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Ken Welch's presentation on credit quality during the Volunteer Track of the 9th Annual Police Officers' Credit Union Conference.
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POLICE OFFICERSCREDIT UNION CONFERENCE
2012
NEW ALLOWANCE FOR LOAN LOSSESLOAN CREDIT QUALITY DISCLOSURESLOAN CREDIT QUALITY DISCLOSURES
ASU – No. 2010 ‐ 20
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AICPA ACCOUNTING STANDARDS UPDATE (ASU) No. 2010‐20DISCLOSURES ABOUT THE CREDIT QUALITY OF FINANCING RECEIVABLES AND THE ALLOWNCE FOR CREDIT LOSSES
Issued July 2010 , Receivables (ASC Topic 310)
“Financing Receivables” Represents Loans for Credit Unions
“Allowance for Credit Losses” ALL for Credit Unions
Applicable for All Entities – Not Just Financial Institutions
Effective for Non Public Entities for Periods Ending After December 15Effective for Non Public Entities for Periods Ending After December 15, 2011, Optional Comparative Presentation for Initial Year
Will Require Comparative Reporting for Periods Ending After December 15, 2012
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AICPA ACCOUNTING STANDARDS UPDATE (ASU) No. 2010‐20DISCLOSURES ABOUT THE CREDIT QUALITY OF FINANCING RECEIVABLES AND THE ALLOWNCE FOR CREDIT LOSSES
No. 2010 ‐ 20 Why Is This Necessary ?
P id fi i l t t t ith tProvide financial statement users with greatertransparency about an entity’s allowance for creditlosses and the credit quality of its financing receivables.The Update is intended to provide additionalinformation to assist financial statement users inassessing a Credit Union’s credit risk exposures andassessing a Credit Union s credit risk exposures andevaluating the adequacy of its Allowance for LoanLosses.
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AICPA ACCOUNTING STANDARDS UPDATE (ASU) No. 2010‐20DISCLOSURES ABOUT THE CREDIT QUALITY OF FINANCING RECEIVABLES AND THE ALLOWNCE FOR CREDIT LOSSES
What It Doesn’t Cover
Short Term Trade Receivables
Fi i R i bl M d t F i V lFinancing Receivables Measured at Fair Value
Financing Receivables Measured at Lower of Cost or Fair Value
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AICPA ACCOUNTING STANDARDS UPDATE (ASU) No. 2010‐20DISCLOSURES ABOUT THE CREDIT QUALITY OF FINANCING RECEIVABLES AND THE ALLOWNCE FOR CREDIT LOSSES
What Are The New Disclosure Objectives?
The Nature of Credit Risk Inherent in the Loan Portfolio
How That Credit Risk is Analyzed and Assessed in Arriving at the AllowanceHow That Credit Risk is Analyzed and Assessed in Arriving at the Allowance for Loan Losses Estimate
Provide Disclosures on a Disaggregated Basis 2 Levels of Disaggregation:Provide Disclosures on a Disaggregated Basis – 2 Levels of Disaggregation: By Segment and Class
f fDisclose Any Changes and Reasons for Those Changes in the Allowance for Loan Losses Estimate Methodology
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AICPA ACCOUNTING STANDARDS UPDATE (ASU) No. 2010‐20DISCLOSURES ABOUT THE CREDIT QUALITY OF FINANCING RECEIVABLES AND THE ALLOWNCE FOR CREDIT LOSSES
What Is Continued From Prior Disclosures?Loan Portfolio Schedule By Major Segments and Class
Rollforward Schedule of the Allowance for Loan Losses for the Beginning to End of the Period ‐ Now by Portfolio Segment
The Recorded Investment of Each Portfolio Segment on a Disaggregated Basis as Evaluated
The Non‐Accrual Status of Loans – Now by Class
Disclosure of Impaired Loans – Now by Class
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p y
AICPA ACCOUNTING STANDARDS UPDATE (ASU) No. 2010‐20DISCLOSURES ABOUT THE CREDIT QUALITY OF FINANCING RECEIVABLES AND THE ALLOWNCE FOR CREDIT LOSSES
What is New for DisclosureCredit Quality Indicators for Loan Classes at End of Period
Aging of Loans at End of Period by Class
Nature and Extent of TDR Activity During the Period by Loan Class including TDR Defaults and the Effect on the ALL
Significant Purchases or Sales of Loans During the Period by Segment
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Segments vs. Classes
The guidance discusses certain new disclosures to be presented by segments and other disclosures to be presented by classes.
