Forward-Looking Credit Loss Recognition and Banks’ Internal Risk Models

The global adoption of IFRS 9 requires banks to recognize loan loss provisions based on forward-looking credit loss estimates. While these rules enhance the timeliness of loss recognition, they also expand the scope for managerial discretion in loss estimation. Using supervisory data on German banks’ internal rating models, we examine how banks respond to these countervailing incentives. Relative to unaffected banks, IFRS 9 adopters update their internal credit risk estimates more frequently, consistent with a general improvement in the timeliness of loss recognition, yet assign systematically more favorable internal ratings to otherwise identical borrowers. A lower precision of these ratings accompanies this pattern, consistent with the strategic use of increased re-porting discretion outweighing the greater timeliness of the estimates. The implications for bank lending are twofold. First, to counter the increased cost of high-risk lending, banks curtail credit to borrowers most likely to experience internal rating downgrades that would trigger additional provisioning in future periods, with these lending changes extending broadly across the non-investment-grade segment and indicating a general portfolio shift toward lower credit risk. Second, lending changes cluster around seemingly arbitrary provisioning thresholds where expected credit losses are systematically underreported, suggesting that expanded reporting discretion distorts lending in a way that optimizes model input rather than portfolio risk.