CECL Readiness Checklist Tool and Examiner Guide Released September 12, 2017
The CSBS State Supervisory Processes Committee, in consultation with state examiners, has developed and approved the above tool to help financial institutions prepare for the coming changes associated with the Financial Accounting Standards Board's (FASB) release of Accounting Standards Update (ASU) 2016-13, Financial Instruments—Credit Losses (Topic 326) commonly referred to as the Current Expected Credit Losses (CECL) method. The tool provides a framework that a financial institution could use to plan for the eventual implementation of these accounting changes. CECL will have a significant impact on the way a financial institution estimates and provides for credit losses and early preparation is prudent. The associated examiner guide provides talking points, limitations, and other information examiners might find helpful if the tool is encountered in an examination. As explained in the examiner guide, the tool is not intended to establish regulatory expectations or deadlines. This tool is offered as a resource and should be used as-needed. While some institutions may already be planning for CECL implementation, smaller institutions, in particular, reported difficulty understanding the changes and sought a straightforward tool to begin the planning process. This tool offers a means to get started and helps an institution set internal goals for the different implementation steps. It is understood that each institution will approach the implementation of CECL differently, and this tool is not an attempt to standardize the implementation process or set forth regulatory expectations. Questions about the tool or examiner guide should be directed to Kyle Thomas (firstname.lastname@example.org or 202-407-7131).
End of Exam Functions in ETS (released April 2017)
This job aid was created by the CSBS State Examiner Review Team (SERT) to help state examiners understand the different functions of the Examination Tools Suite (ETS) that are related to closing out an examination. State examiners are prohibited from uploading examination data from ETS directly into the FDIC’s ViSION system, other systems of record (such as the Interagency Exam Repository) are accessible to state examiners. This job aid explains the purposes and accessibility of these functions specifically for state examiners.
Loan Scoping Job Aid (released January 2017)
The Loan Scoping Job Aid was developed by the State Examiner Review Team (SERT) to improve the loan scoping process by providing a set of considerations and action steps to assist examiners in forming a comprehensive and thoughtful loan review scope using ETS. The job aid's concepts are less focused on meeting a pre-determined penetration ratio and more focused on locating risk. By encouraging examiners to consider less traditional risk criteria, the concepts may lead to a more effective examination and more valuable loan review experience from the institution's perspective.
BSA/AML Self-Assessment Tool (released January 2017)
CSBS and a group of state BSA/AML subject-matter experts developed the BSA/AML Self-Assessment Tool to be used at the discretion of a financial institution to help in the BSA/AML risk assessment process. It is flexible and intended to be adapted to each institution’s circumstances and risk profile. As the instructions above state, the tool is not a replacement for other aspects of an institution’s BSA/AML risk management program, but is an optional supplement to that program. It is our hope that this tool helps institutions more effectively assess and internally manage their BSA/AML risks and thus reduce some of the regulatory burden associated with BSA/AML risk management. The internal communication this tool encourages should lead to a more informed board and staff, reducing uncertainty and improving the institution’s risk posture. The Assessment Tool is available for use by any institution and is strictly optional.
We invite feedback and questions at email@example.com
NOTE: Zip file will download
Assets Requiring Enhanced Monitoring Template (released May 2016)
The Assets Requiring Enhanced Monitoring Template was developed by the State Examiner Review Team (SERT) in response to recent increases in the levels of credit documentation weaknesses and technical exceptions. Examiners desired a method to document and track credits that are not classified or listed as special mention, but exhibited certain weaknesses. As a result, SERT created this elective page to serve as a means to document, quantify, and communicate to management that such assets exist and enhanced monitoring is recommended.
This page was approved by the State Supervisory Processes Committee for discretionary use. It may be used as a report of exam page, a workpaper, or an exit meeting supplement as appropriate. An ETS template is available for download and may be saved to the Resource Library for examinations conducted in ETS. When saving the template, be sure to select Save-As and ensure the extension .ETSRES is in the filename. In the Save As Type dropdown menu, select All Files. This will ensure the ETS Resource File populates in the available files to import. See the Saving and Importing a Custom Template to the Resource Library job aid for instructions on how to save and import a custom template to the Resource Library.
