACL for Available-
for-Sale Debt Securities
FASB ASC Subtopic 326–30,
Financial Instruments—Credit Losses—
Available-for-Sale Debt Securities
(FASB ASC Subtopic 326–30) describes
the accounting for expected credit losses
associated with available-for-sale debt
securities. Credit losses for available-for-
sale debt securities are evaluated as of
each reporting date when the fair value
is less than amortized cost. FASB ASC
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accounting for expected credit losses
associated with available-for-sale debt
securities. Credit losses for available-for-
sale debt securities are evaluated as of
each reporting date when the fair value
is less than amortized cost. FASB ASC
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23 Non-credit impairment on an available-for-sale
debt security that is not required to be recorded
through the ACL should be reported in other
comprehensive income as described in ASC 326–
30–35–2.
24 The accounting policy elections described in
the ‘‘Accrued Interest Receivable’’ section of this
policy statement apply to accrued interest
receivable recorded for an available-for-sale debt
security if an institution excludes applicable
accrued interest receivable from both the fair value
and amortized cost basis of the security for
purposes of identifying and measuring impairment.
25 Management often documents policies,
procedures, and controls related to ACLs in
accounting or credit risk management policies, or
a combination thereof.
Subtopic 326–30 requires credit losses
to be calculated individually, rather
than collectively, using a discounted
cash flow method, through which
management compares the present value
of expected cash flows with the
amortized cost basis of the security. An
ACL is established, with a charge to the
PCL, to reflect the credit loss component
of the decline in fair value below
amortized cost. If the fair value of the
security increases over time, any ACL
that has not been written off may be
reversed through a credit to the PCL.
The ACL for an available-for-sale debt
security is limited by the amount that
the fair value is less than the amortized
cost, which is referred to as the fair
value floor
lect the credit loss component
of the decline in fair value below
amortized cost. If the fair value of the
security increases over time, any ACL
that has not been written off may be
reversed through a credit to the PCL.
The ACL for an available-for-sale debt
security is limited by the amount that
the fair value is less than the amortized
cost, which is referred to as the fair
value floor.
If management intends to sell an
available-for-sale debt security or will
more likely than not be required to sell
the security before recovery of the
amortized cost basis, the security’s ACL
should be written off and the amortized
cost basis of the security should be
written down to its fair value at the
reporting date with any incremental
impairment reported in income.
A change during the reporting period
in the non-credit component of any
decline in fair value below amortized
cost on an available-for-sale debt
security is reported in other
comprehensive income, net of
applicable income taxes.23
When evaluating impairment for
available-for-sale debt securities,
management may evaluate the
amortized cost basis including accrued
interest receivable, or may evaluate the
accrued interest receivable separately
from the remaining amortized cost basis.
If evaluated separately, accrued interest
receivable is excluded from both the fair
value of the available-for-sale debt
security and its amortized cost basis.24
Documentation Standards
For financial and regulatory reporting
purposes, ACLs and PCLs must be
determined in accordance with GAAP.
ACLs and PCLs should be well
documented, with clear explanations of
the supporting analyses and rationale
ated separately, accrued interest
receivable is excluded from both the fair
value of the available-for-sale debt
security and its amortized cost basis.24
Documentation Standards
For financial and regulatory reporting
purposes, ACLs and PCLs must be
determined in accordance with GAAP.
ACLs and PCLs should be well
documented, with clear explanations of
the supporting analyses and rationale.
Sound policies, procedures, and control
systems should be appropriately
tailored to an institution’s size and
complexity, organizational structure,
business environment and strategy, risk
appetite, financial asset characteristics,
loan administration procedures,
investment strategy, and management
information systems.25 Maintaining,
analyzing, supporting, and documenting
appropriate ACLs and PCLs in
accordance with GAAP is consistent
with safe and sound banking practices.
The policies and procedures
governing an institution’s ACL
processes and the controls over these
processes should be designed,
implemented, and maintained to
reasonably estimate expected credit
losses for financial assets and off-
balance-sheet credit exposures as of the
reporting date. The policies and
procedures should describe
management’s processes for evaluating
the credit quality and collectibility of
financial asset portfolios, including
reasonable and supportable forecasts
about changes in the credit quality of
these portfolios, through a disciplined
and consistently applied process that
results in an appropriate estimate of the
ACLs. Management should review and,
as needed, revise the institution’s ACL
policies and procedures at least
annually, or more frequently if
necessary
y of
financial asset portfolios, including
reasonable and supportable forecasts
about changes in the credit quality of
these portfolios, through a disciplined
and consistently applied process that
results in an appropriate estimate of the
ACLs. Management should review and,
as needed, revise the institution’s ACL
policies and procedures at least
annually, or more frequently if
necessary.
