As a credit risk consulting firm that supports community and regional banks, Ardmore Banking Advisors has assembled some credit risk management best practices when it comes to how executives should look at their bank’s portfolio during the coronavirus-induced economic crisis.
It is clear that the expectation of regulators is that credit risk management programs (including identification, measurement, monitoring, control and reporting) should be enhanced and adapted to the current economic challenges. Credit risk management programs require proactive actions from the first line of defense (borrower contact by loan officers), the second line of defense (credit oversight) and the third line of defense (independent review and validation of actions and risk ratings).
Boards will have to enhance their oversight of asset quality. Regulators and CPAs will be focusing on process and control, and challenge the banks on what they have done to mitigate risk. Going concern opinions on borrowers by CPAs may become widely used, which will put pressure on banks to be conservative in risk ratings.
New regulatory guidance and best practices indicate that more forward-looking, leading indicators of credit must be employed. We expect greater emphasis on borrower contact and information on liquidity and projections. These concepts are also embodied in the new credit loss and loan loss reserve model that went into effect at larger banks in the first quarter.
Many banks have used Covid-19 as an opportunity to increase their loan loss provisions, reviewing their portfolios for weaknesses in borrowers that may never recover. This evaluation will be expected by regulators during examinations; it is a good indication of forward-thinking proactive oversight by a bank’s officers and directors.
Risk Rating Approaches in the Current Climate
When it comes to risk ratings, it is not advisable for banks to automatically downgrade entire business segments. Instead, executives should scrutinize the most vulnerable segments of the portfolio that include highly stressed industries and types of loans.
Banks do not have to downgrade modifications or extensions solely because they provided relief related to Covid-19; however, the basis for extensions or modifications should be evaluated relative to the ultimate ability of the borrower to repay their loans going forward, after the short-term disruption concludes or the deferral matures.
We have observed that regulators are focusing on second deferrals and asking whether a risk rating change or troubled debt restructuring are warranted. Banks should be reviewing information on further deferrals to determine if there could be an underlying problem indicating that payment is ultimately unlikely.
Paycheck Protection Program loans do not require a downgrade; however, banks may want an independent review of PPP loans to identify any operational or reputational risk. We also recommend that current customers who received PPP loans should be evaluated for their ability to repay other loans once the short-term disruption concludes.
Credit review, the third line of defense, is typically a backward-looking exercise, after loans are already made and funded. It is predicated primarily on an independent review of the analysis of borrowers by loan officers during the first line of defense, and credit officers in the second line of defense. For over 10 years, the industry has experienced relatively good economic times. The current environment requires a more insightful assessment of the bank’s actions and the borrower’s emerging risk profile and outlook, with less reliance on past performance.
The bank should evaluate historical and recent financial information from the borrower as a predicate for evaluating the borrower’s ability to withstand current economic challenges. Executives should review any new information reported by the bank’s officers on the current condition, extensions or modifications provided and the current status of the borrower’s operations to determine if a risk rating change is necessary.
Importance of Credit Review for Banks
Banks must look carefully at risk ratings to confirm that all lines of defense have properly reviewed the borrowers, with a realistic assessment of their ultimate ability to repay the loan after any short-term deferrals, modifications or extensions due to the Covid-19 disruption. This includes an assessment of whether the action requires formal valuation of troubled debt restructuring status. The banks can then follow the current regulatory guidance that an extension or modification does not in itself require a designation as a TDR.
We believe based on our years in banking that the bank regulators will test the bankers’ response and process in the current economic downturn. They, and the CPAs certifying annual financial statements, will expect realistic credit risk evaluations and controls as confirmed by independent and credible loan reviews. Bank boards and executive management teams will be well-served by accurate loan and borrower credit risk assessment during regulatory exams and the annual financial CPA audits for 2020.