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Inc Incorporatin ing Economic ic For orecasts ts in into CECL July 19, 2018 Sohini Chowdhury PhD, Director Agenda 1. R&S Economic Forecasts 2. Beyond the R&S Forecast Horizon 3. Simple ECL Solution for Consumer Loans 2 1


  1. Inc Incorporatin ing Economic ic For orecasts ts in into CECL July 19, 2018 Sohini Chowdhury PhD, Director

  2. Agenda 1. R&S Economic Forecasts 2. Beyond the R&S Forecast Horizon 3. Simple ECL Solution for Consumer Loans 2

  3. 1 R&S Economic Forecasts

  4. FASB Requirements Topic 326 guidance “The measurement of expected credit losses is based on relevant information about past events, including historical experience , current conditions , and reasonable and supportable forecasts that affect the collectability of the reported amount. An entity must use judgment in determining the relevant information and estimation methods that are appropriate in its circumstances.” Source: Page 3, Financial Instruments — Credit Losses (Topic 326), FASB, No. 2016-13, June 2016 4

  5. What Makes an Economic Forecast Reasonable and Supportable? It is produced by a model which  Is based on sound, generally accepted economic and statistical theory  Incorporates inter-relationships and feedback effects among variables such that a shock to one factor impacts all other factors over time  Provides information at varying levels of geographic aggregation to capture local economic effects Our economic forecasting model meets these criteria 5

  6. Moody’s Scenarios Cover A Range of Possible Outcomes Scenario service, monthly updates with narratives and probability weights Real GDP, % change yr ago 8 Scenario Inventory 7 BAU/CECL-Driven 6 BL Baseline Forecast (50 th pctile) CB Consensus Baseline 5 S0 Strong Upside (4 th pctile) S1 Stronger Near-Term Growth (10 th pctile) 4 S2 Slower Near-Term Growth (75 th pctile) S3 Moderate Recession (90 th pctile) 3 S4 Protracted Slump (96 th pctile) 2 S5 Below-Trend Long-Term Growth S6 Stagflation 1 S7 Next-Cycle Recession S8 Low Oil Price 0 CS Constant Severity CB Consensus Baseline -1 S0 Baseline -2 Compliance-Driven S1 S2 FB Fed Baseline -3 FA Fed Adverse S3 S4 FS Severely Adverse Scenario -4 17 18 19 20 21 22 23 24 BC Bank-Specific Scenario Source: Moody’s Analytics 6

  7. How to Use R&S Economic Forecasts in CECL? Options – 1. Use forecasts and narratives to inform CECL estimate: qualitative overlay approach Select a single scenario to derive “official” CECL estimate: quantitative overlay approach 2. » Run shadow scenarios to inform any qualitative adjustments 3. Estimate CECL under several alternative economic scenarios: multiple scenarios approach Compute the probability weighted average a s the “official” CECL estimate » 4. Estimate CECL under several thousand simulated scenarios: simulated scenarios approach Compute the mean as the “official” CECL estimate » 7

  8. 1. Qualitative Overlay Approach Institution may use a vintage- loss rate approach to estimate CECL An expected increase in unemployment within their geography justifies an increase in their loss estimate. 8

  9. Capture Local Conditions Dallas is expected to outperform TX, US Unemployment rate, % 10 9 Dallas Texas US 8 7 6 5 4 3 2 00 05 10 15 20 25 30 35 40 45 Sources: BLS, Moody’s Analytics 9

  10. 2. Quantitative Overlay Approach ECL estimation with baseline, adjusted for stress 0.7 Quarterly conditional Institution may use a formal PD-LGD approach with Baseline probability of default, % a preferred scenario to estimate “official” ECL 0.6 Scenario 3 Run shadow scenarios to measure sensitivity to 0.5 alternative economic scenarios 0.4 Qualitatively adjust “official” ECL based in part on 0.3 these exercises 0.2 ECL = PD*LGD*EAD 0.1 Qtrs from forecast start 0.0 1 3 5 7 9 11 13 15 17 19 10

  11. 3. Multiple Scenarios Approach (OTS) ECL estimation with range of scenarios Institution may use a formal PD-LGD approach with 0.7 Quarterly conditional set of alternative scenario to estimate ECL Baseline probability of default, % 0.6 Scenario 3 Range of upside and downside scenarios provide Scenario 1 insight into sensitivities 0.5 Quantitatively combine ECL estimated from each 0.4 scenario to compute probability weighted ECL 0.3 Lifetime ECL 16% 30% wgt 0.2 14% 12% 0.1 10% 8% Qtrs from forecast start 0.0 6% 40% wgt 30% wgt 4% 1 3 5 7 9 11 13 15 17 19 2% 0% Baseline Scenario 1 Scenario 3 Wt Avg 11

