ABA Banking Journal
No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
SUBSCRIBE
ABA Banking Journal
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
No Result
View All Result
No Result
View All Result
Home ABA Banking Journal

Fed’s SCALE Method for CECL: Haze Lifted, Questions Remain

October 6, 2021
Reading Time: 2 mins read
Podcast: The Risks of Delaying CECL for Some Banks but Not Others

By Josh Stein

Responding to years of calls by ABA for simplification of processes for the current expected credit loss standards, the Federal Reserve introduced its Scalable CECL Allowance for Losses Estimator, or SCALE, method and tool during an “Ask the Fed” webinar this summer. The webinar discussed steps for assessing the appropriateness of using the tool and considerations when using it. Areas where management judgment is needed were emphasized, which should help frame conversations with examiners and auditors.

What is less obvious is whether SCALE is right for your individual institution or not. With that in mind, it appears that SCALE likely will help all 2023 adopters, as it sets a key boundary line on the playing field of CECL analysis.

As with any new accounting standard, expectations around CECL implementation initially are based on the practices of those larger institutions that adopted first in 2020. Because of their sophistication, however, such practice appears to be marking “the complex side of the playing field.” We all knew that there should be a noncomplex side of the field, but the inherent complexity of CECL covered it in a haze and many banks have been frustrated in exploring that direction. With the introduction and endorsement of SCALE, the boundaries for noncomplex banks are being refined, and this should make it easier for all 2023 adopters to find their individual section of the playing field.

Some clarifications ABA has learned since the webinar include:

  • SCALE tool vs. SCALE method: The SCALE method uses proxy expected lifetime loss rates in calculating CECL estimates. The SCALE tool is a spreadsheet based on using proxy expected lifetime loss rates from call report data reported by institutions between $1 billion to $10 billion in assets. The SCALE tool is, thus, restricted to institutions under $1 billion. However, the SCALE method of using proxy loss rates is not restricted.
  • Other regulators have publicly stated that SCALE is an acceptable CECL methodology. That being said, they emphasize that each eligible institution should make a determination as to whether the SCALE methodology is appropriate.
  • Credit risk monitoring activities are not affected (should not change) but rather can inform appropriate qualitative adjustments.
  • Qualitative factors and the related qualitative adjustments are not going away, with both CECL and the interagency guidance providing direction for qualitative factors.

As banks head toward the 2023 adoption of CECL, questions remain regarding how prevalent the use of SCALE will be. Discussions with certain auditors, for example, indicate a level of discomfort and a view that a lower threshold may be more appropriate to move past SCALE. There are also concerns about how granularity in segmentation may need to increase. Most banks, for example, have learned how some restaurants have thrived during COVID while others have struggled. All such restaurants, however, are reported as C&I loans in SCALE.

Similar segmentation issues exist for CRE loans, with hospitality loans having different risk factors from other commercial real estate. As a result expectations related to the QAs above will require significant discussions with examiners and auditors. Overall, however, the introduction of SCALE appears to be a positive development.

If you have any thoughts or question about SCALE, reach out to ABA’s Josh Stein.

Tags: AuditCECLFederal Reserve
ShareTweetPin

Author

Josh Stein

Josh Stein

Josh Stein is VP for accounting policy at ABA.

Related Posts

ABA DataBank: Why CMBS is a poor proxy for banks’ commercial real estate exposures

Private-market investing gains traction among wealthy households

Wealth Management
October 6, 2026

Nearly nine out of 10 investors say they would invest following a strong recommendation from their advisors, yet nearly half say such discussions have not taken place.

Fed, FDIC withdraw statements on managing risks for crypto

House committee removes proposed tax deferral for digital asset rewards

Newsbytes
September 16, 2026

House lawmakers removed a provision from a tax package that would have permitted entities involved in the staking and mining of digital assets to defer taxes on rewards for those assets.

Podcast: The Risks of Delaying CECL for Some Banks but Not Others

Thinking beyond CECL repeal

Community Banking
September 11, 2026

The current expected credit loss framework should be simplified. There are other ways to improve it, too.

ABA urges accounting standards body to appropriately scale objectives, inspections

ABA urges accounting standards body to appropriately scale objectives, inspections

Newsbytes
September 9, 2026

As the Public Company Accounting Oversight Board considers modernizing its standard-setting and enforcement operations, the board should ensure its objectives are proportionate to the risks they address and guarantee that bank audits are not selected for inspection more...

Hitting home

Hitting home

ABA Banking Journal
September 9, 2026

When people talk about financial services, they often talk about systems, markets, platforms and performance. But on Sept. 11, all of that fell away.

Old ways of life, new bank opportunities

Old ways of life, new bank opportunities

Community Banking
September 8, 2026

As the Amish and Plain population explodes across the country, their growth creates new opportunities for community banks with flexible policies.

NEWSBYTES

Robertson, Boyer receive Distinguished Service Awards for AML/CFT and fraud management

October 14, 2026

OCC releases report on alleged ‘debanking’ by large banks

October 14, 2026

Illinois to appeal interchange ruling

October 14, 2026

SPONSORED CONTENT

The Shift from Demographic Marketing

The Shift from Demographic Marketing

October 1, 2026
Meeting Ag Lending Goals Without Going It Alone

Meeting Ag Lending Goals Without Going It Alone

October 1, 2026
Beyond the Portfolio: The Wealth Manager’s New Role in a Multigenerational World

Beyond the Portfolio: The Wealth Manager’s New Role in a Multigenerational World

September 17, 2026
Banking Technology at a Strategic Crossroads

Banking Technology at a Strategic Crossroads

September 8, 2026

PODCASTS

Podcast: How community banks can keep farmers farming in turbulent times

October 14, 2026

Podcast: The birth of American money and how it triggered a revolution

October 8, 2026

Podcast: Creating seamless customer experiences

September 30, 2026

American Bankers Association
1333 New Hampshire Ave NW
Washington, DC 20036
1-800-BANKERS (800-226-5377)
www.aba.com
About ABA
Privacy Policy
Contact ABA

ABA Banking Journal
About ABA Banking Journal
Media Kit
Advertising
Subscribe

© 2026 American Bankers Association. All rights reserved.

No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive

© 2026 American Bankers Association. All rights reserved.