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Allowance for Loan Loss Presented by Tasha Kostick Assurance Partner McGladrey LLP

Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

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Page 1: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Allowance for Loan Loss Presented by Tasha Kostick

Assurance Partner McGladrey LLP

Page 2: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Agenda • Review Historical Trends for loan growth,

allowance and key indicators • Review of the 2013 McGladrey Allowance for

Loan Loss Reserve Survey • Expectations for the future • Changes on the horizon that could impact the

Allowance for Loan Losses

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Page 3: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Ready set go…

Who feels like they have been on a roller coaster when it comes to the allowance for loan losses?

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Page 4: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Historical Trends

• Allowance for loan losses • Delinquencies • Charge offs

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Page 5: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Historical Trends over the past 10 years

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Page 6: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Historical Trends over the past 10 years

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Page 7: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Historical Trends over the past 10 years

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Page 8: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

2013 McGladrey Loan Loss Reserve Survey

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Page 9: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Overview • Gathered key data on reserve requirements • Charted into 6 subgroups based on asset size • Nationally and 5 separate U.S. geographic

regions • 9th annual year of the survey

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Page 10: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Profile by assets and Region • Participants Assets

– <$250 M - 36% – $250-$500 M - 19% – $500-$750 M – 16% – $750 M-$1 B – 7% – $1 -$2 B – 14% – >$2 B – 7%

• Region – West - 20% – Central – 29% – Great Lakes – 11% – Southeast – 8% – Northeast – 31%

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Page 11: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Local Economic Conditions

How would

you assess your local economic

conditions?

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Page 12: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Local Economic Conditions

• Mixed Results • Over 50% of all institutions reported their

local market conditions were significantly improving or improving.

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Page 13: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

Northeast Southeast West Great Lakes Central

Significantly improving

Improving

Stable

Declining

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Page 14: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Historical Losses

Number of years historical

charge-offs are used in

determining the historical factor.

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Page 15: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

1 year 2 years 3 years 4 years 5 years 6 years 7 years >7 years

Series1

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Page 16: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Has the historical loss period you use changed within the last year?

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Page 17: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

No change

Increase

Decrease

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Page 18: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Based on the credit trends in your market,

are you anticipating recording a credit to your loan loss provision in

the next 12 months?

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Page 19: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

90.0%

National Northeast Southeast West Great Lakes Central

Increasing

Remains the same

Decreasing

Significantly decreasing

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Page 20: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

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Historical Trends over the past 10 years

Page 21: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Future Expectations •Are we over the severe funding requirements? •Decreasing or remaining consistent with prior year •How do you expect to adjust for loan growth? •Increasing in some portfolios

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Page 22: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Expectation of Change in the future general reserve

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

National Northeast Southeast West Great Lakes Central

Increase

Remain the same

Decrease

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Page 23: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Components for reserve requirements • General Reserve (ASC 450-20)

– average of 60% • Specific Reserve (ASC 310-10)

– average of 24% • Unallocated Reserve

– average of 12% • Total loan loss reserve

– average of 2%

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Page 24: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

General Reserve (ASC 450-20)

• 18 categories assessed

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Page 25: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Time • Time to prepare, document and review the

allowance for loan loss calculation – Average of 26 hours

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Page 26: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Primary Responsibility for Calculation • Who performs these duties?

– 48% stated accounting or finance staff – 39% stated credit/ lending/ risk staff

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Page 27: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

90.0%

National Northeast Southeast West Great Lakes Central

Yes

No

Do you use a software tool to assist with the calculation?

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Page 28: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Board of Directors review or oversight

• High-involvement – “detailed review of the loan committee level, high

level review of the full board” – “thorough review by the board” – “reviews of loan factors, specific reserves and

trends”

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Page 29: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Board of Directors review or oversight

• Low-involvement – Minimal roles in the loan loss reserve review – With awareness limited to high-level discussions

of ratios – Or simple review of the staff reports in the

meeting minutes

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Page 30: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Assuming the FASB proposed credit impairment model is finalized in its

current state, what is the approximate anticipated impact on

your ratio of allowance for loan losses to total loans?

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Page 31: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Little to no impact

Increase 50 basis points

increase 100 basis points

increase 150 basis points

increase 200 basis points or greater

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Page 32: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Financial Instruments Impact • Further redeliberations through March 2014 • When estimating allowance for current expected credit losses

– Recognize lifetime expected losses rather than losses that are probable at the balance sheet date

– Revert to historical loss experience for future periods when you cannot make or obtain reasonable and supportable forecasts

– Consider lifetime contractual cashflows and expected prepayments (unless you expect to execute a TDR, ignore expected extensions/ renewals/ modifications)

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Page 33: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Financial Instruments Impact • When estimating current expected credit losses, continued:

– Reflect risk of loss even if remote, however amount of expected loss may be zero

– Can use discounted cash flow model as well as loss-rate or probability of default methods and provision matrix

– Implementation guidance will address how to adjust historical experience for current and forecasted conditions

• Slated for 2nd half 2014 issuance

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Page 34: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Questions

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Page 35: Allowance for Loan Loss - CUNA Councils · Allowance for Loan Loss Presented by Tasha Kostick . Assurance Partner McGladrey LLP . Agenda • Review Historical Trends for loan growth,

Contact Info

Tasha Kostick 415.848.5351

[email protected]

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