Posted on Oct 3, 2017

CECL Considerations for Dealerships

The ECL will be reported in current earnings as an allowance for loan and lease losses (ALLL) in your entity’s financial statements. Because this new methodology could adversely affect a BHPH dealer’s net worth on financial statements, dealers will need to factor in CECL considerations and how adjusted financial statements could impact existing bank loan covenants or other credit agreements.

Banks will be aware of potential changes among their customers, but proactive communication will be important to ensure that relationships and access to credit remain intact.

Besides big changes in accounting methodologies for RFCs, it remains to be seen what this FASB standard means for established BHPH dealers seeking future access to traditional capital. BHPH loans, by their nature, are short-term loans with a high risk of default. Dealers rely on strong relationships with financing arms to purchase inventory and maintain operations through the ebb and flow of customer transactions and variable payment plans. As banks and other third-party financing arms adopt some form of CECL model for their portfolios, they will weigh the expected risk of loans even more heavily than before — which may limit their participation in financing higher risk industries like BHPH.

Well-managed BHPH dealerships can maintain strong cash flow by keeping customers in cars, collecting payments consistently, diversifying sources of revenue and reinvesting in a variety of inventory. As we have discussed in , there are ways to improve the scale and structure of your dealership to add value to the loan portfolio. We focus on your relationship with financing, your tax returns and operational changes to improve profits.

Download the Whitepaper: The Impact of New Credit Loss Standards on the BHPH Industry

In light of this new federal accounting standard for monitoring and calculating expected credit losses, BHPH operators of all sizes will likely require additional professional support. A CPA knowledgeable in BHPH operations can help you determine the standard’s impact on your current accounting methods, monitoring and reporting. Talk to the audit group at Cornwell Jackson to start planning for internal and external finance changes in the next few years.

Mike Rizkal, CPA is the lead partner in Cornwell Jackson’s Audit and Attest Service Group. He provides advisory services, including financial audit and attest services, to privately held, middle-market businesses. Contact him at mike.rizkal@cornwelljackson.com

 

 

 

Posted on Sep 22, 2017

Analysis Required

In a June 2016 report by Big Four accounting firm PwC, it stated that each entity’s “estimate of expected credit losses (ECL) should consider historical information, current information, and reasonable and supportable forecasts, including estimates of prepayments.”

The actual methodology used to calculate ECL is left up to each financial entity, so it may be that several models are tested and used in combination to assess loan portfolio risk. Again, the new methodology is an assessment of risk of future losses as opposed to calculation of actual incurred losses, so you will need to use reasonable judgments based on historic data and the nature of current contracts and customer profiles — even types of cars sold — to determine the ECL.

Let’s look at two methodologies commonly used by BHPH operators to determine portfolio value and discounts, and how these might be adjusted and work in tandem to support the new standard:

Vintage Analysis

Vintage analysis is based on loss curves that include expectations of losses at each point in the life of a financial asset. Under the CECL model, dealers would look at the remaining area under the loss curve rather than one point of time on the loss curve. Dealers can use vintage analysis to report expected credit losses on the remaining life of the assets in their portfolio. This calculation can then be measured against a baseline of portfolio performance.

Static Pool Analysis

A baseline of portfolio performance — that is, historic performance — must be established in order to forecast expected losses. Using a static pool concept, you collect data on common risk characteristics within existing segments or classes of loans. Using origination dates by same month, quarter or year will help you develop a pool that can be tracked for lifetime of loss. By looking back over several years of origination and collection data, you will develop a stronger baseline to support implementation of the CECL and recording a risk-focused ALLL on your financial statements.

Continue Reading: Other Considerations Relating to CECL

In light of this new federal accounting standard for monitoring and calculating expected credit losses, BHPH operators of all sizes will likely require additional professional support. A CPA knowledgeable in BHPH operations can help you determine the standard’s impact on your current accounting methods, monitoring and reporting. Talk to the audit group at Cornwell Jackson to start planning for internal and external finance changes in the next few years.

Mike Rizkal, CPA is the lead partner in Cornwell Jackson’s Audit and Attest Service Group. He provides advisory services, including financial audit and attest services, to privately held, middle-market businesses. 

Contact him at mike.rizkal@cornwelljackson.com.

Posted on Sep 12, 2017

BHPH dealers may need to consider data collection in ways they haven’t before, or ways of collecting data that weren’t required before, to develop forward-thinking estimates of credit loss.

For example, our clients will often review data on all the loans issued in a given month, and then analyze how those loans are performing as a gauge of how all loans are performing for the year (static pool analysis). They might see that 10 percent of loans defaulted in the first six months and another 10 percent defaulted in the next six months. Using that static pool of loans, the dealers will then calculate a discount rate before selling the portfolio to the RFC.

With the new standard, tracking average default rates for a short time period is not enough. Analysis will have to go deeper to determine “potential loss” over the life of loans. The final risk-based calculation will be reported in the dealer’s current earnings as an “Allowance for Loan and Lease Losses (ALLL)” on financial statements.

