Thoughts About Your Accounting Close and Financial Reporting with a Remote Workforce

April 27, 2020 By CFO Consulting Partners

Many businesses are adopting social distancing strategies, including increased use of remote workforces to adapt to and fight through the Covid-19 crisis. Completing monthly, quarterly or annual financial reporting activities can be challenging to accomplish remotely, so we share our experiences in assisting clients to do so in this article. With thoughtful management, the efficiency and effectiveness of accounting and reporting processes can be maintained as much as possible with a remote workforce.

The physical separation of remote workforces adds difficulty to all involved. While many of the tools used under “normal operations” continue to be effective, the remote nature of the workforce may change the way in which the work product is compiled and assembled. It will also change the interaction needed between team members to complete, review and perform quality control on the work products. Therefore, leaders need to make extra efforts to overcome the difficulties of operating remotely.

Clearly define goals and project plans, and monitor and report on status. These disciplines are more important now than ever before to enable processes to run smoothly and avoid fire drills that are even more challenging in a remote environment.

Communicate more than “normal” so that everyone can become comfortable with remote work and interactions.

Ensure that the technology and information security requirements are in place so that your team can operate effectively on a remote basis

Working remotely and meeting critical finance, accounting and reporting deadlines requires significant focus to optimize team structure and workflows.

Use detailed project plans, checklists, timelines and other mechanisms to define project requirements, clarify roles within the team, identify dependencies, and communicate status. Monthly and quarterly closing checklists and similar outlines are extremely helpful for all required deliverables: Board and senior management reports, press releases, SEC reporting, etc.

Make resources available to all who need them in real time.
- Develop a file storage plan and use it consistently while maintaining appropriate access security over those files. Typically, companies will create a central folder for each period’s financial reports.
- Finished work products should be stored centrally and shared according to agreed-upon nomenclature so that team members can locate and process as needed.

One individual should own a document and be the gatekeeper for changes proposed by internal preparers, executive management, external legal and accounting advisors, investor relations etc.
- The gatekeeper should maintain version control so that reviewers can easily identify updates to the documents. “Track Changes” and blacklined documents help focus reviewers’ efforts.
- Establish deadlines for comments and limit the number of drafts to minimize time spent processing successive versions. Relevant comments will always need to be considered but avoid excessive wordsmithing once you have a solid document.

Success as remote team is tied to many factors: Convenient and secure access to information. Clear project plans and access to effective project management tools, deploying team members effectively and relentless communication while supporting individual needs for job satisfaction, growth and enrichment.

Larry Davis – ldavis@cfoconsultingpartners.com

Paul Karr – pkarr@cfoconsultingpartners.com

Eric Segal – esegal@cfoconsultingpartners.com

Newsletter – April 2020

April 8, 2020 By CFO Consulting Partners

Thinking Ahead – Accounting for Loan Losses During and After Covid-19

One of the many challenges posed by the current health crisis is the need for lenders to reassess their borrowers’ ability to repay their loans. While it may seem unfair, or even unseemly, to have to address this issue at this time, financial institutions will need to do exactly that in closing their books and reporting on the First Quarter of 2020 in their regulatory reports and (for SEC registrants) Forms 10-Q.

The accounting approach most community institutions are following, and on which we will focus here, is the traditional, probable incurred loss model. This model requires institutions to provide for losses that are probable to have been incurred under the GAAP literature in Accounting Standards Codification (ASC) 450, Contingencies, and 310, Receivables. In practice, this usually involves a modeled component, based on historical write-offs over a look-back period, and a qualitative component, based on the current state and trend of economic and other factors affecting the portfolio. A good summary of the factors to be considered in this qualitative analysis are the nine points summarized in an Interagency Policy Statement issued in 2006 by federal banking agencies, which can be found at this link: https://www.occ.gov/news-issuances/bulletins/2006/bulletin-2006-47a.pdf

Generally, increased loss provisions are expected but likely too few facts are available to make specific loss assumptions. Measuring specific incurred losses at the end of Q1 will be difficult and most likely will be addressed through additional qualitative factors. Reserve assumptions for those credits already under analysis should be reevaluated and likely dealt with across product and delinquency categories.