An institution’s policies and
procedures for the systems, processes,
and controls necessary to maintain
appropriate ACLs should address, but
not be limited to:
• Processes that support the
determination and maintenance of
appropriate levels for ACLs that are
based on a comprehensive, well-
documented, and consistently applied
analysis of an institution’s financial
asset portfolios and off-balance-sheet
credit exposures. The analyses and loss
estimation processes used should
consider all significant factors that affect
the credit risk and collectibility of the
financial asset portfolios;
• The roles, responsibilities, and
segregation of duties of the institution’s
senior management and other personnel
who provide input into ACL processes,
determine ACLs, or review ACLs. These
departments and individuals may
include accounting, financial reporting,
treasury, investment management,
lending, special asset or problem loan
workout teams, retail collections and
foreclosure groups, credit review, model
risk management, internal audit, and
others, as applicable
management and other personnel
who provide input into ACL processes,
determine ACLs, or review ACLs. These
departments and individuals may
include accounting, financial reporting,
treasury, investment management,
lending, special asset or problem loan
workout teams, retail collections and
foreclosure groups, credit review, model
risk management, internal audit, and
others, as applicable. Individuals with
responsibilities related to the estimation
of ACLs should be competent and well-
trained, with the ability to escalate
material issues;
• Processes for determining the
appropriate historical period(s) to use as
the basis for estimating expected credit
losses and approaches for adjusting
historical credit loss information to
reflect differences in asset specific
characteristics, as well as current
conditions and reasonable and
supportable forecasts that are different
from conditions existing in the
historical period(s);
• Processes for determining and
revising the appropriate techniques and
periods to revert to historical credit loss
information when the contractual term
of a financial asset or off-balance-sheet
credit exposure extends beyond the
reasonable and supportable forecast
period(s);
• Processes for segmenting financial
assets for estimating expected credit
losses and periodically evaluating the
segments to determine whether the
assets continue to share similar risk
characteristics;
• Data capture and reporting systems
that supply the quality and breadth of
relevant and reliable information
necessary, whether obtained internally
or externally, to support and document
the estimates of appropriate ACLs for
regulatory reporting requirements and,
if applicable, financial statement and
disclosure requirements;
• The description of the institution’s
systematic and logical loss estimation
process(es) for determining and
consolidating expected credit losses to
ensure that the ACLs are recorded in
accordance with GAAP and regulatory
reporting requirements
nt
the estimates of appropriate ACLs for
regulatory reporting requirements and,
if applicable, financial statement and
disclosure requirements;
• The description of the institution’s
systematic and logical loss estimation
process(es) for determining and
consolidating expected credit losses to
ensure that the ACLs are recorded in
accordance with GAAP and regulatory
reporting requirements. This may
include, but is not limited to:
Æ Management’s judgments,
accounting policy elections, and
application of practical expedients in
determining the amount of expected
credit losses;
Æ The process for determining when
a loan is collateral-dependent;
Æ The process for determining the fair
value of collateral, if any, used as an
input when estimating the ACL,
including the basis for making any
adjustments to the market value
conclusion and how costs to sell, if
applicable, are calculated;
Æ The process for determining when
a financial asset has zero credit loss
expectations;
Æ The process for determining
expected credit losses when a financial
asset has a collateral maintenance
provision; and
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Federal Register / Vol. 88, No. 81 / Thursday, April 27, 2023 / Rules and Regulations
26 Institutions using models in the loss estimation
process may incorporate a qualitative factor
adjustment in the estimate of expected credit losses
to capture the variance between modeled credit loss
expectations and actual historical losses when the
model is still considered predictive and fit for use.
Institutions should monitor this variance, as well as
changes to the variance, to determine if the variance
is significant or material enough to warrant further
changes to the model
adjustment in the estimate of expected credit losses
to capture the variance between modeled credit loss
expectations and actual historical losses when the
model is still considered predictive and fit for use.
