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Certain Recent Accounting Pronouncements (Notes)
9 Months Ended
Sep. 30, 2019
Certain Recent Accounting Pronouncements [Abstract]  
Certain Recent Accounting Pronouncements [Text Block] RECENT ACCOUNTING PRONOUNCEMENTS AND DEVELOPMENTS
Accounting Standard UpdatesDescriptionDate of adoptionEffect on the financial statements or other significant matters
Updates not yet adopted by the Bank
ASU 2016-13,
Credit Losses
(Topic 326):
Measurement of
Credit Losses on
Financial
Instruments and subsequent related ASUs

This ASU, and subsequent updates, significantly changes how entities will measure credit losses for virtually all financial assets and certain other instruments that are not measured at fair value through net income that have the contractual right to receive cash. The Update replaces today’s “incurred loss” approach with a current expected credit loss (“CECL”) model for instruments such as loans and held-to-maturity (“HTM”) securities that are measured at amortized cost. The ASU requires credit losses relating to available-for sale (“AFS”) debt securities to be recorded through an allowance for credit loss (“ACL”) rather than a reduction of the carrying amount and replaces the historically required other-than-temporary impairment (“OTTI”) analysis. It also changes the accounting for purchased credit-impaired debt securities and loans.

The ASU retains many of the current disclosure requirements in U.S. GAAP and expands other disclosure requirements. The new guidance is effective for calendar year-end public companies beginning January 1, 2020. Early adoption is permitted as of January 1, 2019.
January 1,
2020
During the first and second quarters of 2019, we ran limited parallel runs. During the third quarter, we ran a more complete parallel run including additional analytics, controls, and a parallel governance process. A set of controls, including management review controls, implementation controls, data, model, and forecasting controls has been established. Next steps include further testing of controls and developing disclosures. We will continue to evaluate and refine our loss estimates throughout 2019.

The impact of the ASU at adoption may have a material impact on the Bank's financial statements. The impact will be influenced by the portfolio composition and credit quality, macroeconomic conditions and forecasts at that time, as well as other management judgments. We expect more volatility in the credit loss estimate under CECL than under the current accounting requirements.

The Bank will adopt this guidance beginning January 1, 2020. Transition to the new ASU will be through a cumulative-effect adjustment to the opening balance of retained earnings as of the beginning of January 1, 2020.
ASU 2017-04,
Intangibles –
Goodwill and
Other (Topic 350):
Simplifying the
Test for Goodwill
Impairment

This ASU removes the requirements in step two of the current goodwill impairment model, eliminating the requirement to calculate and compare the implied fair value of the reporting entity with the carrying amount of that entity, including goodwill, to measure any impairment charge. Instead, entities will record an impairment charge based on the excess of a reporting unit’s carrying amount of goodwill over its implied fair value of goodwill (i.e., measure the charge based on step one of the current guidance).

The ASU also continues to allow entities to perform an optional qualitative goodwill impairment assessment before determining whether to proceed to the quantitative step one. The Update is effective for the Bank as of January 1, 2020. Early adoption is allowed for any goodwill impairment test performed after January 1, 2017.
January 1,
2020
We do not currently expect this guidance will have a material impact on the Bank’s financial statements since the fair values of our reporting units were not lower than their respective carrying amounts of goodwill at the time of our impairment analysis for 2018 and there were no significant decreases in the fair value identified for the relevant reporting units since the analysis was performed.

The Bank is not planning to early adopt this new guidance. The transition and adoption provisions are to be applied prospectively.
Accounting Standard UpdatesDescriptionDate of adoptionEffect on the financial statements or other significant matters
Updates adopted by the Bank during 2019
ASU 2016-02,
Leases (Topic 842)
and subsequent
related ASUs

Although lessor accounting was left materially unchanged by ASU 2016-02 (and all related ASUs which together have been codified in ASC 842), ASC 842 requires that all lessees recognize a right-of-use ("ROU") asset and an offsetting lease liability for all leases with a term greater than 12 months. As the lessee, we adopted an accounting policy election, by class of underlying asset, to not recognize lease assets or liabilities for leases with a term of 12 months or less.

The recognition, measurement, and presentation of expenses and cash flows arising from a lease will depend primarily on its classification as a finance or operating lease. ASC 842 requires additional disclosures to provide financial statement users a better understanding of the amount, timing, and uncertainty of cash flows arising from leases. These new quantitative and qualitative disclosure requirements are detailed further in Note 8.
January 1,
2019
The Bank adopted ASC 842 as of January 1, 2019 using the second of two permitted modified retrospective approaches for initial adoption. Under this method, the Bank recorded a right-of use asset of approximately $225 million and a lease liability of approximately $242 million. There was no impact to retained earnings upon adoption.

See Note 8 for additional details on the financial statement impact of completing the adoption of ASC 842.

ASU 2017-08,
Nonrefundable
Fees and Other
Costs (Subtopic
310-20). Premium
Amortization on
Purchased
Callable Debt
Securities
The amendments in this ASU shorten the amortization period for certain callable debt securities held at a premium. The ASU requires the premium of qualifying debt securities to be amortized to the earliest call date. The update does not change the accounting for callable debt securities held at a discount.

January 1,
2019
We adopted this ASU as of January 1, 2019 using a modified retrospective transition approach. As a result of adoption, we recorded a $3 million decrease to retained earnings on January 1, 2019, as a cumulative effect adjustment.
ASU 2018-13,
Fair Value
Measurement
(Topic 820):
Disclosure
Framework –
Changes to the
Disclosure
Requirements for
Fair Value
Measurement
The purpose of this ASU is to improve the effectiveness of disclosures in the notes to the financial statements. This Update removes, modifies, and makes certain additions to the disclosure requirements for fair value measurement.
The mandatory adoption date of the guidance in this ASU is for the first fiscal period beginning after December 15, 2019, with early adoption permitted.

January 1,
2019
We early adopted this ASU as of January 1, 2019. This Update
will be applied prospectively. The changes to the disclosure requirements for fair value
measurements are immaterial to the financial statements and can be found in Note 3.
ASU 2018-15,
Intangibles –
Goodwill and
Other-Internal-
Use Software
(Topic 350-40):
Customer’s
Accounting for
Implementation
Cost Incurred in a
Cloud Computing
Arrangement That
Is a Service
Contract

This ASU aligns the requirements for capitalizing implementation costs associated with Cloud Computing Arrangements that meet the definition of a service contract with requirements already provided for costs associated with internal-use software. Additionally, it clarifies that:
-The amortization period for capitalized amounts will be the noncancelable hosting contract term plus any expected renewal periods.
-Entities in a hosting arrangement that is a service contract must provide certain qualitative and quantitative disclosures.
-Transition for those not already following the provisions of this ASU can be applied either retrospectively or prospectively.
January 1,
2019
We early adopted this ASU as of January 1, 2019. The Bank has historically been applying the guidance as clarified in this ASU. Consequently, the adoption of the ASU did not have a material impact on the Bank’s financial statements.