  12. Multiple Scenarios Approach (Custom) Use Scenario Studio to tweak Moody’s OTS scenarios to incorporate management’s views » Web-based application to develop scenarios » Uses Moody’s Analytics validated macro models » Forecast governance built into the application – Audit trail of edits to assumptions – Test edits in a sandbox environment before committing them to the “official” forecast – Transparency of equations and assumptions » Collaborate with colleagues or Moody’s Analytics economists on the same forecast – Simultaneous read/write access 12

  13. Example: 10-Year Treasury Forecast Equation 13

  14. 4. Simulation Approach ECL estimation with simulated scenarios 16% 14.9% 14% Based on 1000 simulations Based on MA OTS scenarios 12% Lifetime ECL from different scenarios/simulations 10% 8.7% 7.7% 7.4% 8% 5.1% 6% 4.0% 4% 2% 0% Simulated Simulated Scenario 1 Baseline Scenario 3 Scenario Average Median Weighted 30% wgt 40% wgt 30% wgt Average Source: Moody’s Analytics 14

  15. So…which is the Recommended Approach? Depends on firm size/complexity Approach Recommended Firm Size Pros Cons (by Assets) • Easiest to explain • Hardest to defend Single scenario Smallest • Easiest to implement • Qualitative overlay • Hard to quantify operationally • Likely to produce more volatile ECL estimates compared to multiple scenarios • Easier to implement than Single scenario • Depending on the scenario chosen, • Quantitative overlay multiple scenarios Small/Medium could produce less conservative ECL • Easy to explain estimates compared to multiple scenarios approach • Likely to produce more • Operationally more complex to Probability-weighted multiple scenarios stable ECL estimates than implement than single scenario Medium/Large • Moody’s OTS • May require additional single scenario • Custom • Likely to produce more documentation to support scenario conservative ECL estimates customization • Produces most accurate • Operationally most complex, given ECL estimates Simulated scenarios tight quarterly reporting deadlines Largest • Recognizes future business • Hardest to explain cycles 15

  16. 2 Beyond the R&S Forecast Horizon

  17. What is the R&S Forecast Horizon? Depends on BOTH the credit loss models and the economic forecast models Credit Loss Models Economic Forecast Models » Is the length of observed historical » Are forecasts for forward-looking drivers performance sufficient to project losses? econometrically determined? » Is observed history of performance relevant for » Are data with limited history being the future time horizon? extrapolated? » Is the methodology used reasonable and » Are economic cycles being forecasted in supportable over the time horizon? a reasonable fashion? 17

  18. What to do Beyond the R&S Horizon? Topic 326 guidance … for periods beyond which the entity is able to make or obtain reasonable and supportable forecasts of expected credit losses, an entity shall revert to historical loss information …An entity shall not adjust historical loss information for existing economic conditions or expectations of future economic conditions for periods that are beyond the reasonable and supportable period. An entity may revert to historical loss information at the input level or based on the entire estimate . An entity may revert to historical loss information immediately, on a straight-line basis, or using another rational and systematic basis (326-20-30-9 ) … some entities will use this reversion technique, while others may have the systems and processes in place to forecast over the estimated life of the financial asset on a reasonable and supportable basis . (BC53) 18

  19. Options for Reversion Approach R&S Forecast Horizon Problems Lifetime horizon. May lead to low estimates of Input Reversion Revert model inputs to losses in the out years when long-term trends. scenarios converge. Requires definition of historical Institution-specific. loss rate Revert model outputs to • What is the historical historical loss rates Output Reversion time period? immediately or gradually • should we control for with decay. credit quality, product, age? Either approach will need to be defended as reasonable and supportable. 19

  20. Input Reversion Example Moody’s Analytics scenarios revert to historical trends in the long -run U.S. Unemployment rate, % 10 Moody's Analytics Baseline 9 Moody's Analytics Scenario 1 8 Moody's Analytics Scenario 3 7 6 5 4 3 2 00 05 10 15 20 25 30 35 40 45 Sources: BLS, Moody’s Analytics 20

  21. Assume credit model is Output Reversion reasonable and supportable for 36 months Monthly Conditional Loss Rate, % 0.25 0.20 0.15 Model 0.10 Model + Input Reversion Historical Portfolio Loss Rate Immediate Loss Reversion 0.05 Gradual Loss Reversion 0.00 0 12 24 36 48 60 Months on book (age) Source: Moody’s Analytics 21

  22. 3 OTS ECL Solutions for Consumer Loans

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