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ALLOWANCE FOR LOAN LOSSES
9 Months Ended
Jun. 30, 2018
Receivables [Abstract]  
ALLOWANCE FOR LOAN LOSSES
ALLOWANCE FOR LOAN LOSSES

At June 30, 2018, the Company’s allowance for loan losses increased to $22.0 million from $7.5 million at September 30, 2017. The increase in the allowance for loan losses from September 30, 2017 to June 30, 2018 was primarily due to the additional provision expense of $20.3 million related to tax services loans due to the Company retaining all tax services loans on its balance sheet, as compared to the previous year when a majority of these loans were sold. Also contributing to the increase was a $3.0 million provision on the Company's purchased student loan portfolios. During the nine months ended June 30, 2018, the Company recorded a provision for loan losses of $24.7 million compared to $10.7 million for the same period of the prior year. The Company had $10.3 million of net charge-offs for the nine months ended June 30, 2018, of which $8.6 million was related to a portion of the Company's taxpayer advances and $1.5 million was related to the charge offs of the Company's remaining ERO advance balances. This compared to $1.4 million of net charge-offs for the nine months ended June 30, 2017. See “Consumer Lending” under Note 2 to the Notes to Condensed Consolidated Financial Statements, which is incorporated herein by reference, for further details on the Company's purchased student loan portfolios.

The allowance for loan losses is established through the provision for loan losses based on management’s evaluation of the risk inherent in its loan portfolio and changes in the nature and volume of its loan activity, including those loans which are being specifically monitored by management.  Such evaluation, which includes a review of loans for which full collectability may not be reasonably assured, considers, among other matters, the estimated fair value of the underlying collateral, economic conditions, historical loan loss experience and other factors that warrant recognition in providing for an appropriate loan loss allowance.

Management closely monitors economic developments both regionally and nationwide and considers these factors when assessing the appropriateness of its allowance for loan losses. Management believes that, based on a detailed review of the loan portfolio, historic loan losses, current economic conditions, the size of the loan portfolio and other factors, the level of the allowance for loan losses at June 30, 2018, reflected an appropriate allowance against probable losses from the loan portfolio.  Although the Company maintains its allowance for loan losses at a level it considers to be appropriate, investors and others are cautioned that there can be no assurance that future losses will not exceed estimated amounts, or that additional provisions for loan losses will not be required in future periods.  In addition, the Company’s determination of the allowance for loan losses is subject to review by the OCC, which can require the establishment of additional general or specific allowances.

Real estate properties acquired through foreclosure are recorded at the lesser of fair value or the recorded investment.  If fair value at the date of foreclosure is lower than the balance of the related loan, the difference will be charged to the allowance for loan losses at the time of transfer.  Valuations are periodically updated by management and, if the value declines, a specific provision for losses on such property is established by a charge to operations.