The new CECL standard is presumably designed to enhance the stability of the financial sector by providing more accurate assessments of loan losses. It also requires a change from the current estimates of loan losses that are produced by most institutions today to projections or forecasts.
Speaking at the American Bar Association Banking Law Committee Annual Meeting, "Principles of Supervision"; in Washington, D.C., FDIC Chair McWilliams described her vision and priorities for the Corporation.
A regulatory examination of lending activity, whether fair lending related or safety and soundness, always focuses on data. Data integrity notwithstanding (which is another blog post entirely), such data is a function of (2) things: (1) policies and (2) actual practices. The interaction of these two forces creates the lending data that will be the subject of a regulatory examination. These data, in turn, will shape the ultimate outcome of the review.
As concerns continue to grow for investors due to market volatility and increasingly pessimistic economic forecasts, financial institutions should be paying particular attention. The economic news, coupled with the prospect of more interest rate hikes, not only create conditions for weakening asset quality and earnings but also highlights the importance of measuring these potential impacts on loan portfolios.
All of us are familiar with the term “perfect storm.” A perfect storm can be defined as the occurrence of a highly improbable event. In the context of the perfect storm, the event is improbable because a combination of factors or conditions have to occur or exist either simultaneously or in a particular sequence in order to produce the event. It is the unlikely nature of the simultaneity of multiple factors or conditions that produces the “perfect storm.”
On December 21, the OCC, FDIC and the Fed Board of Governors approved a final rule modifying their regulatory capital rules and providing a phase-in period of three years of the day-one regulatory capital effects of CECL. The final rule will take effect April 1, 2019.
Representing a significant change, the FDIC is requesting comment on a proposed rule that would amend the existing stress testing regulations to increase the minimum threshold for applicability from $10 billion to $250 billion, revise the frequency of required stress tests by FDIC-supervised institutions, and reduce the number of required stress testing scenarios from three to two.
On December 13, the FDIC released FDIC Quarterly¸ a quarterly comprehensive summary of the most current financial results for the banking industry. Within this summary is a featured article titled “2018 Summary of Deposit Highlights: Deposit Growth Slows and Office Decline Continues.”
On December 6, the FDIC announced actions to promote a “more transparent, streamlined, and accountable deposit insurance application process” to encourage the establishment of new, or de novo, banks.