Will Uncle Sam pay for JP Morgan’s Interest Income

We take a closer look at JP Morgan's 1Q20 financial statements in order to better understand loan accounting as well as the credit costs due to the #CCPVirus


An interesting part of a bank’s financial statements is what is called the Loan Accounting Framework or LAF. In normal times, this is glossed over but we live in strange times indeed.

Accountants get paid for recording the figures. Analysts get paid for reordering them. We are Analysts.

This section discloses several important accounting policies, namely which US GAAP policy applies to the loan (there are only 3: Held For Investment, Held For Sale, At Fair Value), how the loan is recognized on the balance sheet and how the bank recognizes interest income.

For example, JP Morgan has this disclosure when it comes to credit card loans, of which its outstanding loan amount was $154.0B as of Mar 31, 2020, which is accounted under the Held For Investment category. This was down from $168.9B in Dec 31, 2020, a reduction of $14.9B.  Of course, many observers will be surprised as to why this figure went down, considering that as the United States is facing the worst economic crisis since the Great Depression, there would be a tendency for stressed borrowers to draw down on their credit card lines.

In order to understand this, we have to first understand how credit card loans are accounted for as disclosed over here:

Loans held-for-investment
Originated or purchased loans held-for-investment are recorded at the principal amount outstanding, net of the following: charge-offs; interest applied to principal (for loans accounted for on the cost recovery method); unamortized discounts and premiums; and net deferred loan fees or costs. Credit card loans also include billed finance charges and fees.
Allowance for loan losses
The allowance for loan losses represents the estimated probable credit losses inherent in the held-for-investment loan portfolio at the balance sheet date and is recognized on the balance sheet as a contra asset, which brings the recorded investment to the net carrying value. Changes in the allowance for loan losses are recorded in the provision for credit losses on the Firm’s Consolidated statements of income. Refer to Note 13 for further information on the Firm’s accounting policies for the allowance for loan losses


Accrued interest receivables
As permitted by the guidance, the Firm elected to continue classifying accrued interest on loans, including accrued but unbilled interest on credit card loans, and investment securities in accrued interest and accounts receivables on the Consolidated balance sheets. For credit card loans, accrued interest is recognized in the loan balances as it is billed, with the related allowance recorded in the allowance for credit losses. Changes in the allowance for credit losses on accrued interest on credit card loans are recognized in the provision for credit losses and charge-offs are recognized by reversing interest income. For other loans and securities, the Firm generally does not recognize an allowance for credit losses on accrued interest receivables, consistent with its policy to write them off no later than 90 days past due by reversing interest income.


Credit card
Total credit card loans decreased from December 31, 2019 due to seasonality and a decline in sales volume in March as a result of the COVID-19 pandemic. The March 31, 2020 30+ and 90+ day delinquency rates of 1.96% and 1.02%, respectively, increased compared to the December 31, 2019 30+ and 90+ day delinquency rates of 1.87% and 0.95%, respectively due to the decline in credit card loans noted above. Net charge-offs increased for the three months ended March 31, 2020 when compared with the same period in the prior year due to loan growth, in line with prior expectations.
Consistent with the Firm’s policy, all credit card loans typically remain on accrual status until charged off. However, the Firm’s allowance for loan losses includes the estimated uncollectible portion of accrued and billed interest and fee income.


The key facts

  • JP Morgan’s allowance for loan losses increased $13.5B to $23.2B, mostly due to an increase in allowances for Credit Card
  • All cards remain on accrual status until charged off. This means the firm can continue to recognise income until they finally call the loan a bad loan. Then they have to reverse all the interest income they claimed but was not paid.
  • Accrued interest on receivables increased from $72.9B to $122.0B

Let’s unpack both these accounting policies.  As of 4Q19, JP Morgan’s Allowance for Loan Losses, or ALL for their credit card portfolio was $5.2B. As of 1Q20, the ALL for their credit card portfolio was $14.95B, an increase of approximately $10B. So the reduction of $10B of the reduction from 4Q19 to 1Q20 was not due to Customer’s repaying their loans but because JP Morgan took an allowance against the outstanding loan amount of about $10B, which reduced the carrying amount of this loan. (The customers are still on the hook for the same amount regardless of the allowance. So if you had $10,000 of Credit Card debt and JP Morgan took an allowance of $5,000, you still are on the hook for the $10,000 credit card debt. )

Of course, several questions are pertinent, namely was this allowance conservative enough, meaning will JP Morgan sustain a credit loss of greater than the $10B they provided for?

Historically, for the last 2 years, JP Morgan took an average charge-off of $4.5 – $4.8B, so the additional $10B for their credit card portfolio could be seen as taking an additional 2 years worth of credit losses. ($5B of this additional allowance was due to the introduction of the CECL accounting requirement in the US, also known as IFRS 9 to the rest of the world).

Furthermore, the 30+ delinquency rate, which measures the proportion of all credit card loans overdue by more than 30 days was at 1.96% or slightly higher than 1.85% in Dec 31, 2019. So definitely, based on the data that JP Morgan had at the end of 31 March 2020, the additional allowance for the Credit Card portfolio at $10B seemed reasonable.

There are several things working in favor of JP Morgan and not in favor of borrowers. Credit Card debt can be rolled over at the Minimum Payment per month so in effect, borrowers can still be considered to be current on their loan payments by just making the minimum payment sum, no matter how financially stressed they are. The revenue rate for Credit Card loans was about 10.68% These loans continue to accrue interest until they turn bad.

The most troubling of this entire disclosure – this entire increase of $50B recognized under Accrued Interest and Receivables.  Reading further it consists of several components

  • Unbilled interest on credit card loans
  • Margin loans to brokerage clients in CIB and AWM that are collateralized by assets maintained in the clients’ brokerage accounts (e.g., cash on deposit, liquid and readily marketable debt or equity securities

Summary and Conclusion

So over the last 50 days since JP Morgan reported their results, the US Unemployment rate climbed from 4.4% to 14.4%. Whilst JP Morgan took an additional $5B allowance for their Credit Card portfolio (of the $10B, $5B was due to CECL as of Jan 01,2020 without #CCPVirus),  only an additional $619M was taken against its other Residential and Auto portfolio and $1.7B for its wholesale portfolio (meaning the loans to large corporates like Boeing).  The outstanding amounts of these loan portfolios were $293.8B and $565.8B, for a total of $859.6B. It would not surprise me if the net charge off against those loans amounted to 2% over the next several months, for an incremental credit cost of $17B. Total credit losses for 2020 would probably be in the range of $20 – $25B, or about 4x its 2019 provision of $5.5B.

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