Institutions should monitor this variance, as well as
changes to the variance, to determine if the variance
is significant or material enough to warrant further
changes to the model.
27 Engaging the institution’s external auditor to
perform the validation process described in this
paragraph when the external auditor also conducts
the institution’s independent financial statement
audit, may impair the auditor’s independence
under applicable auditor independence standards
and prevent the auditor from performing an
independent audit of the institution’s financial
statements.
Æ A description of and support for
qualitative factors that affect
collectibility of financial assets;
• Procedures for validating and
independently reviewing the loss
estimation process as well as any
changes to the process from prior
periods;
• Policies and procedures for the
prompt write-off of financial assets, or
portions of financial assets, when
available information confirms the
assets to be uncollectible, consistent
with regulatory reporting requirements;
and
• The systems of internal controls
used to confirm that the ACL processes
are maintained and periodically
adjusted in accordance with GAAP and
interagency guidelines establishing
standards for safety and soundness
f financial assets, or
portions of financial assets, when
available information confirms the
assets to be uncollectible, consistent
with regulatory reporting requirements;
and
• The systems of internal controls
used to confirm that the ACL processes
are maintained and periodically
adjusted in accordance with GAAP and
interagency guidelines establishing
standards for safety and soundness.
Internal control systems for the ACL
estimation processes should:
• Provide reasonable assurance
regarding the relevance, reliability, and
integrity of data and other information
used in estimating expected credit
losses;
• Provide reasonable assurance of
compliance with laws, regulations, and
the institution’s policies and
procedures;
• Provide reasonable assurance that
the institution’s financial statements are
prepared in accordance with GAAP, and
the institution’s regulatory reports are
prepared in accordance with the
applicable instructions;
• Include a well-defined and effective
loan review and grading process that is
consistently applied and identifies,
measures, monitors, and reports asset
quality problems in an accurate, sound
and timely manner. The loan review
process should respond to changes in
internal and external factors affecting
the level of credit risk in the portfolio;
and
• Include a well-defined and effective
process for monitoring credit quality in
the debt securities portfolio.
Analyzing and Validating the Overall
Measurement of ACLs
To ensure that ACLs are presented
fairly, in accordance with GAAP and
regulatory reporting requirements, and
are transparent for regulatory
examinations, management should
document its measurements of the
amounts of ACLs reported in regulatory
reports and financial statements, if
applicable, for each type of financial
asset (e.g., loans, held-to-maturity debt
securities, and available-for-sale debt
securities) and for off-balance-sheet
credit exposures
nd
regulatory reporting requirements, and
are transparent for regulatory
examinations, management should
document its measurements of the
amounts of ACLs reported in regulatory
reports and financial statements, if
applicable, for each type of financial
asset (e.g., loans, held-to-maturity debt
securities, and available-for-sale debt
securities) and for off-balance-sheet
credit exposures. This documentation
should include ACL calculations,
qualitative adjustments, and any
adjustments to the ACLs that are
required as part of the internal review
and challenge process. The board of
directors, or a committee thereof, should
review management’s assessments of
and justifications for the reported
amounts of ACLs.
Various techniques are available to
assist management in analyzing and
evaluating the ACLs. For example,
comparing estimates of expected credit
losses to actual write-offs in aggregate,
and by portfolio, may enable
management to assess whether the
institution’s loss estimation process is
sufficiently designed.26 Further,
comparing the estimate of ACLs to
actual write-offs at the financial asset
portfolio level allows management to
analyze changing portfolio
characteristics, such as the volume of
assets or increases in write-off rates,
which may affect future forecast
adjustments. Techniques applied in
these instances do not have to be
complex to be effective, but, if used,
should be commensurate with the
institution’s size and complexity.
Ratio analysis may also be useful for
evaluating the overall reasonableness of
ACLs. Ratio analysis assists in
identifying divergent or emerging trends
in the relationship of ACLs to other
factors such as adversely classified or
graded loans, past due and nonaccrual
loans, total loans, historical gross write-
offs, net write-offs, and historic
delinquency and default trends for
securities
atio analysis may also be useful for
evaluating the overall reasonableness of
ACLs. Ratio analysis assists in
identifying divergent or emerging trends
in the relationship of ACLs to other
factors such as adversely classified or
graded loans, past due and nonaccrual
loans, total loans, historical gross write-
offs, net write-offs, and historic
delinquency and default trends for
securities.