Following are the nine points from the Policy Statement, in italics, followed in each case by our comments:

1. Changes in lending policies and procedures, including changes in underwriting standards and collection, charge-off, and recovery practices not considered elsewhere in estimating credit losses. This would include loan forbearance and other regulatory relief measures enacted to assist with resolution of the crisis: https://www.fdic.gov/news/news/press/2020/pr20038a.pdf

2. Changes in international, national, regional, and local economic and business conditions and developments that affect the collectability of the portfolio, including the condition of various market segments. The effects of the current health crisis will be pervasive, as covered in the other points.

3. Changes in the nature and volume of the portfolio and in the terms of loans. Institutions will need to address any shifts in new lending – in some portfolio segments, new production will have stopped, and thus not be available to offset increased non-performing loans and normal amortization within those segments. Thus, looking forward and doing the math, loss rates will increase within these portfolio segments.

4. Changes in the experience, ability, and depth of lending management and other relevant staff. Will there be sufficient staff available to effectively manage the portfolio? Will remote collection efforts be as effective as prior techniques?

5. Changes in the volume and severity of past due loans, the volume of non-accrual loans, and the volume and severity of adversely classified or graded loans. A sharp increase in delinquencies can be expected, albeit delayed by the TDR forbearance mentioned above. The ultimate losses may be mitigated by any government guarantees that are available, as well as borrowers’ ability to access business interruption insurance.

6. Changes in the quality of the institution’s loan review system.
Improvements that strengthen the process of reviewing loans could be a mitigating factor. If however, the loan review process weakens, either because of staff illness or other limitations, this factor may be another reason to strengthen reserves.

7. Changes in the value of underlying collateral for collateral-dependent loans. Real estate loans will be a challenging area, as the impact of current developments on the commercial and residential real estate markets will take some time to shake out, however declines in market values seem likely.

8. The existence and effect of any concentrations of credit, and changes in the level of such concentrations. The effect of concentrations can become more severe as conditions in certain industry sectors worsen, and the relative size of concentrations can become larger as healthier loans run off in a low origination environment.

9. The effect of other external factors such as competition and legal and regulatory requirements on the level of estimated credit losses in the institution’s existing portfolio. These factors include forbearance that is enabled by legislation e.g., restrictions on foreclosure that lead to increased losses from deterioration in the physical condition of properties and/or in the property market.

Your portfolio consists of two types of borrowers: healthy and current borrowers who may be negatively affected by the duration and severity of the current crisis; and those already exhibiting financial stress (past due and delinquent accounts, businesses already under severe attack from a variety of sources including the lack of a viable internet strategy, lower cost of foreign competition, and many others) for which the current crisis may finalize their situation. Both may benefit from the governmental assistance and forbearance programs, however the exclusion from TDR accounting applies only to the former borrowers. You should track and maintain records of your borrowers’ status throughout the deferment and modification process in order to demonstrate those which are not TDRs.

We have discussed the challenge of first quarter reserving with senior representatives from several large accounting firms, and the following pieces of practical advice emerged:

* Now is not too soon to begin discussing reserving considerations with professional service providers, including auditors and consultants.

* Most institutions are targeting timely filings of their First Quarter reports, notwithstanding the grace periods being offered by regulators, including the FDIC and SEC. See the announcement of the grace periods at:
https://www.fdic.gov/news/news/financial/2020/fil20028.html
https://www.sec.gov/news/press-release/2020-53

* Auditors, regulators, analysts and other interested parties will be looking for a strengthening of the environmental/qualitative reserve, along with supporting evidence that identifies the impact of current events and links to any adjustments.

* Whatever process is followed, it will be necessary to step back and consider whether the result makes sense.

* Whatever answer is arrived at for First Quarter reporting, further adjustments will undoubtedly be required in the Second and Third Quarters as more information becomes available.

We are familiar with these issues and accustomed to working remotely. Please let us know if we can help in any way.

