Kevin Graff

How to Maximize the Benefit of an External Loan Review
Loan Review Series: Part 1 of 3

By: Kevin Graff, President

Third-party loan reviews can be an excellent way to manage a variety of risks a financial institution is exposed to.  These can include credit underwriting, credit administration, and reputational risks.  A loan review should provide insights into the effectiveness of the risk rating process, credit underwriting and credit administration function. 

Leveraging the overall loan review process will result in a more effective loan review.  Up-front time preparing for the review will maximize the return on investment in the loan review process.   Every loan review firm has their own approach to a loan review engagement. While the specific steps and processes may differ, they all require timely access to the credit file information and the appropriate personnel from the financial institution. 

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ACL Model Validation

Part III: Qualitative Adjustments

By: Peter Warmenhoven, Consultant

As previously mentioned in Part 2 of this ACL Model Validation series, financial institutions have recently transitioned to the new Current Expected Credit Loss, or “CECL” method of estimating the Allowance for Credit Losses (“ACL”). While much about the CECL method is unfamiliar, and while ACL calculation models vary, there are a few basic similarities with the previous incurred-loss method. First, historical loss information still provides the starting point and figures heavily into the “quantitative” calculation of an institution’s ACL.

Further, the CECL method still incorporates adjustments for qualitative and environmental factors into the ACL calculation, to adjust for how current or forecasted conditions differ from historical loss experience. The purpose of qualitative factors is to adjust for what is not in the historical loss analysis. An important difference with CECL is that management should apply a forward-looking thought process when evaluating these criteria.  Q-factor adjustments should address the differences in the current environment, and the current or expected conditions that indicate that future loss rates will be different than losses incurred in the past.

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The Enduring Relevance: Exploring the Timelessness of the 5 C’s of Credit 

By: Kevin Graff

As we begin a new year, the financial landscape is evolving at an unprecedented pace. Despite the whirlwind of technological advancements and the ever-changing dynamics of the banking industry, there exists a set of principles that stand the test of time—The 5 C’s of Credit. In this blog, we delve into the enduring relevance of these timeless principles and their fundamental role in navigating the complexities of the financial realm. 

Timeless, as defined by Merriam-Webster, is not restricted to a certain time or date. The concept of timelessness can be applied to many factors involved in commercial lending. While technological advancements in credit underwriting can make complex and difficult financial analysis seem easy, the basic tenets of commercial lending remain steadfast. These central principles included within Character, Capacity, Collateral, Conditions, and Capital provide the foundation for nearly every lending decision.  

Character: The Foundation of Trust 
The first of the 5 C’s, Character, remains the bedrock of sound lending practices. In an era dominated by algorithms and data analytics, the assessment of an individual’s integrity, honesty, and reputation remains unparalleled. The timeless nature of character evaluation ensures that trust, a currency more valuable than ever, continues to be a cornerstone in lending decisions.  

Capacity: Navigating Financial Waters 
Capacity, the second C, addresses the borrower’s ability to repay a loan. Despite the advent of sophisticated financial models, the ability to understand and analyze an individual or business’s capacity to meet financial obligations remains a linchpin in prudent lending. This timeless principle involves both art and science as borrowers face a continuously evolving economic landscape, proving its relevance in diverse financial scenarios.  

Collateral: A Tangible Safety Net 
Collateral, the third C, provides a tangible safety net for lenders. While technological innovations have introduced new ways of assessing collateral value, the fundamental principle of understanding the various nuances of pledged assets remains steadfast. The ability to understand how collateral may be impacted by changing market conditions ensures that this timeless principle remains effective in mitigating risk.  

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Can you believe it? Five years have passed since we embarked on this incredible journey, and we couldn’t have done it without you. We are thrilled to celebrate our 5th year in business, and we want to take a moment to express our heartfelt gratitude for your support. This milestone not only represents our achievement but the trust and loyalty you’ve shown us throughout this adventure. 

 Our success story is incomplete without the remarkable people who have supported us from day one  — our customers. We want to extend our deepest gratitude to each one of you.  You are the reason we are here today, and we promise to keep exceeding your expectations.  

 And to our team – we want to extend our heartfelt appreciation to our consultants who have been a driving force in our success. experience, hard work, and dedication has allowed us to expand into five states across the Upper Midwest, serve over 50 financial institutions, review over 2,300 credit relationships, and almost $14 billion in total portfolio commitments.   

 As we celebrate this milestone, we’re not just looking back; we are also looking forward to the exciting journey ahead of us. We value your feedback, and we remain motivated to keep improving.  

 Our 5th-year anniversary is not just about our accomplishments; it’s a celebration of the relationships we’ve built and the community that surrounds us. Thank you for choosing us as your trusted partner, and here’s to many more years of growth, success, and shared moments. We look forward to continuing this next chapter with you! 

Reviewing real estate appraisals and evaluations can seem a mundane but required task in the commercial lending process.  The commercial appraisal and evaluation (valuation) review process[i] within community-based financial institutions includes internally prepared reviews, third-party prepared reviews, or some combination of the two.  Often, the internally prepared review is completed by less experienced financial institution staff as a part of their training process, while some institutions have a dedicated appraisal and review department.  Loan officers may also perceive the review as a necessary evil rather than a risk management function.  The significance of the appraisal or evaluation review should be considered as a part of the pre-funding due diligence and risk management process, however pedestrian the process may seem.

Valuation reviews are a standard and vital part of a loan file review for commercial real estate lending transactions.  Recently our loan review activities identified two situations where the compliance review completed by the financial institution did not identify material flaws with the information included in the appraisal.   Both circumstances originated with a flawed appraisal engagement letter which did not appropriately identify the subject property.  The reviews of these valuations did not detect the mismatch between the appraised property and the property identified in the credit approval pledged to secure the transaction.  The result of the deficient appraisal review led to lending decisions using market values that did not represent the collateral pledged.

[i] The Uniform Standards of Professional Appraisal Practice (USPAP) 2010-2011 edition defines an appraisal review as the act or process of developing and communicating an opinion about the quality of another appraiser’s work that was performed as part of an appraisal, appraisal review, or appraisal consulting assignment. In addition, Section 1473(e) of the Dodd-Frank Act amended Section 1110 of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 to require the federal financial regulatory agencies, Federal Housing Finance Agency (FHFA), and Consumer Financial Protection Bureau (CFPB) to issue appraisal review standards.

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