Segment: The overriding level at which an entity develops and documents a systematic method for determining itsand documents a systematic method for determining its allowance for credit losses.
(Ex: Real Estate, Consumer, Commercial)
Class: Disaggregation of portfolio segment.(Ex: 1 Mortgage, Unsecured , Vehicle)
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Best Practice Recommendation Use Classes
CliftonLarsonAllen will most often recommend using classesCliftonLarsonAllen will most often recommend using classesfor all disclosures in most Credit Union Financial Statementsin order to simplify the disclosure process, ease preparationburdens and also to eliminate financial statement userconfusion when shifting between segments and classes.
Note :The key to all disclosures is to ensure they are customized to the individual Credit Union’s practices and procedures.
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New TDR Disclosure Requirements
ASU No. 2010‐20 requires entities to disclose the nature and extent oftroubled debt restructurings that occurred during the reporting periodtroubled debt restructurings that occurred during the reporting periodby class of financing receivables and their effect on the allowance forcredit losses.
It also requires disclosure of the nature and extent of financing receivablesmodified as TDRs within the previous 12 months that defaulted duringthe reporting period by class of financing receivables and their effect onthe allowance for credit lossesthe allowance for credit losses.
Prior to these new disclosures, entities were required to report their dollarvolumes of TDRs and the amount of any commitments to lend additionalyfunds to borrowers whose terms were modified in a TDR.
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Note 1‐Summary of Significant Accounting Policies
Previously Note 1 included a “Loans Net” section whichPreviously, Note 1 included a Loans, Net section whichincluded discussion of loans and the allowance for loanlosses
Now, the “Allowance for Loan Losses” section is broken outseparately within Note 1 and includes additional discussionrelated to credit risks, impaired loans, inherent loss factorsor credit quality factors considered.
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Note 1‐Summary of Significant Accounting Policies
Continued:Added ‐ A discussion of loan segments and/or classes and their
general description of terms and risk characteristics asgeneral description of terms and risk characteristics asevaluated or tracked by the Credit Union
Added A discussion of loan modifications and troubled debtAdded – A discussion of loan modifications and troubled debtrestructurings, their impact on the loan portfolio andAllowance for Loan Losses
Added – A discussion and definition of impaired loans andtheir measurement principles
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Note 1‐Summary of Significant Accounting PoliciesPolicies
Troubled Debt Restructuring
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Note 1‐Summary of Significant Accounting Policies
H f li ( l f l ) bHomogeneous portfolio segments (pools of loans) are to bedefined along with their risk characteristics.
Segments listed need to agree with those in the allowance forloan losses calculation (These may change over time as loan
d ff i l )product offerings evolve) .
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Note 1‐Summary of Significant Accounting Policies
Risk RatingsApplicable for Credit Unions with a risk rating system in place forloans. Most often this will apply to participation loans and memberbusiness loans only (No need to include this section if not applicable).bus ess oa s o y ( o eed o ude s se o o app ab e)
Identify portfolio segments and the risk characteristics for the loancategories that are risk rated.
If member business/commercial loans are accounted for as pools inthe Credit Union’s ALL calculation, they should be included in thehomogeneous pools portion of Note 1 loan segment disclosuresinstead
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Note X ‐ Loans, Net
Loan Portfolio Segment/ Classes ScheduleNeeds to agree with segments/ Classes listed and defined inN 1 Si ifi A i P li iNote 1 Significant Accounting PoliciesNeeds to agree with ALL calculation segments
Allowance for Loan Losses Activity ScheduleThe activity schedule is presented comparatively or both yearsand will be deleted once comparative data on the newand will be deleted once comparative data on the newdisclosures is available for two years (beginning with12/31/2012 reporting).
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Note X ‐ Loans, Net,The composition of loans to members is as follows:
2011 2010Fi t M t $ $First Mortgages -$ -$ Home Equity and Other Real Estate - - Direct Vehicle - - Indirect Vehicle - - Credit Cards - - Share/Certificate Secured - - Other Secured - - Other Unsecured - - Commercial Real Estate - - Commercial Other - -
Net Deferred Loan Origination Costs (Fees) - - Allowance for Loan Losses - -
-$ -$
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Note X ‐ Loans, Net
New Allowance Activity Schedule
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Note X ‐ Loans, Net
Columns used in the ALL activity disclosure need to agree withloan portfolio segment risk descriptions in Note 1 of theloan portfolio segment risk descriptions in Note 1 of thefinancial statements and the Loans, Net Segment/Classescomposition in Note X as well as the ALL calculationsegments.
Both 2012 and 2011 data will be presented in this format goingforward as this will need to be a comparative disclosure.
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Note X ‐ Loans, Net
The same ALL activity line items are presented.Disclosures are now by segment/ class instead of beingDisclosures are now by segment/ class instead of being
combined for the entire portfolio.Need to ensure the total ALL for all segments agrees with
the ALL balance in the loan portfolio schedule.
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Note X ‐ Loans, Net
Other Changes to the ALL Activity DisclosureOther Changes to the ALL Activity DisclosureFirst Line: Ending ALL for loans individually evaluated for impairment by segment (ASC 310‐40, formerly FAS 114)Second Line: Ending ALL for loans collectively evaluated for impairment by segment (ASC 450, formerly FAS 5)Third Line: Ending ALL for loans acquired with deterioratedThird Line: Ending ALL for loans acquired with deteriorated credit quality (this will most likely not be applicable for the majority of the Credit Unions)
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Note X ‐ Loans, Net
The sum of the orange boxes will equal the blue highlighted b f hbox for each segment.
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Note X ‐ Loans, Net
The sum of the orange boxes will equal the blue highlighted box for each segment
De c e mbe r 3 1 , 2 0 1 1First
Mortgages
Allowa nc e for Loa n Losse s:Balance at Beginning of Year -$
Provision for Loan Losses -
box for each segment
Provision for Loan Losses -
Loans Charged- Off -
Recoveries of Loans
Previously Charged- Off -
Balance at End of Year -$
Ending Balance: Individually
Evaluated for Impairment -$
Ending Balance: Collectively
Evaluated for Impairment -$
Ending Balance: Loans
Acquired with Deteriorated
Credit Quality -$
Loa ns:Ending Balance: Individually
Evaluated for Impairment -$
Ending Balance: Collectively
Evaluated for Impairment -$
©2012 CliftonLarsonAllen LLP
Ending Balance: Loans
Acquired with Deteriorated
Credit Quality -$
Note X ‐ Loans, Net
This schedule shows the risk rated loans (usually participation and commercial loans) by risk rating.
Risk ratings will agree with those defined in Note 1. Totals for segments/ classes will agree with Loans Netsegments/ classes will agree with Loans, Net.
Deleted if not applicable.
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Note X ‐ Loans, Net,
New payment activity disclosures will present all loans bysegment/ class (homogeneous pools and rated loans. Totalsagree to Loans, Net for each segment/ class.
Performing vs non‐performing will be determined by thePerforming vs. non‐performing will be determined by thenumber of days at which CU policy indicates loans stopaccruing interest (60 or 90 days).
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Note X ‐ Loans, Net
New Loan Aging Analysis Scheduleg g y
Accruing interest portion will agree with the Credit Union’spolicy (60 or 90 days).p y ( y )
2nd column will either read 30‐89 days past due or 30‐59days past due depending on the accrued interest policy ofy p p g p ythe Credit Union.
Numbers appearing in the disclosure are the loan balancespp gwith totals by portfolio segment/ class.