Note on CECL: Institutions that have adopted the new Current Expected Credit Loss Model in the First Quarter will have similar considerations, but with the additional challenge of adopting the new model. They should also consider the possible impact of the CARES Act on timing of adoption, and related regulatory actions, including the Federal Institutions Letter on the interaction between timing of adoption and capital relief:
https://www.fdic.gov/news/news/financial/2020/fil20032.pdf

Larry Davis – ldavis@cfoconsultingpartners.com
Paul Karr – pkarr@cfoconsultingpartners.com
Eric Segal – esegal@cfoconsultingpartners.com

Newsletter – October 2019

November 4, 2019 By CFO Consulting Partners

Insurance Update – Includes our Takeaways from the Annual SIFM Conference

We attended the Annual Conference of the Society of Insurance Financial Management held in Atlantic City, New Jersey, on September 15-18, 2019. This excellent and well-attended Conference brought together finance professionals from insurance companies and professional service providers to discuss topics of current interest. This update incorporates a few of the themes introduced by speakers at the Conference.

Overall:

Financial leaders in insurance will continue to be challenged by our rapidly changing industry and the real need to more quickly deliver meaningful financial information. Many financial executives are wrestling with support of innovative new products, how to best leverage new technology, accounting and tax changes, and the need to maintain a quality high workforce.

Meeting Evolving Customer Needs:

The needs of the industry’s customers continue to change, and finance teams need to be able to support their business partners in meeting those needs. This will require speed, agility and affordable cost. One potential enabler is automation, but the base finance and accounting processes themselves need to be evaluated to make sure they are optimized for existing technology and to avoid “paving the cow path” when new technology is implemented.

Where there is a lack of comfort with a source of management and financial information, for any reason, multiple sources tend to proliferate, which creates a need for a single source of the truth. Until that single source is achieved, the multiple sources need to be reconciled each and every reporting cycle. That effort, which can be considerable, should achieve the obvious control objectives as well as underscore the need to eliminate the multiple sources.

Implementing New GAAP for Credit Losses:

This new accounting standard has more applicability to insurers than some may realize. First, an outline of the effective dates for calendar year-end entities, incorporating the FASB’s tentative decision in October to defer certain dates:

1. Public business entities that meet the definition of an SEC filer, excluding “smaller reporting companies” (as defined by the SEC) – January 2020

2. All other entities – January 2023

Most insurers will expect the new GAAP (ASU 2016-13) to apply to held to maturity investments and commercial mortgage loans, BUT it also applies to reinsurance receivables! The new GAAP model, Current Expected Credit Losses (CECL), requires reserving expected future losses at the time the asset is initially recorded (there is no “probable” trigger anymore).

Reinsurance receivables therefore are required to be viewed as having a probability of default, which requires estimating both that probability and the amount of loss that would occur in the event of a default. There are several practical considerations to keep in mind in making these estimates:

For probability of default, where the insurer has no history of having experienced defaults in its reinsurance arrangements, it may be necessary to use industry statistics;
For amount of loss in the event of default, the required reserve may not be very sensitive to this estimate if the probability of loss is low.

For statutory accounting purposes, the rules on credit losses have not changed yet, but we can reasonably expect those rules to follow suit after the GAAP world has developed some experience applying the new standard.

Tips for Insurance Company CFO’s & CEO’s:

Merger & Acquisition-

As brokers perform due diligence on acquisition opportunities, client agreements should be reviewed to ensure that these agreements allow for transfer of the contract to the acquiring company. Otherwise the acquiring company could experience more rapid client attrition than anticipated.

With the reduction in tax rates, as companies model acquisition opportunities, companies should be sure to incorporate these lower rates in the net operating loss forward calculations

Supplemental Compensation-

Brokers need to thoroughly understand the terms of their Carriers’ Supplemental Compensation Agreements. A worthwhile exercise is to read each agreement and recompute the amount that should have been received for each of the last few prior payment periods. Then compare these calculations to the computations provided by the Carrier.

Product and Business Unit Performance-

Some companies are using expedient methodologies to allocate corporate overhead across business units or products – i.e., the allocation of overhead as a percent of revenue. In other cases, when business drivers are utilized to allocate these costs, expenditures needed to support the rapid future growth of one product are inappropriately distributed across all products. This occurs because current period business drivers are used to compute the current period cost allocations. As a result of these two allocation approaches, Product and Business Unit internal reports could be inaccurate.

