CECL banking solutions

CECL Solutions

Solving your compliance needs - with an eye to the future. CECL modeling, validation, implementation and methodology expertise can all be found at Baker Tilly.

CECL Solutions

Simplifying CECL with a flexible approach and full suite of services

Simplifying CECL with a flexible approach and full suite of services

Navigating the requirements of current expected credit losses (CECL) isn’t easy for most organizations because it’s complex and time-consuming. Baker Tilly advisors understand today’s regulatory hurdles and have the right methodology, technology and modeling experience to help clients not only achieve compliance, but to use their data to their strategic advantage.

Our full suite of CECL services

Implementation

Want a more strategic approach to the new standard? Baker Tilly CECL specialists achieve strategic insight by combining their deep industry knowledge in highly regulated financial service industries with their strong data science acumen and technology platform. The result is a custom solution that fits your business needs.

CECL service bureau

Baker Tilly simplifies your regulatory stress by providing you with the specialists you need, when you need them. Our Value Architects will go further with your implementation needs by assessing what model is best for you, then running it through our software on your timeline—monthly, quarterly, or annually. At Baker Tilly, we can give you simplicity of choice for information from a centralized database.

Validation

Looking for independent validation for your model? Baker Tilly CECL specialists bring another level of credibility. Our team offers a deep bench of financial services industry knowledge and regulatory compliance, data science and technology know-how as well as a track record of CECL model validation. We are ideally situated to help you with your third-party model validation needs.

Value beyond compliance

Get more from your regulatory compliance efforts — build business value with additional testing, reviews and data analyses all using the same data you are already preparing for your CECL process. Our data scientists can identify other strategic insights that can be pulled from your existing data — saving you time and increasing the value of your compliance data.

CECL implementation and validation

For the most critical of all your financial calculations, you can trust Baker Tilly — without worrying about augmenting your staff with hard-to-find data scientists who are well versed in the technology needed to get the job done. More than compliance services, our Value Architects™ bring an advisory mindset that not only protects your value, but also enhances it with a strategic lens to the future. Going beyond the typical one-size-fits-all approach, we customize our offerings, whether you need a full implementation or just specific issues addressed within your operations.

  • CECL Implementation – where you are developing a new CECL model that complies with the new standard
  • Outsourced CECL modeling – where you periodically bring in specialists to review and fine-tune the model for streamlined utilization of your model
  • Independent CECL validation – where you need an independent party to help you understand your key risks and validate the methods you’re employing in accordance with the policies and regulatory requirements (e.g., OCC, FDIC, FRB) specific to your organization

Our job is making your job easier and leaving you with the confidence you need.

Giving you the experience and tools you need to make the CECL transition more effective for your business.

Implementation

CECL Solutions | Implementation

You need a more strategic approach to CECL

Navigating the implementation requirements of the CECL standard isn’t something most companies have the knowledge or resources to take on themselves. Due to its complexity and time commitment, it’s difficult to manage without an advisor who not only understands today’s regulatory hurdles, but also knows how to draw on the right methodology options, technology and modeling experience to use data to your strategic advantage. Baker Tilly is here to make it simple for you.

CECL doesn’t identify a specific model, so companies are responsible for selecting, implementing and justifying the models they select. CECL implementations are an enterprise-wide activity, and it is expected that senior management, risk, legal, IT, etc., will all be involved. To provide you with the best methodology and model options, our solutions can be customized to just those you need — at the level of involvement you want.

Training – Educate your internal CECL team and key stakeholders to understand the new standard.

Gap analysis – Understand your current situation and what areas you need to address.

Data stratification – Segment your loan data to minimize your institution’s loan portfolio risk.

Implementing a technology platform – Identify and implement the right technology platform to model your CECL estimate.

Model selection and validation – Select the appropriate methodology option and model parallel runs using your data in our in-house modeling software.

Governance, compliance and risk restructuring – Re-evaluate and enhance governance, compliance and risk policies.

Internal controls testing – Evaluate and test your internal controls over financial reporting (ICFR).

CECL service bureau

CECL Solutions | Outsourced modeling

Rely on Baker Tilly to provide a customized and straightforward path to CECL compliance. We will handle your data on an as-needed basis, while taking into account your size and complexity requirements. Not only can we run your model, but we are also a full-suite CPA firm providing you much needed simplification of the CECL process to ensure all compliance needs.

