Big banks are making progress in preparing for the new accounting requirements around credit losses, but non-bank operating companies are likely to face a heavier lift as they approach the fourth quarter.

Bank of America has either validated its new models for recognizing credit losses under a “current expected credit losses” approach or is in the process of validating them, said Chris Lynch, senior vice president, at a recent American Institute of Certified Public Accountants banking conference. “We’re running our CECL process in real time to make sure it can do it at game speed,” he said. “It’s been a great experience.”