Comparing the institution’s ACLs to
those of peer institutions may provide
management with limited insight into
management’s own ACL estimates.
Management should apply caution
when performing peer comparisons as
there may be significant differences
among peer institutions in the mix of
financial asset portfolios, reasonable
and supportable forecast period
assumptions, reversion techniques, the
data used for historical loss information,
and other factors.
When used prudently, comparisons of
estimated expected losses to actual
write-offs, ratio analysis, and peer
comparisons can be helpful as a
supplemental check on the
reasonableness of management’s
assumptions and analyses. Because
appropriate ACLs are institution-
specific estimates, the use of
comparisons does not eliminate the
need for a comprehensive analysis of
financial asset portfolios and the factors
affecting their collectibility.
When an appropriate expected credit
loss framework has been used to
estimate expected credit losses, it is
inappropriate for the board of directors
or management to make further
adjustments to ACLs for the sole
purpose of reporting ACLs that
correspond to a peer group median, a
target ratio, or a budgeted amount.
Additionally, neither the board of
directors nor management should
further adjust ACLs beyond what has
been appropriately measured and
documented in accordance with FASB
ASC Topic 326
appropriate for the board of directors
or management to make further
adjustments to ACLs for the sole
purpose of reporting ACLs that
correspond to a peer group median, a
target ratio, or a budgeted amount.
Additionally, neither the board of
directors nor management should
further adjust ACLs beyond what has
been appropriately measured and
documented in accordance with FASB
ASC Topic 326.
After analyzing ACLs, management
should periodically validate the loss
estimation process, and any changes to
the process, to confirm that the process
remains appropriate for the institution’s
size, complexity, and risk profile. The
validation process should include
procedures for review by a party with
appropriate knowledge, technical
expertise, and experience who is
independent of the institution’s credit
approval and ACL estimation processes.
A party who is independent of these
processes could be from internal audit
staff, a risk management unit of the
institution independent of management
supervising these processes, or a
contracted third-party. One party need
not perform the entire analysis as the
validation may be divided among
various independent parties.27
Responsibilities of the Board of
Directors
The board of directors, or a committee
thereof, is responsible for overseeing
management’s significant judgments
and estimates used in determining
appropriate ACLs. Evidence of the board
of directors’ oversight activities is
subject to review by examiners. These
activities should include, but are not
limited to:
• Retaining experienced and qualified
management to oversee all ACL and PCL
activities;
• Reviewing and approving the
institution’s written loss estimation
policies, including any revisions
thereto, at least annually;
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are not
limited to:
• Retaining experienced and qualified
management to oversee all ACL and PCL
activities;
• Reviewing and approving the
institution’s written loss estimation
policies, including any revisions
thereto, at least annually;
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Federal Register / Vol. 88, No. 81 / Thursday, April 27, 2023 / Rules and Regulations
28 Guidance on third party service providers may
be found in SR Letter 13–19/Consumer Affairs
Letter 13–21, Guidance on Managing Outsourcing
Risk (FRB); Financial Institution Letter (FIL) 44–
2008, Guidance for Managing Third Party Risk
(FDIC); Supervisory Letter No. 07–01, Evaluating
Third Party Relationships (NCUA); and OCC
Bulletin 2013–29, Third Party Relationships: Risk
Management Guidance, OCC Bulletin 2017–7,
Third Party Relationships: Supplemental
Examination Procedures, and OCC Bulletin 2017–
21, Third Party Relationships: Frequently Asked
Questions to Supplement OCC Bulletin 2013–29.
29 See the interagency statement titled,
Supervisory Guidance on Model Risk Management,
published by the Board in SR Letter 11–7 and OCC
Bulletin 2011–12 on April 4, 2011. The statement
also addresses the incorporation of vendor products
into an institution’s model risk management
framework following the same principles relevant
to in-house models. The FDIC adopted the
interagency statement on June 7, 2017. Institutions
supervised by the FDIC should refer to FIL–22–
2017, Adoption of Supervisory Guidance on Model
Risk Management, including the statement of
applicability in the FIL
esses the incorporation of vendor products
into an institution’s model risk management
framework following the same principles relevant
to in-house models. The FDIC adopted the
interagency statement on June 7, 2017. Institutions
supervised by the FDIC should refer to FIL–22–
2017, Adoption of Supervisory Guidance on Model
Risk Management, including the statement of
applicability in the FIL.