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Note X ‐ Loans, Net
N L A i A l i S h d l E lNew Loan Aging Analysis Schedule ExampleDe c e mbe r 3 1 , 2 0 1 1
Nona c c rua l30- 89 90 Days or 90 Days or Total
Accruing Interest
y y
Current Days Past Due More Past Due More Past Due Loans
First Mortgages -$ -$ -$ -$ -$
HELOC and Other Real Estate
Direct Vehic le - - - - -
Indirect Vehic le - - - - -Indirect Vehic le
Credit Cards - - - - -
Share/Certificate Secured - - - - -
Other Secured - - - - -
Other Unsecured - - - - -
Commercial Real EstateCommercial Real Estate - - - - -
Commercial Other - - - - -
-$ -$ -$ -$ -$
©2012 CliftonLarsonAllen LLP
Note X ‐ Loans, Net
Interest income foregone on nonaccrual loans:S t d h b l dd d f i d di lSuggested paragraphs below added for required disclosure.You will need to choose the correct option for inclusion in thefootnotes. This data is not usually readily available and can beestimated
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Note X ‐ Loans, Net
New ‐ Impaired Loans ScheduleImpaired Loans must now be disclosed by loan segment/ class for the following:Impaired Loans must now be disclosed by loan segment/ class for the following:
Impaired loans with no related allowance
Impaired loans with an allowance recorded
Total impaired loans
Note ‐ This information must be comparative in 2012Note This information must be comparative in 2012
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Note X ‐ Loans, NetDe c e mbe r 3 1 , 2 0 1 1 Unpaid Average Interest
Recorded Principal Related Recorded IncomeInvestment Balance Allowance Investment Recognized
With No Related Allowance:
First Mortgages -$ -$ -$ -$First Mortgages $ $ $ $
HELOC and Other Real Estate
Direct Vehic le - - - -
Indirect Vehic le - - - -
Credit Cards - - - -
Share/Certificate Secured - - - -
Other Secured - - - -
Other Unsecured - - - -
Commercial Real Estate - - - -
Commercial Other - - - -
With An Allowance Recorded:First Mortgages - - - - - HELOC and Other Real EstateDirect Vehic le - - - - -
Indirect Vehic le - - - - -
Credit Cards - - - - -
Share/Certificate Secured - - - - -
Other Secured - - - - -
Other Unsecured - - - - -
Commercial Real Estate - - - - -
C i l OthCommercial Other - - - - - Total Impaired Loans:First Mortgages -$ -$ -$ -$ -$ HELOC and Other Real EstateDirect Vehic le -$ -$ -$ -$ -$ Indirect Vehic le -$ -$ -$ -$ -$ Credit Cards -$ -$ -$ -$ -$ Share/Certificate Secured -$ -$ -$ -$ -$
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POther Secured -$ -$ -$ -$ -$ Other Unsecured -$ -$ -$ -$ -$ Commercial Real Estate -$ -$ -$ -$ -$ Commercial Other -$ -$ -$ -$ -$
Note X ‐ Loans, Net
Impaired Loans Schedule Columns:Unpaid Principal Balance: The amount the borrower owes onthe loan
Recorded Investment: The amount recorded on the generalledger for various loan segments
Note: Unpaid principal balance and recorded investment willmost often be the same for Credit Unions. If loans werespecifically written down, they may differ.specifically written down, they may differ.
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Note X ‐ Loans, Net
Impaired Loans Schedule ‐ ContinuedImpaired Loans Schedule ContinuedRelated Allowance: The allowance provided on the variousimpaired loans by segment
Average Recorded Investment: We will disclose the simpleaverage of beginning and ending balances for the auditperiod (or other quantifiable methods)
Interest Income Recognized: The amount of interest incomerecognized using cash‐basis during the time within theaudit period that loans were impaired, if practicable.
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Note X ‐ Loans, Net
New required disclosure regarding commitments q g gexisting in TDRs and nonaccrual loans.
To be modified as necessary:
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Note X ‐ Loans, Net
New Disclosures related to TDRs (first three columns):Number of loans by segmentNumber of loans by segmentLoan balance by segmentSpecific reserve by segment
The above disclosures are for all TDRs modified duringThe above disclosures are for all TDRs modified during the reporting period and not total TDRs.
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Note X ‐ Loans, Net
New disclosures also exist for TDRs that subsequentlyq ymissed a payment (modified as TDRs within the previoustwelve months and for which there was a paymentdefault during the reporting period)default during the reporting period).
Number of Loans by segment
Loan Balance by segment
Specific Reserve by segmentSpec c ese e by seg e t
Note ‐ this information is not generally readily available
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Note X ‐ Loans, Net
New TDR Disclosure Schedule ExampleNew TDR Disclosure Schedule ExampleDuring the Year Ended December 31, 2011
Troubled Debt Restructurings
Troubled Debt Restructurings That Subsequently Defaulted
Number of Post- modification Specific Number of Post- modification Specific
Loans Outstanding Balance Reserve Loans Outstanding Balance Reserve
First Mortgages - -$ -$ - -$ -$
HELOC and Other Real Estate - - - - - -
Direct Vehic le - - - - - -
Indirect Vehic le - - - - - -
Credit Cards - - - - - -
Share/Certificate Secured - - - - - -
Other Secured - - - - - -
Other Unsecured - - - - - -
Commercial Real Estate - - - - - -
Commercial Other
- -$ -$ - -$ -$
©2012 CliftonLarsonAllen LLP
Note X ‐ Loans, Net
This disclosure will be necessary when CreditUnions have added interest and fees to loansUnions have added interest and fees to loansthrough the modification process related toTDRs.TDRs.
