Oct 25 - The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the FDIC have jointly issued supervisory guidance on certain issues related to commercial and residential real estate loans that have undergone troubled debt restructurings. This guidance applies to all national banks, federal savings associations, and federal branches and agencies of foreign banks.
This guidance reiterates key aspects of previously issued regulatory guidance and discusses the definition of collateral-dependent loans and the circumstances under which a charge-off is required for TDRs. The guidance also elaborates on the concept of “operation of collateral” for repayment. The agencies continue to view prudent modifications as positive actions when they mitigate credit risk, and will not criticize banks for engaging in prudent workout arrangements, even if the modified loans result in TDRs.
Any questions regarding the 2013 guidance should be directed to Joy Palmer, senior accounting policy advisor, Office of the Chief Accountant, at 415-396-5892; or Lou Ann Francis, national bank examiner and technical expert, Credit Risk Policy Division, at 202-649-6406.
Click here for the guidance.