Adequacy of Farm Credit System Institutions' Allowance for Loan Losses and Risk Funds
April 26, 2004
To: The Chairman of the Board
The Chief Executive Officer
All Farm Credit System Institutions
From: Roland E. Smith, Chief Examiner
Office of Examination
Subject: Adequacy of Farm Credit System Institutions’ Allowance for Loan Losses and Risk Funds
This bookletter informs Farm Credit System (System) institutions of the Farm Credit Administration's (FCA or agency) expectations regarding the process used to determine the adequacy of their allowance for loan losses (ALL) and risk funds. This bookletter provides guidance to System institutions on principles for maintenance of an adequate level of the ALL to ensure prudent risk funds management. With the issuance of this bookletter, the agency's objective is to establish minimum criteria that each System institution should consider in its process used to determine the adequacy of its ALL and risk funds. Thus, the criteria communicated in this bookletter will be used by FCA examiners to evaluate the process a System institution uses to determine the adequacy of its ALL and risk funds. This bookletter also identifies key elements of sound business principles and practices for risk funds management by System institutions.
For many years, the Securities and Exchange Commission (SEC) and the other Federal banking agencies1 have provided guidance concerning their expectations regarding the ALL and related documentation. Most recently, in July 2001, the SEC issued Staff Accounting Bulletin (SAB) No. 102, Selected Loan Loss Allowance Methodology and Documentation Issues, and the other Federal banking agencies issued an Interagency Policy Statement on Allowance for Loan and Lease Losses Methodologies and Documentation for Banks and Savings Institutions (Interagency Policy Statement). Both the SEC's and the other Federal banking agencies' guidance focused significant attention on the level of documentation needed by lenders in order to support the amounts in their ALL accounts. SAB No. 102 and the Interagency Policy Statement reflect a continued refinement of accounting guidance that has served to shape industry and System practices in this area.
1We refer collectively to the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of Thrift Supervision as the "other Federal banking agencies."
To date, the agency has issued only limited formal guidance to System institutions on their ALL process. Section 621.5 of our accounting and reporting regulations set forth the agency's only regulatory requirement addressing the ALL of System institutions. This regulation, which was originally adopted in 1986, provides only the broad guidance that "[e]ach institution shall maintain at all times an allowance for loan losses that is adequate to absorb all probable and estimable losses that may reasonably be expected to exist in the loan portfolio" and "[d]evelop, adopt, and consistently apply policies and procedures governing the establishment and maintenance of the allowance for loan losses . . . ." The only other substantive agency guidance is an examination directive issued in June 1986. This directive outlines factors that the agency believes System institutions should consider in the evaluation of their ALL. The guidance in the directive is also very broad in nature. The intent of both the regulation and directive essentially was to have System institutions follow generally accepted accounting principles (GAAP).
Until now, the agency has not issued any formal guidance to System institutions with regard to our expectations for their risk funds management practices. The ALL represents a significant component of almost every System institution's risk funds. Thus, our examiners routinely evaluate a System institution's level of risk funds (i.e., ALL and capital) to assess its overall risk-bearing capacity. While the other Federal banking agencies' Interagency Policy Statement does not address risk funds, the guidance on risk funds management in this bookletter tracks best business practices with regard to boards of directors and management responsibilities.