Disclose the appropriate option:
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Note X ‐ Loans, Net
This additional TDR disclosure schedule presents loan pbalances by class, based on the type of concession granted:
Rate and MaturityPaymentOthOther
Totals in this schedule should agree with totals in theTDR activity scheduleTDR activity schedule.
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Note X ‐ Loans, Net
A summary of loans that were mod
Rate and
Maturity Payment Other Total
First Mortgages -$ -$ - -$
HELOC and Other Real Estate - - - -
Direct Vehic le - - - -
Indirect Vehic le - - - -
Credit Cards - - - -
Share/Certificate Secured - - - -
Other Secured - - - -
Other Unsecured - - - -
Commercial Real Estate - - - -Commercial Real Estate
Commercial Other
-$ -$ - -$
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Other Items to Consider
Changes in Accounting Policies or Methodology from the Prior Period
Need to disclose any material changes from the prior period and the entity’s rationale for the change.
Need to disclose the quantitative effect on current‐period provision.
Only disclosed when material.y
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Other Items to Consider
Other Qualitative Disclosures –Add if the CU has purchased loan participations:The Credit Union has purchased loan participations originated by various other credit unions/financialoriginated by various other credit unions/financial institutionswhich are secured by commercial property, real estate, and vehicles to members of other credit
i /fi i l i i i Th l i i iunions/financial institutions. These loan participations were purchased without recourse and the originating Credit Union/Bank performs all loan servicing functions on these loans.
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Other Items to Consider
Use only if CU has Third‐Party Sub‐Prime LoansThe Credit Union has third party sub prime loansThe Credit Union has third‐party sub‐prime loans outstanding of $_____ and $______ at December 31, 2011 and 2010, respectively. In addition, the Credit
$ $Union reported $_____ and $_____ in collateral in process of liquidation pertaining to the sub‐prime loan program as of December 31, 2011 and 2010, p g , ,respectively. Management evaluates the collectability of these loans and the collateral in process of liquidation on a monthly basis Management has reserved for thea monthly basis. Management has reserved for the estimated loan losses on this portfolio through its allowance for loan losses and has determined that there
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Pis no further impairment on the collateral in process of liquidation.
Other Items to Consider
Use if the CU has non‐traditional loans (1st mortgages or hybrid loans) and modify based on adjustable rate loans vs. interestloans) and modify based on adjustable rate loans vs. interest only –
The Credit Union offers non‐traditional mortgage loans to itsThe Credit Union offers non traditional mortgage loans to its members. These loans include hybrid and variable interest only mortgages. Hybrid loans consist of loans that are fixed for an initial period of three, five or seven years. After this period, the mortgagesperiod of three, five or seven years. After this period, the mortgages are converted to variable rates using an indexed rate, which can result in significant payment shock to the borrower. The interest only loans allow the borrower to pay only interest for a specifiedonly loans allow the borrower to pay only interest for a specified number of years. These types of loans may result in a lack of principal amortization or even negative amortization, if the minimum payment is less than the interest accruing on the loan
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Pminimum payment is less than the interest accruing on the loan
Best Practice Recommendations
Communicate with all necessary departmentsy pregularly (accounting, lending, collections)
Prepare monthly and YTD schedules throughout thePrepare monthly and YTD schedules throughout the fiscal year
Allowance activity roll forwardyImpaired loans (average recorded Investment and interestincome recognized)TDR activity roll forward
Adopt proof and validation procedures surrounding di l h d l
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Best Practice Recommendations
Define your loan “impairment” policy clearly and reportconsistently GAAP definition:consistently – GAAP definition:
“a loan is impaired when, based on current information and events, it is probable that a creditor will be unable to collect all amounts pdue according to the contractual terms of the loan agreement.”
Disclose the accounting policy basis for determiningDisclose the accounting policy basis for determiningcollective inherent impairment and individualimpairment classifications
Ensure your ALL adequacy model reconciles with yourfinancial statement disclosures
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Questions
Kenneth Welch, CPAPartner Credit Union GroupPh. (703) 825‐2182 K h l h@ lif l ll
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