Even as the new accounting standard for estimating the allowance was being announced in the summer of 2016, we knew the key issue – and the hardest part of transitioning to CECL – was going to be about data. We understood from the beginning that to comply with CECL we were going to need a lot of data, and that the data had to be of good, consistent quality. The concern remains paramount, in fact has grown. We see it everywhere: in webinars, white papers and conference presentations. The devil’s in the data.