Criteria for the ALL and Risk Funds Process
When a System institution determines the adequacy of its ALL and risk funds, we expect the process it uses to consider the following criteria:
I. FCS Board of Directors' Responsibilities
Effective board oversight of an institution's ALL determination is one of the keystones of a sound risk funds management process. Such oversight is crucial to a board's understanding of the process by which the institution estimates the losses inherent in the loan portfolio and determines that the level of its ALL is adequate. To properly fulfill its responsibilities, a board should at a minimum:
- Take measures to ensure its understanding of how the adequacy of the ALL relates to the overall business strategies of the institution, including those that relate to risk funds management;
- Direct management to develop and maintain appropriate policies, procedures, and internal controls that specifically address the institution's unique goals, systems, risk profile, personnel, and other resources necessary to identify the institution's exposure to loan losses and to ensure that an adequate level of the ALL and overall risk funds are continuously maintained to safeguard the institution against financial risks;
- Oversee and monitor the ALL process by ensuring internal controls are in place to consistently determine the institution's ALL in accordance with its policies and procedures and GAAP, including policies for recognition of impaired and nonaccrual loans and for recording loan charge-offs and recoveries;
- Direct management to develop documentation standards that require appropriate written supporting documentation for its ALL adequacy determination, build discipline and consistency into the ALL determination process, and ensure that all relevant factors are appropriately considered in the ALL analysis;
- Preclude management from implementing ALL methodologies that would allow the institution's earnings to be inappropriately manipulated;
- Review management's analysis and basis for its determination of the adequacy of the institution's level of the ALL in conjunction with its overall risk funds determination, including the basis for the institution's ALL methodologies and any revisions to the methodologies and/or overall process;
- Provide appropriate oversight, either directly or through a board-established audit committee, of the ALL process, including coordination and communication with the institution’s independent qualified public accountant having audit responsibilities with respect to the institution’s ALL process;
- Review and approve the overall level of the institution's ALL, including additions and reductions in its level and approval of any reductions of overall risk funds; and
- Ensure the institution is in compliance with FCA's regulatory requirements, the institution's policies, procedures, and internal controls, GAAP, and other applicable guidance that pertains to the maintenance of an adequate level of the ALL and prudent risk funds management.
II. Management's Responsibilities
Management is responsible for ensuring that the institution's risk funds are properly managed. Management should at a minimum:
- Develop and maintain procedures that translate the board's major business strategies and policies addressing the adequacy of the institution's risk funds into appropriate performance standards and expectations for risk funds management;
- Ensure the methodologies for determining the adequacy of capital, the ALL, and overall risk funds remain appropriate for the institution;
- Perform periodic reviews of the institution's lending and loan review functions;
- Maintain a record of its analysis and the basis for its determination of the adequacy of the institution's overall risk funds, including an assessment of capital and the ALL levels;
- Implement and maintain a management information system that appropriately tracks information necessary to assess the adequacy of the institution's risk funds; and
- Establish proper internal controls and audits of the risk funds management process.
Management should assess the adequacy of the institution's ALL on a regular basis but not less than quarterly. If management determines that the level of the institution's ALL is inadequate or excessive, a provision or reversal should be made to the ALL to assure the accuracy of financial statements. Likewise, management should ensure that loan losses are charged off to the ALL at the time a determination is made that a loan or portions thereof are known to be uncollectible and that recoveries are appropriately recognized when realized.
System institutions are expected to develop and document systematic methodologies to determine their ALL and related provisions for loan losses. Crucial to sound ALL methodologies is that they incorporate management's current judgments about the credit quality of the institution's loan portfolio through a disciplined and consistently applied process. It is important that the methodologies achieve a high level of correlation between changes in the level of the ALL and significant favorable or unfavorable trends in the quality of the loan portfolio. An institution's methodologies should be influenced by and tailored to entity-specific factors, such as the institution's size, organizational structure, business strategy, economic environment, management style, staff experience, loan portfolio characteristics, loan administration procedures, information systems, and internal controls.
While different institutions may use different methods, there are certain common elements that should be included in any methodologies to be considered effective. Each institution's methodologies generally should:
- Include a detailed analysis of estimated losses in the loan portfolio performed on a regular basis but not less than quarterly;
- Consider all loans (whether on a individual or group basis);
- Identify loans to be evaluated on an individual basis under Statement of Financial Accounting Standards No. 114, Accounting by Creditors for Impairment of a Loan, and segment the remainder of the loans (those that will not be individually evaluated) into groups of loans with similar characteristics for evaluation under Statement of Financial Accounting Standards No. 5, Accounting for Contingencies;
- Consider all relevant qualitative and quantitative factors that may affect loan collectibility including the risks associated with lending in a single sector;
- Be applied consistently but, when appropriate, modified for new factors;
- Consider the overall quality of the institution's credit review programs, the concentrations of lending in a single sector, and the overall quality and experience of management;
- Place emphasis on sound management judgment;
- Consider relevant observable data;
- Review historical loan loss experiences, taking into account current conditions;
- Consider the particular risks inherent in different kinds of lending, including changing government policy regarding agricultural subsidies and the volatility of the agricultural operating environment;
- Consider collateral values, repayment patterns, and off-farm sources of income;
- Require that the methodologies function be performed by competent and well-trained staff;
- Include an analysis of deterioration in concentrations of credit, classes of borrowers, and pledged collateral based on volume and type of loans;
- Give consideration to current economic conditions and trends in delinquencies and nonaccruals;
- Include an analysis of recent trends in portfolio volume, maturity, and composition;
- Be based on reliable data;
- Include clear explanations of the supporting analyses and rationale; and
- Include a systematic and logical method to consolidate losses.
