More than one-fourth of financial institutions indicated recently they are in the final stages of implementing a new accounting standard that requires a more forward-looking approach to accounting for debt instruments, but nearly an equal number are still in the early stages.

That’s the result of a new poll by software firm SS&C Technologies Holdings on bank readiness to use a “current expected credit loss” approach to reflecting credit-related financial instruments in financial statements. Accounting Standards Codification Topic 326 requires companies to use a combination of their own historic data and market data to estimate where and in what amounts it will see trouble in its debt portfolio. Taking effect beginning in 2020 for publicly traded companies, the new accounting under ASC 326 compels companies to book projected losses even at the inception of new, fully performing arrangements.

The poll found 27 percent of organizations at a stage where they are actively implementing systems and controls to comply with the new accounting, while 16 percent are drafting their requirements for implementation. Another 14 percent said they were still assessing the quantitative impact the new standard will have on their organizations, and 20 percent said they were performing their gap analysis. Nearly one-fourth, or 23 percent, said they were still in the beginning stages, or gathering information and planning how they will proceed.

Data remains one of the biggest areas of concern for entities, with 34 percent ranking it above modeling, resources, knowledge and understanding, and system integration as key issues in implementation. When it comes to data, entities are most concerned about how to determine the reasonable and supportable forecast period that will form the basis for their estimated losses. Ranking behind that, companies are worried about insufficient historic data regarding portfolio segmentation, life of loan estimates, and historic losses. They’re also concerned about the identification of and use of external data.

In terms of internal controls, more than half of survey respondents are worried about controls over data. Only 15 percent are stuck on controls over the model or reporting and disclosure controls. Loan origination controls are a concern to only 9 percent, and credit risk controls worry only 6 percent.

In 2016, the first year SS&C conducted the poll, roughly 20 percent of participants described the transition to the CECL approach to reflecting loan losses as the biggest change to occur in bank accounting.

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