If the ALLL increases — as many think it will under this new standard — it will impact the net worth of a financial institution on its financial statements. That’s why it’s so important to collect the right data and make sure it is accurate. Incomplete or inaccurate historic data — such as data that has not historically been audited — will affect the accuracy of the final calculation

Operators may need to track data such as expected timing and extent of projected cash collections of the loan portfolio as well as projected losses and an estimate of future principal losses. In order to estimate future losses, it may also be helpful to track:

  • Actual cash value and type of vehicle sold
  • Customer risk assessments, including credit scores
  • Underwriters approving each contract
  • Collectors assigned to which loans
  • Loan performance data

The level of risk estimated also correlates to the amount of cash reserves an entity may be required to hold to support these expected losses over the life of the loan portfolio. Known as your entity’s “reserves for credit losses,” this amount may need to increase under the new accounting standard if you find that “expected credit losses” over the life of the loan portfolio are higher than the real incurred losses that previously guided reserves.

Continue Reading: CECL and Loan Portfolio Analysis

In light of this new federal accounting standard for monitoring and calculating expected credit losses, BHPH operators of all sizes will likely require additional professional support. A CPA knowledgeable in BHPH operations can help you determine the standard’s impact on your current accounting methods, monitoring and reporting. Talk to the audit group at Cornwell Jackson to start planning for internal and external finance changes in the next few years.

Mike Rizkal, CPA is the lead partner in Cornwell Jackson’s Audit and Attest Service Group. He provides advisory services, including financial audit and attest services, to privately held, middle-market businesses. Contact him at mike.rizkal@cornwelljackson.com

Posted on Sep 5, 2017

Following the global financial crisis of 2007 and 2008, the Federal Accounting Standards Board (FASB) has taken steps to mitigate risk among financial institutions. One of the newest standards is a change from the “incurred loss” accounting model used to evaluate financial portfolios to an “expected loss” model known as the Current Expected Credit Loss model (CECL). For BHPH dealers, CECL will require changes in loan and lease loss recording, which in turn requires changes in the type of loan data collected and how it’s analyzed. This article outlines what BHPH dealers can do to prepare for this sweeping change and why it’s important to start planning now.

At a recent TIADA conference, BHPH dealers and related experts were discussing the impact of the Current Expected Credit Loss (CECL) model on their industry.

New Credit Loss Standards

CECL was announced in 2016 as part of a new Federal Accounting Standards Board (FASB) update, and it “represents the biggest change to bank accounting ever,” according to Mike Gullette, vice president, Accounting and Financial Management, for the American Bankers Association. The implementation deadline is by 2021 for all financial institutions. The deadline for SEC filers is 2020, and these entities will likely set a course that non-SEC filers will use to develop their own standards methodology.

This new standard impacts any financial entity with the following assets, including Related Finance Companies (RFCs):

  • assets subject to credit losses and measured at amortized cost;
  • certain off-balance sheet credit exposures, including
    • loans
    • held-to-maturity debt securities
    • loan commitments
    • financial guarantees
    • net investments in leases
    • reinsurance and trade receivables.

In essence, CECL is designed to make financial institutions examine the future risk to their portfolios, not based on actual incurred losses in the portfolio but on expected loss. This expected loss isn’t reliant on annual loss rates, but on expected “life of loan” data or life of portfolio loss rates.

In future blog posts we will drill down on some immediate impacts to the BHPH industry — specifically on loan portfolio data collection, analysis and loan covenant considerations.

Continue Reading: Current Expected Credit Loss Model and Data Collection

 

In light of this new federal accounting standard for monitoring and calculating expected credit losses, BHPH operators of all sizes will likely require additional professional support. A CPA knowledgeable in BHPH operations can help you determine the standard’s impact on your current accounting methods, monitoring and reporting. Talk to the audit group at Cornwell Jackson to start planning for internal and external finance changes in the next few years.

Mike Rizkal, CPA is the lead partner in Cornwell Jackson’s Audit and Attest Service Group. He provides advisory services, including financial audit and attest services, to privately held, middle-market businesses. Contact him at mike.rizkal@cornwelljackson.com

Posted on Mar 14, 2016

New retail space available for rent

Many companies choose to lease certain assets, rather than buy them outright. Leasing arrangements are especially common among construction contractors, manufacturers, retailers, health care providers, airlines and trucking companies that rely on expensive equipment or real estate in their day-to-day operations.

FASB Chair Golden Speaks Out

Here’s what Financial Accounting Standards Board (FASB) Chair Russell Golden has to say about the new standard on accounting for leases, according to a FASB News Release on February 25:

“The new guidance responds to requests from investors and other financial statement users for a more faithful representation of an organization’s leasing activities. It ends what the U.S. Securities and Exchange Commission and other stakeholders have identified as one of the largest forms of off-balance sheet accounting, while requiring more disclosures related to leasing transactions. The guidance also reflects the input we received during our extensive outreach with preparers, auditors, and other practitioners, whose feedback was instrumental in helping us develop a cost-effective, operational standard.”

