7.1 Introduction
The CECL model does not apply to AFS debt securities. Instead, the FASB
decided to make targeted improvements to the OTTI model in ASC 320 for AFS debt
securities to eliminate the concept of “other than temporary” from that model. Although
the Board originally sought to develop an expected credit losses model that would apply
similarly to loans and debt securities, feedback received from stakeholders throughout
the model’s development indicated that an entity manages AFS debt securities differently
from how it manages other assets measured at amortized cost (e.g., loans and HTM debt
securities). Accordingly, in paragraph BC81 of ASU 2016-13, the Board indicates that “the
same credit loss model cannot apply because there are different measurement attributes.
The measurement attribute for available-for-sale debt securities necessitates a separate
credit loss model because an entity may realize the total value of the securities either
through collection of contractual cash flows or through sales of the securities.”
The targeted changes to the OTTI model can be summarized as follows (see
Section 7.2.3.1 for
more information):
- The entity must use an allowance approach (as opposed to permanently writing down the security’s cost basis).
- The entity must limit the allowance to the amount at which the security’s fair value is less than its amortized cost basis.
- The entity may not consider the length of time fair value has been less than amortized cost.
- The entity may not consider recoveries in fair value after the balance sheet date when assessing whether a credit loss exists.
These targeted changes do not apply to an AFS debt security if (1) the
entity intends to sell the security or (2) it is more likely than not that the entity
will be required to sell the security before the recovery of the security’s amortized
cost basis. In such cases, the entity would write down the debt security’s amortized
cost to its fair value. The decision tree below illustrates how an entity identifies and
assesses impairment on AFS debt securities.