ALLL best practices – Pay attention to qualitative factors
Abstract: Staying on top of the allowance for loan and lease losses (ALLL) is critical for banks, especially in the current economy. If examiners find that an ALLL is underfunded, they may downgrade the bank’s CAMEL rating, require it to increase capital levels or take other remedial action. One of the biggest challenges in calculating the ALLL is assessing the impact of qualitative, or “environmental,” factors that cause a bank’s loss estimates to deviate from its historical loss experience. This article looks at interagency guidance that provides a useful outline for this analysis, but also discusses best practices proposed by two examiners.