Regulatory Agencies Issue FAQs on CECL

An inter-agency statement was jointly issued by the FDIC, OCC, FRB, and NCUA answering many of the frequently asked questions surrounding the new credit loss model, commonly referred to as CECL.  These FAQs are applicable to financial institutions with assets under $1 billion in total assets.   Some of the highlights to note are as follows:

  • Recommendations for applications of the new CECL standard
  • Tips for preparing for the implementation of CECL
  • Timeline

CECL Effective Dates

U.S. GAAP Effective Date Regulatory Report Effective Date*
PBEs That Are SEC Filers Fiscal years beginning after 12/15/2019, including interim periods within those fiscal years 3/31/2020
Other PBEs (Non-SEC Filers) Fiscal years beginning after 12/15/2020, including interim periods within those fiscal years 3/31/2021
Non-PBEs Fiscal years beginning after 12/15/2020, and interim periods for fiscal years beginning after 12/15/2021 3/31/2021
Early Applications Early application permitted for fiscal years beginning after 12/15/2018, including interim periods within those fiscal years

Full Statement

CLA continues to monitor this standard very closely and can be a resource for any questions your institution may have surrounding CECL.  Please reach out to your CLA representative in the event you have any questions and look for further communications in the near future.

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Joshua Juergensen is a principal with CLA. He works with banks and credit unions nationwide, managing audit engagements, directors’ exams, external loan file reviews, internal audits, and other consulting services.

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