What's the Dilly-o with ALM & CECL: a buyer's guide for credit unions

On September 29, 2026, NCUA released an update to its Simplified CECL Tool for the period ending September 30, 2026.¹ The update added the 2023 to 2025 average net charge-off rates for each of the 13 Call Report loan categories.² Separately, NCUA reported credit union delinquency at 96 basis points in the second quarter of 2026, up 6 from a year earlier.³ We'd use this moment to check how your software handles both your reserve and your rate risk.

The Dilly-o

Every system in this category must handle two jobs: balance-sheet risk and credit loss reserving.^C NCUA says it developed its Simplified CECL Tool for credit unions with less than $100 million in assets.⁴ Choose the one whose assumptions you can explain to your board in plain terms, because that is where examiners will press.

How we'd size up a vendor

Validation support - will the vendor help you arrange an independent outside review of its model, and share what that reviewer needs?
One balance sheet - do the rate risk, liquidity and reserve numbers come from the same data load from your core?

What changed this year

FASB's change for current receivables and contract assets took effect for fiscal years beginning after December 15, 2025.⁵ ASU 2025-08 extends the CECL gross-up approach to purchased seasoned loans, starting with fiscal years beginning after December 15, 2026, and applying going forward.⁶⁷ It also gives institutions that do not use a discounted cash flow method an optional way to measure losses on purchased seasoned loans.⁸ Each change lands in your model, so ask your vendor how and when it will ship.

Will it work with your systems?

We haven't yet reviewed how either one connects to specific cores.^C Ask your provider which cores it pulls loan and share data from today, how often, and who fixes a broken feed.

What other credit unions did

A new credit union service organization (CUSO) built around the Delfi ALM system was announced on February 3, 2026.⁹ A $1.8 billion credit union with 90,000 members joined it as an early investor and adopter.¹⁰

What your examiner will ask

NCUA's 2026 priorities say examiners may review your allowance for credit losses reserves and methodologies.¹¹ They may also look at how rate and liquidity risks feed into governance, contingency funding plans and strategic decisions.¹² A Brown Edwards summary of a talk by an NCUA principal examiner says non-maturity share assumptions in ALM models are under increased scrutiny.¹³ For third-party CECL software, the model validation must be external.¹⁴ Have ready your assumption log, your latest outside validation, your vendor due diligence file and board minutes that show the board discussed the results.

What it costs

Ask each vendor for a written quote that covers setup, annual fees and model updates. NCUA says contracts should cover service levels, penalties for poor performance, ownership of records, audit rights and termination clauses.¹⁵¹⁶¹⁷ NCUA notes that some credit unions signed agreements with large termination penalties, believing them non-negotiable.¹⁸ It adds that early termination, escape and default terms are often negotiable.¹⁸

Food for thought

In a recent speech, Fed Vice Chair Bowman said supervisors were slow to make Silicon Valley Bank reduce its interest rate risk.¹⁹²⁰ Bowman cited a culture of risk aversion.¹⁹²⁰ We think examiners will push harder on rate risk next, so pick software that lets you show your board a bad-rate scenario before anyone asks.

Dilly Labs research, written from our catalog and cited sources · updated Nov 10, 2026. Credit unions pay nothing. Vendors pay a referral fee only when a contract is signed through us. It never changes rankings or this guide. How we work

Sources

NCUA updates Simplified CECL Toolwww.americascreditunions.org
# NCUA updates Simplified CECL Tool September 29, 2026 NCUA has updated its Simplified CECL (Current Expected Credit Loss) Tool for September 2026.
NCUA updates Simplified CECL Toolwww.americascreditunions.org
The update provides the latest life-of-loan—or Weighted Average Remaining Maturity—factors, and the 2023 to 2025 average net charge-off rates for each...
NCUA Releases Second Quarter 2026 Credit Union System Performance Datancua.gov
- The delinquency rate at federally insured credit unions was 96 basis points in the second quarter of 2026, up 6 basis points from one year earlier. ...
Current Expected Credit Loss (CECL): The Simplified CECL Toolncua.gov
The Simplified CECL Tool was developed to support credit unions with less than $100 million in assets.
What's New in CECL: Key Updates to Financial Instrumentscentriconsulting.com
The ASU is effective for fiscal years beginning after December 15, 2025, and interim reporting periods within those fiscal years.
Current Expected Credit Loss (CECL) Implementation Insightswww.deloitte.com
- *ASU 2025-08* — This ASU expands the CECL “gross up approach” beyond purchased credit-deteriorated (PCD) assets to include purchased seasoned loans ...
At Long Last: FASB Issues ASU 2025-08, Eliminating Day-1 Credit Loss Expense for Most Purchased Loanswww.bonadio.com
### Effective Date & Adoption The new rules take effect for fiscal years beginning after December 15, 2026, and apply prospectively.
At Long Last: FASB Issues ASU 2025-08, Eliminating Day-1 Credit Loss Expense for Most Purchased Loanswww.bonadio.com
CECL models will require modifications to incorporate the expanded gross-up approach and, if applicable, the new measurement option.
New CUSO Aims to Help with Asset Liability Managementwww.finopotamus.com
Those discussions led to the formation of the CUSO, announced officially on Feb. 3, 2026.
New CUSO Aims to Help with Asset Liability Managementwww.finopotamus.com
The $1.8 billion Salem, Ore.-based Maps Credit Union (90,000 members) is joining as an early investor and adopter.
NCUA’s 2026 Supervisory Prioritiesncua.gov
Specific review areas will focus on institution-specific risks and may include the sufficiency of credit administration, including loan underwriting, ...
NCUA’s 2026 Supervisory Prioritiesncua.gov
Reviews will focus on how credit unions incorporate these risks into governance frameworks, contingency funding plans, and strategic decision-making, ...
NCUA Insights: Emerging Trends and Risk Management in Credit Unionsblog.becpas.com
Non-Maturity Shares: There's increased scrutiny on the assumptions used for non-maturity shares in ALM models.
NCUA’s recent addendum related to CECL model validationswww.bakertilly.com
software), credit unions must obtain an **external** **validation** of the third-party model.
Evaluating Third Party Relationshipsncua.gov
- Typically, at a minimum, third party contracts should address the following: - Scope of arrangement, services offered, and activities authorized; - ...
Evaluating Third Party Relationshipsncua.gov
- Typically, at a minimum, third party contracts should address the following: - Scope of arrangement, services offered, and activities authorized; - ...
Evaluating Third Party Relationshipsncua.gov
- Typically, at a minimum, third party contracts should address the following: - Scope of arrangement, services offered, and activities authorized; - ...
Evaluating Third Party Relationshipsncua.gov
For example, some credit unions have entered into third party agreements with significant buyout or termination penalties, believing the penalties or ...
Speech by Vice Chair for Supervision Bowman on initial findings from independent review of Silicon Valley Bank - Federal Reserve Boardwww.federalreserve.gov
Third, despite what it knew or should have known, supervisory staff did not take prompt and decisive action to encourage or require SVB to reduce its ...
Speech by Vice Chair for Supervision Bowman on initial findings from independent review of Silicon Valley Bank - Federal Reserve Boardwww.federalreserve.gov
Fifth, one significant factor contributing to supervisory inaction was a long-standing culture of risk aversion.

See the 2 ALM & CECL vendorsSorted by fit with your core, with the evidence behind each.