Current Expected Credit Losses (CECL) Effective Date for Credit Unions (Revised)

This Accounting Alert supersedes the alert issued March 9, 2022.

After issuing the March 9, 2022 Accounting Alert, the NCUA determined that the term “fiscal year” - as used in the Current Expected Credit Losses (CECL) Transition Rule - should not be interpreted to mean “calendar year.” While the Federal Credit Union Act (12 U.S.C. § 1760) requires all federal credit unions to have a fiscal year ending on [the calendar year-end] December 31, the Financial Accounting Standards Board (FASB) enables an audit to be conducted on a different financial reporting year-end, such as September 30, 2023. This Accounting Alert provides notice that a federal credit union may implement CECL based on its audited financial reporting year if different than its fiscal year.

As a reminder, on February 2, 2022, FASB decided not to defer the implementation date for nonpublic entities of the Accounting Standards Update No. 2016-13, Financial Instruments—Credit Losses (Topic 326), commonly known as CECL. Federal credit unions and federally insured state-chartered credit unions are nonpublic entities; thus, CECL becomes effective for credit unions for fiscal years beginning after December 15, 2022.

In practice, a credit union with a financial statement reporting year ending on September 30, 2023, will implement CECL on October 1, 2023. Under the NCUA’s CECL Transition Rule, the phase-in of the day-one effects on a credit union’s net worth ratio would also start on October 1, 2023.

Federally insured state-chartered credit unions may contact their accountant or state regulator with questions on the implementation of CECL.

For additional information on CECL, please visit our CECL Resources Page.

Contact EIMail@ncua.gov with questions not answered in the CECL Resources.

Sent July 20, 2022, via GovDelivery