On Monday June 15th the Federal Reserve announced that it is resuming examinations for Banks of all sizes. The Fed specifically stated that the rationale for this decision is that “As financial institutions have had time to implement contingency operating plans and adapt operations to the COVID-19 operating environment, the Federal Reserve is resuming examination […]

On May 8, 2020, the FDIC, Federal Reserve Board, OCC and NCUA, jointly issued the final Interagency Guidance on Credit Review Systems (1).  Below is a summary of the guidance as provided by CEIS Review. This Interagency Guidance (1) replaces the guidance in– Loan Review Systems, which is part of the December 2006 Interagency Policy Statement on […]

On February 20, 2020, the four US Banking regulators (OCC, FRB, FDIC and NCUA) issued the final policy statement for the financial institution adoption of CECL, the FASB (ASU 2016-13) change from an incurred loss (IL) reserving methodology to an expected loss (EL) methodology. This methodology is a forward looking reserve determination and is calculated […]

Overview of Initial Impact. How Should Lenders Prepare? Over the last few weeks, I’ve been researching the potential financial impact of the COVID-19 Pandemic and reflecting on the economic aftermath relative to previous crises. Although there are some commonalities in all crises (i.e. volatility, disruption), I believe that COVID-19 is profoundly different. The harsh reality […]

Over the past 8 weeks impacts of the actions taken to safeguard everyone from the virus and “flatten the curve” have forced many changes on both our personal and professional activities. As we begin the task to assess these changes and their potential impacts we need to also evaluate what tools are available to help […]

Ten years ago, in the aftermath of the financial crisis the banking community and regulatory authorities embraced the use of enhanced modeling and stress-testing to ward against a future event having such an significant impact on the Nation’s banking environment. Those efforts aided by strong economic recovery, have resulted in increased capital levels and stronger […]

CEIS Review understands that banks have heightened their consideration of “today’s” reserve level adequacy and plans for near to medium term provisions. Reserve levels are currently being impacted by a number of events, some of which are difficult to quantify and will only emerge over time. Decisions need to be made and there are several […]

In response to the COVID-19 the Board of Governors of the Federal Reserve System, Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, National Credit Union Administration , and Office of Comptroller of the Currency issued a joint statement, on March 26th encouraging banks, savings associations and credit unions to offer responsible small-dollar loans to consumers […]

The US Department of Commerce has created a dedicated website to aid small business owners regarding the Federal Governments CARES Act and obtaining Grants or Loans. The Coronavirus Aid, Relief, and Economic Security (CARES) Act allocated almost $350 billion to help small businesses keep workers employed amid the pandemic and economic downturn. Known as the […]