How it works

  • You provide your data
  • We assess the data then process it through the model that is right for you
  • We provide you with the output of your data, meeting your regulatory compliance requirements
  • Data is ready to report

Validation

CECL Solutions | Validation

Experienced independent CECL model validation services when you need it

Independent validation will be required for models developed in-house or by a third party. For most organizations, validation will be required at least annually. For your financial statement impact, a best practice is an annual or periodic validation to understand any material impacts.

Our CECL model validation can include a wide range of procedures including:

Model governance and compliance – Evaluate policies and controls to verify the framework is sound and regulatory requirements are met.

Data inputs – Verify the accuracy and cleanliness of data going into the model.

Model assumptions – Review the assumptions developed against the historic behavior of the portfolio and the economic projections expected.

Model methodology and testing – Fully replicate the model using your data and assumptions and our in-house CECL model to identify any variances.

When you are looking to an independent third party for CECL model validation, Baker Tilly CECL specialists bring another level of credibility. Our team of validators have broad industry experience and knowledge in the areas of financial services and regulatory compliance, data science and technology that, when combined, help challenge your model to uncover any problems and provide you with the needed insights to remediate or adjust the model if necessary. Third-party validation provides you with confidence around key assumptions, and a deeper understanding of risk areas.

Value beyond compliance

CECL Solutions | Value beyond compliance

Model assumptions – review the assumptions developed against the historic behavior of the portfolio and the economic projections expected.

Through the data and processes used to comply with the myriad regulations your organization faces, our regulatory compliance and data scientists can build value. We will help you understand opportunities for growth, recognize risks in more proactive ways and glean insight from the metrics to help you run your business through:

Loan portfolio reviews – Understand exactly what your loan portfolio is made of including major concentrations, origination and migration trends, and pricing movements.

Stress testing and scenario analysis – Analyze how your loan portfolio will perform under stressed economic and financial conditions and develop strategies to mitigate the increased risk.

Capital adequacy and stress-testing analysis – Assess the impact on your institution’s capital levels that would arise from immediate unfavorable conditions or increased concentration limits.

Back-testing and assumption testing – Leverage the historical data provided during year-over-year CECL validations to perform real-time back-testing to major assumptions.

Data quality – Identify gaps in stored data or address data quality issues for subsequent CECL reviews and enhance data and processes for other integrated risk assessments (ALM, budgeting, etc.)

On Nov. 15, 2019, the Financial Accounting Standards Board (FASB) updated the effective date of the current expected credit losses (CECL) standard for certain small public companies and other private companies. The revised effective dates of the standard they updated at that time are as follows.

SEC filers, excluding smaller reporting companies (SRCs): Fiscal years beginning after Dec. 15, 2019

All other entities, including SRCs: Fiscal years beginning after Dec. 15, 2022 (1)

For calendar-year entities, adoption would be required on Jan. 1, 2023.

The scope

The scope is broad and applies to many financial assets. The CECL methodology applies to the measurement of credit losses on financial assets measured at amortized cost, including:

  • Financing receivables
  • Held-to-maturity (HTM) debt securities
  • Receivables from revenue transactions within FASB Accounting Standards Codification (ASC) Topic No. 606, “Revenue from Contracts with Customers” or ASC 610, “Other Income”
  • Receivables from repurchase agreements and securities lending transactions
  • Reinsurance receivables

It also applies to off balance sheet credit exposures not accounted for as insurance (loan commitments, standby letters of credit, financial guarantees, and other similar instruments, except for instruments within the scope of ASC 815, “Derivatives and Hedging”) and net investments in leases recognized by a lessor.

CECL implementation process

As the incurred loss model is being replaced with the CECL model requires advance planning to calculate allowance for loan and lease losses (ALLL) more efficiently. It also brings change for your data collection processes. Our experience and tools of understanding and implementing this standard — and the requirements and deadlines that go with it — allows us to help you plan for and implement its adoption in your accounting and financial reporting and data collection.

Model validation of CECL model or parallel run review

CECL is the largest accounting change the financial sector has seen in years. One of the biggest challenges is that it doesn’t have crystal-clear guidance. If you have already implemented/adopted CECL or currently running parallel runs of CECL model, you should consider having these CECL models independently reviewed and validated.

We’ve already helped a variety of banks and financial services companies confidently validate their CECL models. We can help yours, too.

Regulatory expectations

Baker Tilly model and credit risk professionals have a deep understanding of ALLL/CECL models, including:

  • Independent periodic model validation of CECL and other bank models (i.e. ALM/IRR, BSA/AML, liquidity, etc.)
  • 2001 and 2006 policy statement requirements
  • Prohibition of external auditors from performing under independence requirements (for institutions with more than $500 million in assets)