comments increasing as time went forward. As previously noted, many of the issues related to TCCU’s ALLL were due to failure in impairing individual loans and using an inappropriate basis for loss projections on loan pools. For instance, examiners noted in several examinations between December 2006 and 2009 that the Credit Union consistently used historical factors that were not a realistic reflection of prevailing economic conditions. TCCU was applying a zero percent historical loss rate over MBLs based on three-year historical data when current delinquency data internally and industry-wide predicted significantly higher loss rates.