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“Commodity prices are among the most volatile of any market due to their sensitivity to country, economic, and operational risks such as strikes, unexpected harsh weather, terrorist attacks, and natural disasters,” Rodriguez Valladares says.

Analysts aren’t the only ones with CECL questions, said Mayra Rodriguez Valladares, a managing principal at New York consulting firm MRV Associates. “Bank examiners started having conversations with banks last year, so this puts pressure on banks to work on CECL implementation,” Rodriguez Valladares said.

“It’s great that the Financial Stability Board and the Basel Committee on Banking Supervision have focused so much on the banks, because they were at the epicenter of the crisis. But what about the regulation and the supervision of the nonbanks?” she [Rodriguez Valladares] said.

According to Mayra Rodriguez Valladares “Financial institutions, especially banks, have a lot of problems with legacy systems and data. There are still rules written by regulators that financial institutions, especially banks, will have to comply with. Fintech companies are much nimbler and can provide a lot of services to banks.”

“The banks have known for a while that this day was coming; they got so beat up during the [financial] crisis, and all these non-banks didn’t have the same regulations to comply with,” Rodriguez Valladares says, citing asset management giants like BlackRock and the Vanguard Group as examples. “From 2008 to now, there has been unbelievable, explosive growth by all these non-banks, and what that means is banks now have to be leaner and meaner.”

“Those [smaller] banks will undergo their next round of stress tests in 2020, and the staggered timeline should provide some cost savings to institutions, said consultant Mayra Rodríguez Valladares of MRV Associates, adding that she was concerned over several foreign-owned banks being part of that group.”