IV. Documentation Standards
Documentation is critical to an institution's ALL process in that it provides evidence that its ALL is consistently maintained at an adequate level. Appropriate written supporting documentation for an institution's ALL facilitates the loan loss review process, builds consistency into the determination process, and ensures that all relevant factors are considered in the analysis process. An important part of the ALL process is that there is documentation supporting the relationship between the findings of the detailed review of the institution's loan portfolio and the level of the ALL and related provisions reported by the institution. An institution should establish documentation standards that address the following elements:
- Policies and procedures for the process, including an internal control system to ensure the integrity of the process;
- ALL methodologies and related validation process;
- Accounting policies for loans and loan losses, including policies for charge-offs and recoveries and the fair value of collateral, where applicable;
- Roles and responsibilities of staff and departmental units, including the lending function, credit review, financial reporting, internal audit, board and management, audit committee, and others, as applicable, who determine or review the level of the ALL reported in the institution's financial statements;
- Adjustments to the ALL process and methodologies;
- Loan-grading system and process; and
- Summary or consolidation of the ALL amounts.
V. Internal Controls
For safe and sound operations, each institution should maintain an internal control system over its ALL process. Sound internal controls will ensure that the institution's ALL process is reasonable, the level of the ALL is maintained in accordance with GAAP, and prudent risk funds management practices are in place. A sound internal control system should:
- Include measures to provide assurance regarding the reliability and integrity of information used in the ALL process;
- Assure compliance with relevant laws and regulations, internal policies and procedures, GAAP, and other applicable guidance;
- Include a review of the documentation that supports the ALL methodologies and process for completeness and sufficiency;
- Include a well-defined loan review process that contains an effective loan-grading system, ensures that all relevant loan review information is appropriately considered in estimating losses, and provides clear formal communications and coordination among all parties within the institution who are involved in the ALL process;
- Provide for an audit of the ALL process and the adequacy of the level maintained by a qualified public accountant who is independent of the institution; and
- Reasonably assure that the level of the ALL is adequate to cover the losses inherent in the institution's loan portfolio and is maintained in accordance with GAAP.
VI. FCA's Examination
FCA examiners will assess the adequacy of an institution's ALL and overall risk funds based on evaluation of the overall processes in use by the institution. The assessment will focus on the institution’s policies, practices, internal controls, documentation, methodologies, and other tools used to determine the adequacy of its ALL and overall risk funds. The performance results of an institution's risk funds management process will be considered when evaluating risk exposure levels in accordance with the FCA's Financial Institution Rating System.
This bookletter endorses the guidance issued by the SEC and by the other Federal banking agencies. The agency believes the guidance in this bookletter for the ALL, like the SEC's SAB No. 102 and the other Federal banking agencies' Interagency Policy Statement, is consistent with GAAP. In addition, the agency is issuing an examination bulletin (attached to our Informational Memorandum dated April XX, 2004) that establishes further direction for the agency's examination focus on System institutions' methodologies and documentation needed to support the ALL.
If you have any questions about this bookletter, please contact me at (703) 883-4160, or correspond with me on the Internet at e-mail address email@example.com, or Tom Holland, Special Examination and Supervision Division, Office of Examination, at (703) 883-4484, or correspond with him on the Internet at e-mail address firstname.lastname@example.org.
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