• Reviewing management’s
assessment of the loan review system
and management’s conclusion and
support for whether the system is sound
and appropriate for the institution’s size
and complexity;
• Reviewing management’s
assessment of the effectiveness of
processes and controls for monitoring
the credit quality of the investment
portfolio;
• Reviewing management’s
assessments of and justifications for the
estimated amounts reported each period
for the ACLs and the PCLs;
• Requiring management to
periodically validate, and, when
appropriate, revise loss estimation
methods;
• Approving the internal and external
audit plans for the ACLs, as applicable;
and
• Reviewing any identified audit
findings and monitoring resolution of
those items.
Responsibilities of Management
Management is responsible for
maintaining ACLs at appropriate levels
and for documenting its analyses in
accordance with the concepts and
requirements set forth in GAAP,
regulatory reporting requirements, and
this policy statement. Management
should evaluate the ACLs reported on
the balance sheet as of the end of each
period (and for credit unions, prior to
paying dividends), and debit or credit
the related PCLs to bring the ACLs to an
appropriate level as of each reporting
date
nalyses in
accordance with the concepts and
requirements set forth in GAAP,
regulatory reporting requirements, and
this policy statement. Management
should evaluate the ACLs reported on
the balance sheet as of the end of each
period (and for credit unions, prior to
paying dividends), and debit or credit
the related PCLs to bring the ACLs to an
appropriate level as of each reporting
date. The determination of the amounts
of the ACLs and the PCLs should be
based on management’s current
judgments about the credit quality of the
institution’s financial assets and should
consider known and expected relevant
internal and external factors that
significantly affect collectibility over
reasonable and supportable forecast
periods for the institution’s financial
assets as well as appropriate reversion
techniques applied to periods beyond
the reasonable and supportable forecast
periods. Management’s evaluations are
subject to review by examiners.
In carrying out its responsibility for
maintaining appropriate ACLs,
management should adopt and adhere
to written policies and procedures that
are appropriate to the institution’s size
and the nature, scope, and risk of its
lending and investing activities. These
policies and procedures should address
the processes and activities described in
the ‘‘Documentation Standards’’ section
of this policy statement.
Management fulfills other
responsibilities that aid in the
maintenance of appropriate ACLs.
These activities include, but are not
limited to:
• Establishing and maintaining
appropriate governance activities for the
loss estimation process(es)
policies and procedures should address
the processes and activities described in
the ‘‘Documentation Standards’’ section
of this policy statement.
Management fulfills other
responsibilities that aid in the
maintenance of appropriate ACLs.
These activities include, but are not
limited to:
• Establishing and maintaining
appropriate governance activities for the
loss estimation process(es). These
activities may include reviewing and
challenging the assumptions used in
estimating expected credit losses and
designing and executing effective
internal controls over the credit loss
estimation method(s);
• Periodically performing procedures
that compare credit loss estimates to
actual write-offs, at the portfolio level
and in aggregate, to confirm that
amounts recorded in the ACLs were
sufficient to cover actual credit losses.
This analysis supports that appropriate
ACLs were recorded and provides
insight into the loss estimation process’s
ability to estimate expected credit
losses. This analysis is not intended to
reflect the accuracy of management’s
economic forecasts;
• Periodically validating the loss
estimation process(es), including
changes, if any, to confirm it is
appropriate for the institution; and
• Engaging in sound risk management
of third parties involved 28 in ACL
estimation process(es), if applicable, to
ensure that the loss estimation processes
are commensurate with the level of risk,
the complexity of the third-party
relationship and the institution’s
organizational structure
ation process(es), including
changes, if any, to confirm it is
appropriate for the institution; and
• Engaging in sound risk management
of third parties involved 28 in ACL
estimation process(es), if applicable, to
ensure that the loss estimation processes
are commensurate with the level of risk,
the complexity of the third-party
relationship and the institution’s
organizational structure.
