Validating CECL Model for a Fixed-Rate Mortgage Portfolio
Client: US Bank
Objective
To validate the Probability of Default (PD) and Loss Given Default (LGD) models for a fixed-rate mortgage portfolio for the client.
CRISIL's Solution
- Project Parameters
- Validation based on logistic regression for PD model and Zero-One Inflated Beta Regression for LGD model. This includes the following steps:
- Quantitative validation of the Logistic regression and Beta regression models
- Development of the challenger model using alternate approach/information
- Quantitative validation of the Logistic regression and Beta regression models
- The Logistic Regression and Beta Regression model to estimate the PD and LGD respectively for Mortgage portfolio are:
- logit(p) = β0+ β1 * fico + β2 * mi_pct + β3 * cltv + β4 *dti + β5* Unemployement Rate; PD =(1/(1+𝑒^(−𝑙𝑜𝑔𝑖𝑡(𝑝))))
- LGD = β0+ β1 * ltv + β2 * dti + β3 * House.Price.Index.Level
- logit(p) = β0+ β1 * fico + β2 * mi_pct + β3 * cltv + β4 *dti + β5* Unemployement Rate; PD =(1/(1+𝑒^(−𝑙𝑜𝑔𝑖𝑡(𝑝))))
- Validation based on logistic regression for PD model and Zero-One Inflated Beta Regression for LGD model. This includes the following steps:
- Data Quality & Audit
- Replicated development dataset from raw files available in the general ledgers
- Validation of data cleansing and preparation steps (e.g., validating imputation and transformation of data)
- Routine checks in verifying the inclusion of data corresponding to full economic cycle, data relevancy
- Validated the macroeconomic variables data from the internal repository which gets updated frequently
- Replicated development dataset from raw files available in the general ledgers
- Validation of Key Aspects
- Alternative approaches like contractual term, weighted average method using default/prepayment used to estimate the life of loan
- Current default definition tested against the regulatory definition, underlying assumptions and role of senior management
- Forecast horizon and macro-economic model forecast of reasonable and supportable forecast validated
- Alternative approaches like contractual term, weighted average method using default/prepayment used to estimate the life of loan
- Selection of Initial Pool of Variables
- Variable selection process used in model development document and multi-collinearity validated
- Assigned different significance levels for different variables and options to filter models with user-specified signs for different variables
- Variable selection process used in model development document and multi-collinearity validated
- Model Replication & Challenger Models
- Replicated the entire variable selection process using information provided in the model development document
- Verified the model coefficients along with the significance of the variables and verified the economic intuition of the sign of the variables chosen
- Developed the challenger model using alternative approach/different variable
- Replicated the entire variable selection process using information provided in the model development document
- Independent Testing
- Performed Model Fitting Tests, Coefficient Stability Analysis, Assumption Testing, Seasonality Check, Accuracy Tests of Model, Sensitivity and Scenario Analysis
- Performed back-testing analysis between actual and predicted PDs and LGDs
- Performed Model Fitting Tests, Coefficient Stability Analysis, Assumption Testing, Seasonality Check, Accuracy Tests of Model, Sensitivity and Scenario Analysis