Financial Reporting Incentive to LeaseRoughly 85% of these leases aren’t reported on company balance sheets, according to estimates made by the Financial Accounting Standards Board (FASB). But that’s going to change under a new accounting standard — Accounting Standards Update (ASU) No. 2016-02, Leases (Topic 842) — that was issued on February 25.

Management may decide to lease assets for a variety of reasons. For example, they may not have enough cash for downpayments or access to financing — or they may not want to bear the risk that equipment will become technologically obsolete or property values will nosedive. In essence, leasing can allow companies to be more flexible, lower risk and adapt to changing market conditions.

From a financial reporting perspective, leasing offers an added bonus: Under the existing rules, a lease obligation is reported on the balance sheet of the company that leases the asset (the lessee) only if the arrangement is similar to a financing arrangement — then it’s considered a capital (or finance) lease. Otherwise, it’s an operating lease, which is expensed as lease payments are incurred and the terms are disclosed in the footnotes.

For example, if you lease a computer for most of its useful life and can purchase it for $1 at the end of the lease term, the arrangement would likely qualify as a capital lease. But it you sign a five-year lease on office space, it would probably be classified as an operating lease under current practice.

Globally, this treatment has allowed companies to hide trillions of dollars of operating leasing obligations in their footnote disclosures, rather than report them on their balance sheets.

The FASB Finalizes Long-Awaited Leasing Standard

The lease accounting project has been on the FASB’s agenda for more than a decade. In 2013, the FASB proposed the latest round of changes to lease accounting, which were largely aligned with an international accounting proposal on leasing. But these proposals were met with significant opposition across the world. So, the FASB and the International Accounting Standards Board subsequently abandoned their effort to create a converged lease accounting standard and separately went back to their own drawing boards.

The finalized standard on lease accounting under U.S. Generally Accepted Accounting Principles is a watered down version of the FASB’s 2013 proposal. It still allows for a distinction between how capital and operating leases are reported on the income statement and statement of cash flows.

Under the new standard, on income statements, capital leases will continue to be treated as financing transactions, meaning interest and amortization will be calculated with rent expense. Because interest is calculated on a declining balance over time, the cost of capital leases will look more expensive at the beginning of a lease. Leases that qualify as operating leases will be treated as simple rentals on the income statement. So, companies with rental-type contracts would report lease payments evenly over time.

The big difference under the updated guidance is that all leases with terms of more than 12 months will be reported on the balance sheet. In other words, lessees will report a liability to make lease payments, initially based on the net present value of those payments, and a right-to-use asset for the term of the lease. Companies can also elect to capitalize leases with terms of 12 months or less under the new standard.

In addition, lessees will need to expand disclosures about the terms and assumptions used to estimate their lease obligations, including information about variable lease payments, options to renew and terminate leases, and options to purchase leased assets. As a practical expedient, the new standard allows private companies and not-for-profit organizations to use risk-free rates to measure lease liabilities.

The new standard also provides guidance on how to determine whether a contract includes a leasing arrangement and, therefore, must be reported on the face of the balance sheet. For example, some “combined” contracts include lease and service provisions. These components generally need to be valued separately, because ASU 2016-02 requires companies to report only lease provisions on the balance sheet. For simplicity, however, the FASB allows companies with combined contracts to elect to also account for nonlease provisions under this guidance, if they prefer.

The FASB defines a lease as, “A contract, or part of a contract, that conveys the right to control the use of identified property, plant, or equipment (an identified asset) for a period of time in exchange for consideration. Control over the use of the identified asset means that the customer has both (1) the right to obtain substantially all of the economic benefits from the use of the asset and (2) the right to direct the use of the asset.”

Updated International Rules Issued in January Regarding Lease Accounting

On January 13, 2016, the International Accounting Standards Board issued its updated guidance on accounting for leases. The FASB and IASB agree on how to report leases on balance sheets. The main difference between the two standards is how expenses are reported on the income statement.

In general, all lease expenses will be treated as financing transactions and capitalized under the international standard. For companies that follow the international accounting standards, the effects will spill over to their income statements and statements of cash flows, not just their balance sheets.

The international rules also permit exemptions for certain small ticket items, such as copiers and coffeemakers. But there’s no specific threshold for which assets are considered “small ticket,” requiring companies to exercise judgment.

Effective Dates of New Lease Accounting Regulations

Fortunately, you still have time to get your accounting systems and lease agreements in order. The new standard goes into effect for fiscal years beginning after December 14, 2018 (in other words, in 2019 for calendar-year public companies). Private companies have an additional year to implement the changes.

This doesn’t mean you should put this standard on the back burner for long. The changes could be significant from current accounting practices if you rely heavily on leased assets. And public companies will need to start collecting comparative data in 2017 to meet the regulatory requirements of the Securities and Exchange Commission.

For more specific information about how this new standard will affect your financial statements, contact our in-house expert, Mike Rizkal, CPA.