Additionally, if an institution uses
loss estimation models in determining
expected credit losses, management
should evaluate the models before they
are employed and modify the model
logic and assumptions, as needed, to
help ensure that the resulting loss
estimates are consistent with GAAP and
regulatory reporting requirements.29 To
demonstrate such consistency,
management should document its
evaluations and conclusions regarding
the appropriateness of estimating credit
losses with models. When used for
multiple purposes within an institution,
models should be specifically adjusted
and validated for use in ACL loss
estimation processes. Management
should document and support any
adjustments made to the models, the
outputs of the models, and
compensating controls applied in
determining the estimated expected
credit losses.
Examiner Review of ACLs
Examiners are expected to assess the
appropriateness of management’s loss
estimation processes and the
appropriateness of the institution’s ACL
balances as part of their supervisory
activities. The review of ACLs,
including the depth of the examiner’s
assessment, should be commensurate
with the institution’s size, complexity,
and risk profile. As part of their
supervisory activities, examiners
generally assess the credit quality and
credit risk of an institution’s financial
asset portfolios, the adequacy of the
institution’s credit loss estimation
processes, the adequacy of supporting
documentation, and the appropriateness
of the reported ACLs and PCLs in the
institution’s regulatory reports and
financial statements, if applicable
art of their
supervisory activities, examiners
generally assess the credit quality and
credit risk of an institution’s financial
asset portfolios, the adequacy of the
institution’s credit loss estimation
processes, the adequacy of supporting
documentation, and the appropriateness
of the reported ACLs and PCLs in the
institution’s regulatory reports and
financial statements, if applicable.
Examiners may consider the significant
factors that affect collectibility,
including the value of collateral
securing financial assets and any other
repayment sources. Supervisory
activities may include evaluating
management’s effectiveness in assessing
credit risk for debt securities (both prior
to purchase and on an on-going basis).
In reviewing the appropriateness of an
institution’s ACLs, examiners may:
• Evaluate the institution’s ACL
policies and procedures and assess the
loss estimation method(s) used to arrive
at overall estimates of ACLs, including
the documentation supporting the
reasonableness of management’s
assumptions, valuations, and
judgments. Supporting activities may
include, but, are not limited to:
Æ Evaluating whether management
has appropriately considered historical
loss information, current conditions,
and reasonable and supportable
forecasts, including significant
qualitative factors that affect the
collectibility of the financial asset
portfolios;
Æ Assessing loss estimation
techniques, including loss estimation
models, if applicable, as well as the
incorporation of qualitative adjustments
to determine whether the resulting
estimates of expected credit losses are in
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sset
portfolios;
Æ Assessing loss estimation
techniques, including loss estimation
models, if applicable, as well as the
incorporation of qualitative adjustments
to determine whether the resulting
estimates of expected credit losses are in
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30 See footnote 29.
31 See footnote 28.
32 Each agency has formal and informal
communication channels for sharing supervisory
information with the board of directors and
management depending on agency practices and the
nature of the information being shared. These
channels may include, but are not limited to,
institution specific supervisory letters, letters to the
industry, transmittal letters, visitation findings
summary letters, targeted review conclusion letters,
or official examination or inspection reports.
conformity with GAAP and regulatory
reporting requirements; and
Æ Evaluating the adequacy of the
documentation and the effectiveness of
the controls used to support the
measurement of the ACLs;
• Assess the effectiveness of board
oversight as well as management’s
effectiveness in identifying, measuring,
monitoring, and controlling credit risk.
This may include, but is not limited to,
a review of underwriting standards and
practices, portfolio composition and
trends, credit risk review functions, risk
rating systems, credit administration
practices, investment securities
management practices, and related
management information systems and
reports;
• Review the appropriateness and
reasonableness of the overall level of the
ACLs relative to the level of credit risk,
the complexity of the institution’s
financial asset portfolios, and available
information relevant to assessing
collectibility, including consideration of
current conditions and reasonable and
supportable forecasts
and related
management information systems and
reports;
• Review the appropriateness and
reasonableness of the overall level of the
ACLs relative to the level of credit risk,
the complexity of the institution’s
financial asset portfolios, and available
information relevant to assessing
collectibility, including consideration of
current conditions and reasonable and
supportable forecasts. Examiners may
include a quantitative analysis (e.g.,
using management’s results comparing
expected write-offs to actual write-offs
as well as ratio analysis) to assess the
appropriateness of the ACLs. This
quantitative analysis may be used to
determine the reasonableness of
management’s assumptions, valuations,
and judgments and understand
variances between actual and estimated
credit losses. Loss estimates that are
consistently and materially over or
under predicting actual losses may
indicate a weakness in the loss
forecasting process;
• Review the ACLs reported in the
institution’s regulatory reports and in
any financial statements and other key
financial reports to determine whether
the reported amounts reconcile to the
institution’s estimate of the ACLs. The
consolidated loss estimates determined
by the institution’s loss estimation
method(s) should be consistent with the
final ACLs reported in its regulatory
reports and financial statements, if
applicable;
• Verify that models used in the loss
estimation process, if any, are subject to
initial and ongoing validation activities.
