Getting ready for CECL: Advice for private companies | Deloitte US has been saved
By Marla Lewis, Audit & Assurance partner, Deloitte & Touche LLP
In the aftermath of the 2008 financial crisis, regulators realized that generally accepted accounting principles in the United States (US GAAP) rules for calculating bad debts (credit losses) had some sizable shortcomings. The rules at the time required companies such as lending institutions to calculate credit losses using an incurred loss model (ILM) based on probable credit losses. The mortgage meltdown, however, wreaked havoc on the ILM, and many investors that the information provided by the ILM about losses was “too little too late”.
To improve weakness in the ILM, in 2016 the financial accounting standards board (FASB) issued ASU 2016-13, which introduced the new CECL accounting standard. The standard took effect for public companies in 2020, with a stipulation that private companies would follow a few years later. The FASB indeed made the standard effective for most private entities as planned January 1, 2023 with the final implementation of ASC 326. Since then, Deloitte has received a number of questions about the standard from private company clients. What is it? How does it impact private companies? And what can we do to get ready? Here’s a brief overview of the CECL standard and what it does.
Unlike the backward-looking ILM, the CECL model requires companies to take a forward-looking view of their potential credit losses by estimating credit losses over the life of the asset when the asset first comes onto a company’s balance sheet. Estimated losses are recorded as a contra-asset, and both the initial expected loss and subsequent changes in the expected loss are generally recorded through net income. This method reduces risk by allowing companies, including banks and other lenders, to recognize credit losses earlier than with the previous ILM.
CECL applies to financial assets held at amortized cost: loans, debt securities, investments held to maturity, accounts receivable, trade receivables and contract assets that result from revenue transactions, and net investments in leases from the lessor’s perspective for sales type and direct financing leases. Assets measured at fair value are outside the scope of ASC 326.
With the CECL standard, it’s no longer enough to consider only previous credit loss data. In fact, the standard requires you to consider forward-looking information. These can include things like unemployment and GDP estimates. This future-focused approach is a significant change from typical accounting practices focused on reporting what happened in the past.
Companies now need to estimate the expected credit losses over the life of the financial asset when it is first originated or acquired. There is an expectation that a CECL allowance will be recorded on most financial assets. In certain situations, an entity can recognize zero credit losses—for example, for something like a US treasury bond held to maturity. But for other types of financial assets, there is generally an expectation that an allowance for credit losses will be recorded.
With CECL, there are no prescribed methods to develop an estimate of current expected credit losses. Companies should use a method that provides a faithful representation of expected credit losses based on the financial assets on its balance sheet.
The standard calls for pooling in-scope assets that share similar risk characteristics. That means segmenting a portfolio with common risk characteristics into categories—such as all borrowers with an AA credit rating or all borrowers in a specific geography. A financial asset that does not share risk characteristic with other assets should be evaluated individually for impairment.
The ultimate impact of the CECL standard on financial statements may not be material. But it is important to have sufficient documentation to support all judgments made by management. These include decisions that may result in immaterial changes to the financial statements or models already in place at the entity.
Deloitte can provide advice and recommendations to your company in assessing the impact of affected balance sheet items and assist in documenting its impact. Implementing ASC 326 may not require a significant overhaul of processes or controls. But updating policies to align with the standard will be important, and Deloitte can advise on that. To learn more about ASC 326, read our Accounting Spotlight or Heads Up. And don’t hesitate to reach out with any questions.
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Marla is a partner in Deloitte’s National Office Accounting and Reporting Services group, in which she is a part of the Income Taxes, Consolidation, and Financial Instruments subject matter teams, focusing on consultation and publication activities. Previously, Marla was a Practice Fellow at the Financial Accounting Standards Board, and led a number of standard-setting projects related to financial instruments. Marla has extensive experience serving clients in the financial services industry in both an audit and advisory capacity, and in helping clients with complex GAAP and SEC reporting matters.