FRS 109’s introduction of the Expected Credit Loss (“ECL”) model has fundamentally changed how provisioning for credit losses is being looked at by banks and other financial institutions. The transition to expected credit loss models requires cross functional support, with expertise around risk management, finance, IT and economic forecasting, being particularly important.
Grant Thornton’s ECL modelling specialists combine such skills and help implement provisioning methodology and process which are right for your business.
Three 'S'
Three ‘S’ define the key success factors for ECL implementation, i.e.
Suitability
Appropriate with reference to size and scale of the business, product profile, customer characteristics, and data/system maturity
Stability
Ability to provide reasonable results in various economic scenarios
Sustainability
Being efficient and accurate, and hence future proof
Design of ECL model
Our approach to ECL
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Policy formation
The key policies mentioned would be agreed upon in this step.
The result of this step shall be well deliberated, and documented conclusions on these areas.
Examples of possible questions to consider include:
- At what level should segmentation of loan portfolio be done?
- What should be considered as the threshold of ‘low’ credit risk?
- What should be definition of significant increase in credit risk (SICR) and default event
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Model development
- Design the methodology for probability of default modelling.
- Static pool transition matrix is typically done, but in case there is lack of historical data, use of market/proxy data would be necessary. For wholesale portfolio, externally available data like credit ratings is also generally considered.
- Identification of macro-economic factors that shall be considered.
- LGD models for the different portfolios is developed
- Design custom automated models, where required
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Identification and validation of inputs
- Evaluate the various sources of inputs (both internal and external), that can be used in the models, and advise on the appropriateness of each of them.
- Evaluate the forward-looking data that should be incorporated.
- Specify the major estimates and assumptions.
- Setting up triggers and benchmarks for future update of data
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Go live
- Develop process manual for future reference
- Document policies for formal internal approval
- Review and update the models as required
- Training and presentation to internal and external stakeholders
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