Business intelligence tools and complex spreadsheets are often used to provide additional analysis. Financial information on these additional profit segments is used to make key decisions for business in a particular geography, industry, sub-product, or marketing channel. Control and review processes must be established in order to prevent the same revenue from being counted twice or partial capturing of certain costs.

The Insurance Industry team at CFO Consulting Partners are senior level professionals with CFO, Controller and Rating Agency experience. We have helped Carriers and Brokers manage credit ratings, implement strategic planning and business analysis functions, improve financial reporting and accounting processes, and strengthen internal controls.

by Michael Sheahan, Director, CFO Consulting Partners

and Paul Karr, Director, CFO Consulting Partners

Newsletter – October 2018

October 15, 2018 By CFO Consulting Partners

Why Does it Take So Long to Close?

Paul Karr, Director, CFO Consulting Partners LLC

This question gets asked at companies of all sizes and industries. Legacy processes and systems, combined with growth in scale and complexity of the business and often multiple sets of accounting principles, are some of the reasons for this. In this article we suggest some ideas on how to address this challenge.

People, processes and systems are the three key elements of any finance function. Each of these elements impacts the closing process, but the theme of this article is leveraging existing resources to see how the closing process can be improved within the context of the finance function’s existing resources.

Why start with the process, rather than implementing a new system, reorganizing or hiring personnel, or making other changes? For one thing, it’s more cost effective than making other, potentially expensive changes, particularly before the potential of the existing process has been fully realized. Also, implementation of a new accounting system necessarily requires focus on getting it done on time and on budget, which are obviously important objectives but take the focus away from process improvement, despite best intentions. The result can be automation of a suboptimal process, sometimes known as “paving the cow path.”

So where does one start the process work? We offer the following areas and suggestions for your consideration:

Closing period. Measure the days from the end of the accounting period to when the last journal entry has been booked and the financial statements have been prepared (the closing period). Not the day everyone wanted to be done, or should have been done, but the actual last day. If there are separate GAAP and regulatory financial statements and the timelines are different, they should be measured separately. The point of defining the closing period is to look at the true performance of the process as it exists today.

Closing activities. The activities during the closing period can be thought about in the following general categories:

- Drivers of last entries. Having laid out the timeline(s), the next issues to explore are what the last entries are, and why they happen when they do. Dependence on information from operations or other functions outside of accounting may be a factor here.

- Timing of activities. Further analysis of closing period activities can be done by putting them in the following buckets: (1) what can be eliminated (through standardization or other process improvements); (2) what can be done before the end of the accounting period (such as planning, estimates, some audit procedures); and (3) what can be done later.

- Account reconciliations. These are sometimes done late in, or after, the closing period. This timing can lead to late entries, unnecessary differences between GAAP and Regulatory or Statutory Accounting Principles, or between parent and subsidiary financial statements, and concerns for top management, auditors and regulators. This timing is often seen as the result of resource constraints, but it can also be driven by issues with the reconciliation process itself and unavailability of timely data to perform the reconciliations. These process and data issues need to be addressed, but a quick way to address timing is prioritizing account reconciliations based on risk and performing lower risk reconciliations on a rotating basis and/or at non-peak times.

Documentation. Roles and responsibilities are usually not as clear as people assume. Even if they were clear at one time, changes in personnel and in demands on the process can create significant, undocumented changes that may need to be addressed. Also, a question that can be asked here is, “would a new employee know what to do?”

Calendar. This needs to be sufficiently specific not only to know who is to do what and when, but to be able to measure whether the closing process is on track.

Pain points. There is a great opportunity here to ask everyone in the process what’s bugging them, from those providing the input, to those doing the accounting, to those using the products of the process. Everyone loves to do this! The only imperative is, once all the stakeholders have been debriefed and all the issues are on the table, it is important to do something about those issues, and be transparent about what is being done and when, even if some action is deferred.

We hope some of this resonates with you, and you see some opportunities for “quick hits” that can help build confidence on the part of your staff that process improvement is achievable. We can help assess your closing process, tailor an improvement program and manage the resulting improvement projects to successful completion. Please let us know if you would like to discuss.

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