Validation activities include evaluating
and concluding on the conceptual
soundness of the model, including
developmental evidence, performing
ongoing monitoring activities, including
process verification and benchmarking,
and analyzing model output.30
Examiners may review model validation
findings, management’s response to
those findings, and applicable action
plans to remediate any concerns, if
applicable
include evaluating
and concluding on the conceptual
soundness of the model, including
developmental evidence, performing
ongoing monitoring activities, including
process verification and benchmarking,
and analyzing model output.30
Examiners may review model validation
findings, management’s response to
those findings, and applicable action
plans to remediate any concerns, if
applicable. Examiners may also assess
the adequacy of the institution’s
processes to implement changes in a
timely manner; and
• Review the effectiveness of the
institution’s third-party risk
management framework associated with
the estimation of ACLs, if applicable, to
assess whether the processes are
commensurate with the level of risk, the
complexity and nature of the
relationship, and the institution’s
organizational structure. Examiners may
determine whether management
monitors material risks and deficiencies
in third-party relationships, and takes
appropriate action as needed.31
When assessing the appropriateness
of ACLs, examiners should recognize
that the processes, loss estimation
methods, and underlying assumptions
an institution uses to calculate ACLs
require the exercise of a substantial
degree of management judgment. Even
when an institution maintains sound
procedures, controls, and monitoring
activities, an estimate of expected credit
losses is not a single precise amount and
may result in a range of acceptable
outcomes for these estimates. This is a
result of the flexibility FASB ASC Topic
326 provides institutions in selecting
loss estimation methods and the wide
range of qualitative and forecasting
factors that are considered.
Management’s ability to estimate
expected credit losses should improve
over the contractual term of financial
assets as substantive information
accumulates regarding the factors
affecting repayment prospects
result of the flexibility FASB ASC Topic
326 provides institutions in selecting
loss estimation methods and the wide
range of qualitative and forecasting
factors that are considered.
Management’s ability to estimate
expected credit losses should improve
over the contractual term of financial
assets as substantive information
accumulates regarding the factors
affecting repayment prospects.
Examiners generally should accept an
institution’s ACL estimates and not seek
adjustments to the ACLs, when
management has provided adequate
support for the loss estimation process
employed, and the ACL balances and
the assumptions used in the ACL
estimates are in accordance with GAAP
and regulatory reporting requirements.
It is inappropriate for examiners to seek
adjustments to ACLs for the sole
purpose of achieving ACL levels that
correspond to a peer group median, a
target ratio, or a benchmark amount
when management has used an
appropriate expected credit loss
framework to estimate expected credit
losses.
If the examiner concludes that an
institution’s reported ACLs are not
appropriate or determines that its ACL
evaluation processes or loss estimation
method(s) are otherwise deficient, these
concerns should be noted in the report
of examination and communicated to
the board of directors and senior
management.32 Additional supervisory
action may be taken based on the
magnitude of the shortcomings in ACLs,
including the materiality of any errors
in the reported amounts of ACLs.
Michael J. Hsu,
Acting Comptroller of the Currency.
By order of the Board of Governors of the
Federal Reserve System.
Ann E. Misback,
Secretary of the Board.
Federal Deposit Insurance Corporation.
By order of the Board of Directors.
Dated at Washington, DC, on March 31,
2023.
James P. Sheesley,
Assistant Executive Secretary.
By the National Credit Union
Administration Board.
Melane Conyers-Ausbrooks,
Secretary of the Board.
[FR Doc
.
By order of the Board of Governors of the
Federal Reserve System.
Ann E. Misback,
Secretary of the Board.
Federal Deposit Insurance Corporation.
By order of the Board of Directors.
Dated at Washington, DC, on March 31,
2023.
James P. Sheesley,
Assistant Executive Secretary.
By the National Credit Union
Administration Board.
Melane Conyers-Ausbrooks,
Secretary of the Board.
[FR Doc. 2023–08876 Filed 4–26–23; 8:45 am]
BILLING CODE 4810–33–P; 6210–01–P; 6714–01–P;
7535–01–P
DEPARTMENT OF STATE
22 CFR Part 121
[Public Notice: 11986]
RIN 1400–AF27
International Traffic in Arms
Regulations: U.S. Munitions List
Targeted Revisions
AGENCY: Department of State.
ACTION: Interim final rule; request for
comments.
SUMMARY: The Department of State (the
Department) amends the International
Traffic in Arms Regulations (ITAR) to
remove from U.S. Munitions List
(USML) Category XI certain high-energy
storage capacitors and to clearly identify
the high-energy storage capacitors that
remain in USML Category XI.
DATES: Effective date May 21, 2023.
Send comments by May 30, 2023.
ADDRESSES: Interested parties may
submit comments to the Department of
State by any of the following methods:
• Visit the Regulations.gov website at:
http://www.regulations.gov and search
for the docket number DOS–2023–0003.
VerDate Sep<11>2014
16:18 Apr 26, 2023
Jkt 259001
PO 00000
Frm 00010
Fmt 4700
Sfmt 4700
E:\FR\FM\27APR1.SGM
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lotter on DSK11XQN23PROD with RULES1

## Nearby sections

- [FDIC FIL-1-2002 FOREIGN ASSETS CONTROL ACT](https://www.frixlaw.com/law-library/statutes/FDIC_FIL02001.md)
- [FDIC FIL-1-2010 Employee Compensation Advance Notice of Proposed Rulemaking](https://www.frixlaw.com/law-library/statutes/FDIC_FIL10001.md)
- [FDIC FIL-1-2024 Consolidated Reports of Condition and Income for Fourth Quarter 2023](https://www.frixlaw.com/law-library/statutes/FDIC_FIL24001.md)
- [FDIC FIL-2-2004 Foreign Assets Control Act](https://www.frixlaw.com/law-library/statutes/FDIC_FIL04002.md)
- [FDIC FIL-2-2020 Consolidated Reports of Condition and Income for Fourth Quarter 2019](https://www.frixlaw.com/law-library/statutes/FDIC_FIL20002.md)
- [FDIC FIL-3-2003 FILING PROCEDURES](https://www.frixlaw.com/law-library/statutes/FDIC_FIL03003.md)
- [FDIC FIL-4-2006 Commercial Real Estate Lending Proposed Interagency Guidance](https://www.frixlaw.com/law-library/statutes/FDIC_FIL06004.md)
- [FDIC FIL-4-2021 Revised Guidelines for Appeals of Material Supervisory Determinations](https://www.frixlaw.com/law-library/statutes/FDIC_FIL21004.md)
- [FDIC FIL-4-2023 Guidance to Help Financial Institutions and Facilitate Recovery in Areas of California Affected by Severe Winter Storms, Flooding, Landslides and Mudslides](https://www.frixlaw.com/law-library/statutes/FDIC_FIL23004.md)
- [FDIC FIL-4-2025 FDIC Statement of Policy on Bank Merger Transactions](https://www.frixlaw.com/law-library/statutes/FDIC_FIL25004.md)
- [FDIC FIL-5-2000 Consumer Credit Reporting Practices](https://www.frixlaw.com/law-library/statutes/FDIC_FIL00005.md)
- [FDIC FIL-5-2003 LETTER TO STAKEHOLDERS](https://www.frixlaw.com/law-library/statutes/FDIC_FIL03005.md)
- [FDIC FIL-5-2021 Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering (AML) Considerations](https://www.frixlaw.com/law-library/statutes/FDIC_FIL21005.md)
- [FDIC FIL-6-2000 Special Alert](https://www.frixlaw.com/law-library/statutes/FDIC_FIL00006.md)

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/FDIC_FIL23017. Check the current official text before relying on it. Not legal advice.
