Focusing on the economy, credit risk, and allowances
Another rate-related issue that managers of credit portfolio risk management will face is economic uncertainty. Still-elevated interest rates are running into declining consumer purchasing power, which stands to add pressure to credit risk.
As a result, Abrigo advisors and customers say managing loan portfolio stress will be a top 2025 issue. Financial institutions with high concentrations in specific segments, such as consumer lending and especially commercial real estate (CRE), will need to proactively manage risks through stress testing, early intervention, and adjustments to loan loss provisioning. Some Abrigo customers named managing watch-list loans and complying with new stress test reporting as among their institutions’ top priorities heading into next year.
Expect continued examiner emphasis on concentrations and monitoring. Many examiners’ expectations include more sophisticated stress testing and more information on how lenders are complying with policy limits. Monitoring risk effectively and proactively remains an essential function in 2025.
“It is important that banks continue to use sound credit risk management practices such as stress testing at both the portfolio and facility levels, timely and accurate risk ratings, and effective concentration risk management,” the OCC said in its Semiannual Risk Perspective released Dec. 16. “The commercial real estate office sector remains stressed. Risks in multifamily CRE lending remain elevated, particularly in the luxury segment.”
Indeed, even with additional interest-rate cuts, challenges in CRE portfolios aren’t going away in the near term, based on customer and advisor comments. CRE loans originated five to seven years ago during the low-rate environment that reprice or mature in the coming year pose risks on two fronts.
First, pricing sensitivity among attractive borrowers and heightened loan-pricing competition will increase the risk of losing refinancing deals. Second, lenders have seen an increase in CRE delinquencies, but related charge offs haven’t yet followed in many cases. Some CRE loan renewals will force a reckoning of the impacts of higher rates and rising vacancies in hard-hit sectors and areas. Banks and credit unions, some of which are experiencing increased past-due loans, will be managing the troubled financial status of some customers, including, in some cases, foreclosures and higher credit losses. Others will reassess their strategies around CRE exposures.
Speaking of credit losses, expect increased scrutiny in the months ahead of allowances under CECL, particularly related to model validation and sensitivity to changes in economic forecasts (including prepayment and curtailment rates). Additionally, auditors are under more pressure from the Public Company Accounting Oversight Board (PCAOB) to audit qualitative factors, according to Abrigo’s experts. Financial institutions likely have only seen the beginning of this pain point in 2024 with many smaller banks having year-end audit work in early 2025.