CECL disclosures

Turning CECL obstacles into opportunities

The Financial Accounting Standards Board (FASB)’s CECL trifecta of being principles-based, involving complex models, and requiring life-of-the-loan estimates with reasonable and supportable (R&S) forecasts will challenge financial statement preparers to develop useful, transparent disclosures. Similarly, these three elements will challenge financial statement users to understand both individual company results and industry comparability.

FASB appreciated the challenges CECL disclosure requirements would present, emphasizing the need for companies to determine the right “Goldilocks” level of disclosures. Furthermore, a major investment manager has suggested that complementing the required Generally Accepted Accounting Principles (GAAP) disclosures with non-GAAP disclosures may be needed to provide investors with a more useful representation of the allowance for credit losses.

Companies that develop informative and transparent CECL disclosures may be rewarded by the investor community upon adoption and, perhaps even more so, when the economy enters its first, post-CECL adoption recessionary period. A disclosure approach that “connects all the disclosure dots” including FASB’s credit quality indicator(s), CECL allowance measurement methodology, and the period-over-period allowance change attribution with the SEC’s critical accounting estimate disclosures should be valuable to investors.

Here’s how you can achieve it:

A possible disclosure approach

Heading toward a January 2020 adoption, financial statement preparers should increase their focus on defining their CECL disclosures approach. Consistent with the international and UK disclosure recommendations, a disclosure approach that connects and aligns the FASB’s credit quality indicator and allowance measurement disclosures with the SEC’s critical accounting estimate sensitivity disclosures should improve transparency and thus enhance understandability.

To connect the disclosure dots, it’s useful to start with the allowance measurement disclosures. These disclosures provide financial statement users with insight into the drivers of the allowance and current-period provision expense and useful information to estimate future CECL sensitivity, including the impact of changing economic forecasts.

In preparing these disclosures, companies also may find further disaggregation in portfolio segmentation useful from that disclosed today. Specifically, disaggregation may provide better linkage to the class of financing receivable disclosures and may better align modeling drivers with SEC accounting estimate sensitivity disclosures. For example, separating overall commercial loans into commercial/industrial and commercial real estate could better align discrete allowance measurement with specific SEC sensitivity disclosures.

Next, connecting the SEC’s MD&A critical accounting estimate sensitivity disclosures to the most significant factors that impact the allowance measurement would be important. Aligning these sensitivity disclosures with the significant allowance measurement drivers should provide financial statement users with key CECL insights needed to understand the risk in the credit portfolio and the associated allowance measurement. Given that R&S forecast changes should impact portfolio segments differently, additional sensitivity disclosure should be beneficial.

Finally, connecting the credit quality indicator(s) disclosures with the allowance measurement and sensitivity disclosures sets the foundation for a better understanding of the allowance. Recognizing the importance of selecting the right credit quality indicators, FASB emphasized that judgment should be used in their selection. Furthermore, given CECL’s new measurement requirements, it could be appropriate to change or perhaps increase the number of credit quality indicators from what was useful under an incurred-loss allowance model.

Meeting the 'Goldilocks' challenge

Developing the right CECL disclosure requirements approach to meet the “Goldilocks” challenge will likely be the most difficult financial disclosure decision preparers will face during their careers.

Using a disclosure approach that connects all the dots should help bridge the GAAP disclosure framework with the SEC MD&A framework. Absent some linkage between FASB’s and SEC’s disclosures requirements, financial statement users likely will be left to go it alone.

For sure, CECL brings a new level of uncertainty to the most closely analyzed number in banks’ financial statements. The CECL implementation journey thus far has had many twists and turns, but those twists and turns may be modest compared to the post-implementation disclosure journey. Clearly, a CECL perspective that connects and aligns all the credit and allowance disclosures could pay big “transparency dividends” for companies.