For common questions and answers, see the Q&A document.
High Volatility Commercial Real Estate Examiner Job Aid (released August 31, 2015)
The regulatory capital rules (BASEL III) that went into effect January 1, 2015, introduced the concept of High-Volatility Commercial Real Estate (HVCRE), and require all loans that meet the definition of HVCRE to be reported separately from other commercial real estate (CRE) loans and assigned a risk weighting of 150% for risk-based capital purposes. This job aid was created by the CSBS State Examiner Review Team to help state examiners understand important aspects of a new designation of commercial real estate loans. It summarizes existing guidance to aid in identifying these loans, understanding contributed capital and other exemptions, and ensuring that these loans are accurately reported.
Revised Regulatory Capital Rules, Part 324 (Basel III) Examiner Job Aid (released November 2, 2014)
This job aid was developed through the State Examiner Review Team to provide a summary of the key changes with the revised Regulatory Capital Final Rule, which was issued by the Federal Reserve Board on July 2, 2013. Community banking organizations are subject to the new rule beginning on January 1, 2015. Many examiners have expressed a need for short guide that could be referenced when questions regarding the new rules are asked during examinations. As such, this two-page job aid highlights the key changes, provide tables of the new ratios and their phase-in schedules, and shares links to more comprehensive information that examiners may find helpful when discussing these important changes with bankers.
Payday Lending Chart of State Authorities (released July 2014)
The Payday Lending Chart of State Authorities is designed to provide users with quick reference information on state authorities covering payday lending. The chart was developed in response to requests from state regulators and others for a single source on payday coverage. The chart is in Microsoft Excel and contains information for every state. The 30 columns within the chart cover the following major areas: General Information, Loan Terms, Debt Limits, Collection Limits, and Regulatory Authority. Each column contains a filter for easy searching or comparisons of state to state authorities. This chart should be useful to state regulators, legislators, Congress, consumer advocates, industry, and anyone else interested in a quick reference on the state laws and authorities covering payday lending.
Third-Party Payment Processors Job Aid (released February 2014, revised August 2014)
The Third-Party Payment Processors Job Aid is to be used by examiners as a means to understand, identify, and assess the risks associated with institutions' relationships with a common type of third-party service provider known as a third-party payment processor or third-party sender (TPPP). This job aid contains examples of how financial institutions and their processor customers send transactions through the ACH network and illustrates how an institution's risk profile may change when accepting these types of customers. Finally, it contains a workprogram that helps examiners ensure management has performed the necessary due diligence and met certain requirements associated with these types of customer relationships.
Municipal Bond Job Aid (released October 2013)
The Municipal Bond Job Aid is intended to serve as a resource for state bank examiners analyzing municipal debt obligations. The job aid provides a summary of changes resulting from the implementation of the Dodd-Frank Act, compiles all relevant federal rules and guidance, provides metrics to use when determining an obligation's credit quality, and discusses potential impacts of a municipal bankruptcy. It is not intended to replace or supersede any procedures required by a particular state banking department.
Thrift Conversions Job Aid (released April 2012)
The Thrift Conversions Job Aid was developed by members of the SSPC and American Council of State Savings Supervisors (ACSSS). The job aid is intended to provide guidance to examiners and resources to state banking departments preparing for an conducting a conversion exam of a thrift institution.
TDR Job Aid (released October 2011)
The TDR Job Aid was developed by the State Examiner Review Team (SERT) as a tool to help field examiners identify and understand troubled debt restructurings. Following a six month pilot period, the job aid was revised and approved for publication by the SSPC (State Supervisory Processes Committee). The job aid is not meant to replace existing accounting guidance, rather it brings guidance and examples from various sources into a single document. It may be shared with institutions.
Loan Participation Job Aid (released January 2010)
The Loan Participation Job Aid was developed by SERT as a tool to assist examiners in identifying the unique credit risks associated with loan participation arrangements.