abrigo.com CHALLENGES Citizens First Bank was using internal spreadsheets and separate impairment analysis worksheets for each loan in its ALLL. Upon completion of the institution’s most recent exam, Jason McCray, Vice President and Commercial Lending Manager, noted a higher level of examiner scrutiny than usual. McCray states, “We consistently had 6-7 examiners looking at our loan portfolio. It’s our standard exam, but this year there was such a strong focus on ALLL that I was really surprised.” As part of the focus on the allowance, examiners began asking for significantly more granular documentation. “We would have to do 70-80 individual impairment analyses, as the examiners were focusing not just on total ALLL, but specifically on each loan,” he mentions. McCray

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