Inappropriate Use of Custom Tags for Provision (Benefit) for Credit Losses on the Income Statement

Staff in the Commission’s Division of Economic and Risk Analysis have completed an assessment of how filers are tagging provision (benefit) for credit losses on the income statement. The assessment was performed on Forms 10-K and 10-Q that included one or more custom tags for tagging the provision (benefit) for credit losses section of the income statement.

Staff has observed that certain filers are creating custom tags for the provision (benefit) of credit losses on unfunded commitments when this amount is presented separately on the income statement. Staff would like to remind filers the standard element us-gaap:OffBalanceSheetCreditLossLiabilityCreditLossExpenseReversal should be used to tag this amount. Staff also observed certain filers are creating custom tags for total provision for credit losses when they have both on-balance sheet (for example, loans held for investment) and off-balance sheet (for example, unfunded lending commitment) credit loss exposures. Filers should use the standard element us-gaap:ProvisionForLoanLeaseAndOtherLosses to tag total provision (benefit) for credit losses presented on the income statement. This element covers credit losses on all exposures, including but not limited to, loans, investment securities, leases, and off-balance exposures.

Tagging the provision (benefit) for credit losses using a custom tag when a standard tag is available reduces the comparability and usability of the information disclosed. The staff encourages filers to carefully review their current tagging for provision (benefit) for credit losses and make necessary changes.

For more data quality reminders, see Staff Observations and Guidance.