Survey Number 2019-13

The Cooperative Credit Union Association invites your comments on the pending proposal to delay the implementation of the Financial Accounting Standards Board’s (“FASB”) current expected credit loss model (“CECL”). The full proposal is available HERE.

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Background:

FASB is requesting comments on a proposed Accounting Standards Update that would extend the implementation date of CECL for non-public business entities, including credit unions. 

Under the proposal, CECL provisions adopted in 2016 would be effective for credit unions for fiscal years beginning after December 15, 2022, instead of after December 2021 under the current FASB standard. The Association and others have raised issues with FASB about the effective date for credit unions. Member comments to the Association continue to indicate that credit union CECL preparation, including assembling the appropriate data, will be difficult for many. The Association has also consistently voiced concerns about the applicability of CECL to credit unions due to the complexity of CECL requirements and that credit unions are not publicly traded. 

Please contribute to this short survey to assist with the preparation of the Association’s comment letter on behalf of members by September 11, 2019.
Survey Questions:

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* 1.      Please indicate your credit union’s current status of CECL preparation:

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* 2.      Is a one (1) year delay beyond Dec. 2021 sufficient for your credit union’s operations to be ready for CECL compliance?

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* 3.      If one year is not sufficient, then please provide another appropriate time period to delay CECL?

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* 4.      What specific concerns does your credit union continue to have about complying with CECL?
Yes/No answers for each with a box to explain:

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* 5.      Have your examiners already questioned your loan loss reserve amount and suggested an adjustment in light of CECL requirements? 

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* 6.      If the proposal is approved, then this action marks the second time that FASB is delaying CECL. If FASB can delay CECL for credit unions and others, then do you agree that it is a signal that CECL may not be necessary for credit unions and others?

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* 7.      Some members of Congress have suggested that an economic impact study on matters such as pricing, credit availability, pro-cyclicality and the relationship of loan loss reserves and regulatory capital on credit unions be completed. Do you support such a study?

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* 8.      Rather than a delay, should FASB reconsider whether CECL should apply to credit unions?

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* 9.      Do you support a credit union or some other beneficial exemption from CECL?

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* 10.      Additional comments

Thank you for completing this survey by September 11, 2019. Please send any questions or comments to govaff-reg@ccua.org.
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