When Should a Bank Start Using Migration Analysis?

Sageworks
May 6, 2013
Read Time: min

Migration analysis is a rigorous analytical process recommended by the regulatory agencies to determine financial institutions’ allowance for loan and lease losses or the allowance for credit losses under the current expected credit loss standard, or CECL. However, migration analysis is often underutilized in lieu of other processes that are perceived to be easier.

Migration analysis for determining loss rates

The purpose of migration analysis is to determine what rate of loss an institution has incurred on similarly impaired or past due loans. Typically under the incurred loss method of estimating credit losses, financial institutions that have a loan portfolio between $400-500 million should consider using migration analysis. There needs to be a large enough number of loans in the portfolio to make migration analysis work. Migration analysis not only requires segmenting your FAS 5 portfolio, but also requires sub-segmenting over time, for example into special mentions, substandard or doubtful. If you have a loan portfolio smaller than $500 million, the sample might be too small, leading to anomalies in the statistical analysis of each sub-segment. That would make migration analysis less effective.

Using migration analysis under CECL

Migration analysis, also known as a “Closed Cohort Migration to Loss” analysis, under CECL has sub-segmentation calculations for ordinal risk characteristics (times delinquent, risk rating, ordinal risk descriptor). This methodology both describes a life-of-loan number and can accurately price the additional risk for deteriorated loans. Typically, “Pass” credits will remain with low reserve and immediately receive additional allocation on migration through the risk levels.

Migration analysis is typically recommended for shorter lived pools (less than three years) that have risk diversity and reconciled controls around that risk diversity. It is typically sensible for renewing commercial credits. Migration analysis may not be recommended for pools with insufficient loss history, long-lived pools, or pools with no risk monitoring.

Additional information on migration analysis

To see a migration analysis example and learn more, read our whitepaper on the pros and cons of migration analysis and other CECL methodologies.

For help enhancing your current allowance processes, testing potential alternate CECL approaches, or adopting single or multiple methodologies, learn more about Abrigo’s Advisory Services.

About the Author

Sageworks

Raleigh, N.C.-based Sageworks, a leading provider of lending, credit risk, and portfolio risk software that enables banks and credit unions to efficiently grow and improve the borrower experience, was founded in 1998. Using its platform, Sageworks analyzed over 11.5 million loans, aggregated the corresponding loan data, and created the largest

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About Abrigo

Abrigo enables U.S. financial institutions to support their communities through technology that fights financial crime, grows loans and deposits, and optimizes risk. Abrigo's platform centralizes the institution's data, creates a digital user experience, ensures compliance, and delivers efficiency for scale and profitable growth.

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