SNC ReView™ was established with the goal of providing services to clients to help them achieve their SNC Program goals by helping them :
- Prepare for SNC Program examinations.
- Enhance collaboration between credit risk management ( the second line of defense ) and credit review / internal audit ( the third line of defense ) to improve SNC Program results.
- Develop risk-based, focused samples for SNC Program internal reviews prior to SNC Program examinations, or targeted portfolio regulatory examinations.
- Develop risk assessments of credit portfolios.
- Develop credit portfolio review schedules that are based on the portfolio risk assessments, portfolio trends, and regulatory considerations.
- Improve credit evaluations and reviews of SNC Program credits, particularly leveraged financing transactions and other high profile, complex, non-investment grade transactions.
- Develop an opinion on the risk of a post-origination Non-Pass rating determination prior to underwriting or committing to the credit.
- Enhance the monitoring and review of SNC portfolios or segments of SNC portfolios that are higher risk ( e.g., leverage finance, real estate, oil & gas, etc. ) or subject to regulatory scrutiny or concerns.
- Enhance the timeliness and quality of communications between Agents and Participants, particularly with regard to credit rating concerns. ( In some cases, SNC downgrade results for Participants are worse than for Agents and there may potentially be ways to address this operational risk disparity. )
- Implement accurate and timely risk grades.
- Resolve contentious risk grading disputes between the second and third lines of defense, including through the potential use of rating down-grade trigger criteria.
- Gain deeper insights into SNC exam individual credit disposition memos and leverage that knowledge of the key themes to more accurately rate credit risk.
- Conduct Non-Pass origination assessments, including six-month lookbacks.
- Avoid negative SNC examination results and surprises for senior management and the board.
- Avoid MRAs and other adverse regulatory findings that could involve business restrictions, fines, penalties and management actions.
- Respond to Supervisory Letters / MRAs with corrective action plans that are effective, sustainable, auditable and completed over a reasonable time frame.
- Complete special, urgent credit review related management projects.
- Enhance the reporting of SNC Program review and exam results to senior management and the board of directors.
- Improve the institution’s relationship and standing with Regulators.
- Maintain the safety and soundness of the institution.
- Drive best practices.
In addition to the services listed above, SNC ReView™ plans to become an ever-expanding hub of content on SNC Program best practices, examination trends, regulatory areas of focus, and risk rating guidance. It intends on being highly responsive to the needs of its clients and will evolve to maximize the benefit of its services. SNC ReView™ also plans to develop and offer to its clients, on a subscription basis, access to a special “concordance table” that will provide a unique level of insight on risk ratings for selected SNC credits, roundtable discussions on “public side” topics, AMA ( Ask Me Anything ) discussions, and E-Mail newsletters on important SNC Program developments.
SNC ReView™ services are designed to help its clients make the best decisions, providing them with a higher level of confidence in the actions they take and the decisions they make.