Rating Credit Risk

As of May 17, 2012, this guidance applies to federal savings associations in addition to national banks.* A-RCR Comptroller of the Currency Administrator of National Banks Rating Credit Risk Comptroller’s Handbook April 2001 Updated June 26, 2017, for Nonaccrual Status A Assets As of May 17, 2012, this guidance applies to federal savings associations in addition to national banks.* Rating Credit Risk Table of Contents Introduction Functions of a Credit Risk Rating System ............................................. 1 Expectations of Bank Credit Risk Rating Systems ................................. 3 Developments in Bank Risk Rating Systems ........................................ 4 Risk Rating Process Controls ............................................................... 8 Examining the Risk Rating Process .................................................... 11 Rating Credit Risk ............................................................................. 13 The Credit Risk Evaluation Process ................................................... 21 Financial Statement Analysis ................................................... 22 Other Repayment Sources ...................................................... 24 Qualitative Considerations ...................................................... 24 Credit Risk Mitigation ............................................................. 25 Accounting Issues ............................................................................. 31 Appendices Appendix A: Nationally Recognized Rating Agencies Definitions ..... 35 Appendix B: Write-Up Standards, Guidelines, and Examples ............ 41 Appendix C: Rating Terminology ...................................................... 51 Appendix D: Guarantees .................................................................. 53 Appendix E: Classification of Foreign Assets ..................................... 54 Appendix F: Structural Weakness Elements ....................................... 62 References ................................................................................................ 67 Comptroller’s Handbook i Rating Credit Risk As of May 17, 2012, this guidance applies to federal savings associations in addition to national banks.* Rating Credit Risk Introduction Credit risk is the primary financial risk in the banking system and exists in virtually all income-producing activities. How a bank selects and manages its credit risk is critically important to its performance over time; indeed, capital depletion through loan losses has been the proximate cause of most institution failures. Identifying and rating credit risk is the essential first step in managing it effectively. The OCC expects national banks to have credit risk management systems that produce accurate and timely risk ratings. Likewise, the OCC considers accurate classification of credit among its top supervisory priorities. This booklet describes the elements of an effective internal process for rating credit risk. It also provides guidance on regulatory classifications supplemental to that found in other OCC credit-related booklets, and should be consulted whenever a credit-related examination is conducted. This handbook provides a comprehensive, but generic, discussion of the objectives and general characteristics of effective credit risk rating systems. In practice, a bank’s risk rating system should reflect the complexity of its lending activities and the overall level of risk involved. No single credit risk rating system is ideal for every bank. Large banks typically require sophisticated rating systems involving multiple rating grades. On the other hand, community banks that lend primarily within their geographic area will typically be able to adhere to this guidance in a less formal and systematic manner because of the simplicity of their credit exposures and management’s direct knowledge of customers’ credit needs and financial conditions. Functions of a Credit Risk Rating System Well-managed credit risk rating systems promote bank safety and soundness by facilitating informed decision making. Rating systems measure credit risk and differentiate individual credits and groups of credits by the risk they pose. This allows bank management and examiners to monitor changes and trends in risk levels. The process also allows bank management to manage risk to optimize returns. Comptroller’s Handbook 1 Rating Credit Risk As of May 17, 2012, this guidance applies to federal savings associations in addition to national banks.* Credit risk ratings are also essential to other important functions, such as: • Credit approval and underwriting C Risk ratings should be used to determine or influence who is authorized to approve a credit, how much credit will be extended or held, and the structure of the credit facility (collateral, repayment terms, guarantor, etc.). • Loan pricing C Risk ratings should guide price setting. The price for taking credit risk must be sufficient to compensate for the risk to earnings and capital. Incorrect pricing can lead to risk/return imbalances, lost business, and adverse selection.1 • Relationship management and credit administration C A credit’s risk rating should determine how the relationship is administered. Higher risk credits should be reviewed and analyzed more frequently, and higher risk borrowers normally should be contacted more frequently. Problem and marginal relationships generally require intensive supervision by management and problem loan/workout specialists. • Allowance for loan and lease losses (ALLL) and capital adequacy C Risk ratings of individual credits underpin the ALLL. Every credit’s inherent loss should be factored into its assigned risk rating with an allowance provided either individually or on a pooled basis. The ALLL must be directly correlated with the level of risk indicated by risk ratings. Ratings are also useful in determining the appropriate amount of capital to absorb extraordinary, unexpected credit losses. • Portfolio management information systems (MIS) and board reporting C Risk rating reports that aggregate and stratify risk and describe risk’s trends within the portfolio are critical to credit risk management and strategic decision making. • Traditional and advanced portfolio management C Risk ratings strongly influence banks’ decisions to buy, sell, hold, and hedge credit facilities. 1 Adverse selection occurs when pricing or other underwriting and marketing factors cause too few desirable risk prospects relative to undesirable risk prospects to respond to a credit offering. Comptroller’s Handbook 2 Rating Credit Risk As of May 17, 2012, this guidance applies to federal savings associations in addition to national banks.* Expectations of Bank Credit Risk Rating Systems No single credit risk rating system is ideal for every bank. The attributes described below should be present in all systems, but how banks combine those attributes to form a process will vary. The OCC expects the following of a national bank’s risk rating system: • The system should be integrated into the bank’s overall portfolio risk management. It should form the foundation for credit risk measurement, monitoring, and reporting, and it should support management’s and the board’s decision making. • The board of directors should approve the credit risk rating system and assign clear responsibility and accountability for the risk rating process. The board should receive sufficient information to oversee management’s implementation of the process. • All credit exposures should be rated. (Where individual credit risk ratings are not assigned, e.g., small-denomination performing loans, banks should assign the portfolio of such exposures a composite credit risk rating that adequately defines its risk, i.e., repayment capacity and loss potential.) • The risk rating system should assign an adequate number of ratings. To ensure that risks among pass credits (i.e., those that are not adversely rated) are adequately differentiated, most rating systems require several pass grades. • Risk ratings must be accurate and timely. • The criteria for assigning each rating should be clear and precisely defined using objective (e.g., cash flow coverage, debt-to-worth, etc.) and subjective (e.g., the quality of management, willingness to repay, etc.) factors. • Ratings should reflect the risks posed by both the borrower’s expected performance and the transaction’s structure. Comptroller’s Handbook 3 Rating Credit Risk As of May 17, 2012, this guidance applies to federal savings associations in addition to national banks.* • The risk rating system should be dynamic — ratings should change when risk changes. • The risk rating process should be independently validated (in addition to regulatory examinations). • Banks should determine through back-testing whether the assumptions implicit in the rating definitions are valid that is, whether they accurately anticipate outcomes. If assumptions are not valid, rating definitions should be modified. • The rating assigned to a credit should be well supported and documented in the credit file. Developments in Bank Risk Rating Systems Many banks are developing more robust internal risk rating processes in order to increase the precision and effectiveness of credit risk measurement and management. This trend will continue as banks implement advanced portfolio risk management practices and improve their processes for measuring and allocating economic capital to credit risk. Further, expanded risk rating system

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