COVID-19

Impact of Covid-19 Felt in the Shared National Credit Reviews Released by Bank Regulators

Business Accounting Concept, Business Man Using Calculator With Computer Laptop, Budget And Loan Paper In Office.

To misquote the great poet Alfred Lord Tennyson, “In the spring a young banker’s fancy lightly turns to thoughts of SNC Classifications.” SNC (pronounced like the candy bar but without the “ers”) stands for the Shared National Credit Program, which, since 1977, has assessed risk in the largest and most complex credits shared by multiple regulated financial institutions.

Governed by an interagency agreement among the Federal Reserve, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC), the program review credits with minimum aggregate loan commitments totaling $100 million or more that were shared by three or more regulated financial institutions. As a former bank examiner, standardized loan reviews keep consistent reviews and estimates of Default Risk and Loss Given Default across different examination teams, which helps both regulator and the regulated.

Loan reviews are completed in the first and third calendar quarters each year. Money center banks receive two reviews each year, while most other agent banks receive a single loan review each year. The results discussed in this document are based on loan reviews conducted in the first and third quarters of 2020 and primarily cover loan commitments originated on or before June 30, 2020. As shown in the table below, the reviewed 2020 SNC loans totaled $5.1 trillion in commitments, an increase of $242 billion, or 5 percent, from the third quarter of 2019 to the third quarter of 2020.

Super Charging the Data Governance Process in Financial Services with Data Lineage
Super Charging the Data Governance Process in Financial Services with Data Lineage

Download our guide to learn how data lineage can strengthen governance functions and get a 360-degree view of your data.

Get the Guide

2020 Snc Commitment Table

While the volume of loans reviewed increased by five percent, the increase in the volume of distressed loans was far sharper, as shown in the graph below:

Classified Loan Trends

Note how loans included for Special Mention and classified rose significantly from 6.9 percent in 2019 to 12.4 percent in 2020. The volume of negative reviews was concentrated in transactions that agent banks identified and reported as leveraged loans. The federal banking agencies noted that the increase in non-pass commitments was largely from borrowers in industries heavily affected by COVID-19, such as entertainment and recreation, oil and gas, real estate, retail, and transportation services. Note that while the absolute dollar volume of loans subject to classification and Special Mention neared the 2009 peak, as a result of the larger amount of loans reviewed, the percentage of loans (12.4 percent vs. 22.3 percent) subject to negative review was substantially lower.

While perhaps not as eloquent as Tennyson’s “In Memoriam,” the table below showing historical SNC classifications and criticisms is much more concise for today’s bankers to consume and refer to:

Committed and Outstanding Balances ($ Billions)
Year Special Mention (SM) Sub Standard
(SS)
Doubtful
(D)
Loss
(L)
Total Classified
(SS + D + L)
Total Criticized
(SM + SS + D + L)
Total Committed Total Outstanding
2000 36.0 47.9 10.7 4.7 63.3 99.3 1,951 705
2001 75.4 87.0 22.5 8.0 117.5 192.8 2,049 769
2002 79.0 112.0 26.1 19.1 157.1 236.1 1,871 692
2003 55.2 112.1 29.3 10.7 152.2 207.4 1,644 600
2004 32.8 55.1 12.5 6.4 74.0 106.8 1,545 500
2005 25.9 44.2 5.6 2.7 52.5 78.3 1,627 522
2006 33.4 58.1 2.5 1.2 61.8 95.2 1,874 626
2007 42.5 69.6 1.2 0.8 71.6 114.1 2,275 835
2008 210.4 154.9 5.5 2.6 163.1 373.4 2,789 1,208
2009 195.3 337.1 56.4 53.3 446.8 642.1 2,881 1,563
2010 142.7 256.4 32.6 15.4 304.5 447.2 2,519 1,210
2011 106.4 190.7 14.0 9.9 214.6 321.0 2,524 1,118
2012 99.3 161.7 29.5 4.6 195.8 295.1 2,792 1,243
2013 115.0 164.5 14.5 8.0 187.0 302.0 3,011 1,362
2014 149.2 171.0 11.8 7.8 191.3 340.6 3,389 1,568
2015 144.2 203.2 20.6 4.6 228.4 372.6 3,909 1,867
2016 136.4 250.7 25.7 8.6 285.1 421.4 4,102 1,986
2017 131.7 245.1 24.2 16.6 285.9 417.6 4,304 2,149
2018 112.4 173.9 5.1 3.4 182.5 294.9 4,435 2,106
2019 131.2 186.3 10.3 7.5 204.1 335.4 4,830 2,359
2020 263.9 314.8 30.4 20.6 365.9 629.8 5,072 2,620
About the Author

Carl is certified in the Scaled Agile Framework (SAFe), a Scrum Master, and a Six Sigma Green Belt project manager with more than 25 years of experience in financial services overseeing large-scale development global, multi-currency accounting, regulatory reporting, and financial reporting software platforms. He has hands-on experience completing, reviewing, and filing Federal Reserve, FFIEC, and IRS reports, including Call Reports, Y9C reports, 2900 reports, TIC reports, and arbitrage rebate reports.

More from this Author

Leave a Reply

This site uses Akismet to reduce spam. Learn how your comment data is processed.

Subscribe to the Weekly Blog Digest:

Sign Up