Review & Assessment Approach
Every institution operates within a unique credit culture and regulatory context. Tod’s process is structured, independent, and practical. With clear findings and practical recommendations designed to support board-level discussion, regulatory confidence, and sustainable risk management.
Leadership Alignment & Risk Context
Initial discussions to understand institutional priorities, portfolio characteristics, and regulatory environment.
Policy, Portfolio & Risk Rating Evaluation
Assessment of loan policies, risk rating practices, and execution consistency—identifying gaps between guidance and practice.
CECL & Credit Risk Framework Review
Evaluation of CECL integration with risk ratings, portfolio segmentation, and forward-looking assumptions.
Service Overview
PCI Performance Management provides independent loan review, loan policy, CECL, and credit risk assessments for community banks nationwide. Tod’s work focuses on evaluating how credit frameworks function in practice—not just how they are documented—by examining the alignment between: • Loan policy and credit decisioning • Risk ratings and portfolio performance • CECL methodologies and underlying risk assumptions The goal is to surface clear, defensible findings that support board oversight, management decision-making, and long-term balance sheet resilience.
Core Areas of Engagement
Loan Review & Portfolio Risk Assessment Independent evaluation of portfolio composition, underwriting practices, risk layering, and emerging credit trends. Loan Policy & Credit Governance Assessment of policy structure, clarity, and alignment with actual lending practices and risk appetite. Risk Rating Accuracy & Discipline Review of risk rating consistency, documentation quality, and adherence to policy and regulatory expectations. CECL Methodology & Risk Integration Evaluation of CECL models, assumptions, segmentation, and governance to ensure transparency, defensibility, and alignment with portfolio risk. Credit Risk Management & Oversight Independent perspective to support boards and executive teams in strengthening credit discipline and governance practices.
What Clients Can Expect
• Independent, objective perspective • Practical findings grounded in real-world lending oversight • Clear communication suitable for board and examiner review • Focus on long-term credit discipline—not short-term fixes
How to Use This Guide
This overview outlines Tod Ellis’s scope of services and review approach for community banks seeking independent insight into credit risk discipline, policy alignment, and regulatory readiness. This document is designed for: • Board members and executive teams • CEOs, CROs, and Credit Administration leaders • Institutions preparing for exams or validating existing frameworks
About Tod Ellis
With more than 40 years of banking experience, Tod Ellis brings deep practical insight across commercial, consumer, and mortgage lending environments. He is known for a disciplined, independent approach to loan review, credit risk evaluation, and CECL assessment—helping boards and management teams identify gaps between policy, execution, and outcomes. Tod’s work emphasizes clarity, challenge, and perspective, supporting confident decision-making and sustainable credit practices.
Download Overview & Scope of Services
Independent Credit Risk Review & Advisory Services
Loan Review · Loan Policy · CECL · Risk Ratings