ALLL is a big deal, to your bank, your regulator and possibly the IRS. You don't want to experiment with this. Do some searches and look for any guidance your regulator has published on ALLL and for any comments they have made in exit reviews or exam discussions.
Then call your regulator and talk about it. Do YOU feel it is adequate based on your portfolio? Ask them what methodologies seem to work best in your peer banks and see how that may apply to you.
While you are commended for getting out of the "this is the way we've always done it" mode, ALLL formulas are not a one size fits all proposition. You need to factor in your portfolio, management, collections, etc.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell