Inherently, a large MBL portfolio covering a wide geographic area presents a valuation risk and requires a robust methodology for calculating the ALLL. TCCU’s calculations included inappropriate assumptions about individually considered loans and relied upon historical trends, which did not reflect actual conditions, to anticipate losses in loan pools.
Regarding TCCU’s ALLL issues, we determined that examiners commented on the ALLL in every examination conducted, with the severity and frequency of their