Loan Participations, CECL, Stress Testing, Loan Modeling for Banks and Credit Unions

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In Regards to Proposed Rule 10-17-19 Interagency Policy Statement on Allowances for Credit Losses

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The proposed rule provides helpful comments on how the new Current Expected Credit Loss (CECL) standard should be managed, validated, and monitored. One seemingly simple statement, however, has significant implications.

In the sections “Analyzing and Validating the Overall Measurement of ACLs”, “Responsibilities …

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