Header Financial Lending
April 2011Issue No. 4
In This Issue
Troubled Debt Restructures
Repeal of Reg Q
New Appraisal Guidelines Adopted
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www.whitlockco.com
 

What Constitutes a TDR?

ASC 310-40 provides the following examples of loan modifications that may lead to a troubled debt restructure (TDR) designation:

  • Absolute or contingent reduction of the stated interest rate for the remaining original term of the debt.
  • Absolute or contingent reduction of the face amount or maturity amount of the debt as stated in the instrument or other agreement.
  • Absolute or contingent reduction of accrued interest.
  • Extension of the maturity date (or dates) at a stated interest rate that's lower than the current market rate for new debt with similar risk.
  • Conversion of a loan from one that amortizes principal and interest payments to an interest-only loan, even at a market rate.

In short: A loan modification is a TDR if the borrower could not qualify for a loan with similar modified terms from another lender.

 

Concerned About Regulatory Demands Cutting into your Profitability?

We offer services to keep your bank efficient and compliant at a great value:

  • Internal Audit
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  • IT Exams
  • Loan Review
 

To our valued clients and friends,

 
In the current post-financial crisis lending environment, most banks are working with at least some borrowers to rehabilitate troubled loans by modifying loan terms. Loan modifications may result in the creation of what's known as a troubled debt restructure, or TDR. This distinction is important, because TDRs are subject to additional regulatory reporting, tracking and accounting requirements. See our lead article below. 

 

Thanks to the Dodd-Frank financial reform bill, Reg Q will finally be repealed this summer. The big question now is what will be the impact of this repeal on community banks? 

 

In December, federal financial regulators adopted the appraisal and evaluation guidelines that were originally issued for public comment in 2008. And we describe some important changes that recently went into effect impacting how bank mortgage loan originators and mortgage brokers can be compensated.

 

We hope that you find this issue of Financial Lending Notes to be helpful and beneficial to your company. If you would like more information on any of the topics mentioned here, we would be glad to discuss them with you in more detail.  

 

Sincerely,

Tom Beisner, CPA, Partner

Troubled Debt Restructures - What You Should Know about TDRs 

In the current post-financial crisis lending environment, financial regulators are taking an especially close look at restructured small business loans. Most banks are working with at least some of their small business and commercial real estate borrowers to rehabilitate troubled loans by modifying loan terms and granting certain concessions. Read more...

Repeal of Reg Q - Competitive Strategy in a Post-Reg Q World

On July 21, a banking regulation on the books for nearly a century and considered by many to be one of the most antiquated laws will finally be repealed. That's the date when Reg Q, which has prohibited banks from paying interest on commercial demand deposit accounts since the Great Depression, will officially become part of the history books. Read more...

New Appraisal Guidelines Adopted for Appraisals and Evaluations

In December, federal financial regulators adopted the appraisal and evaluation guidelines that were originally issued for public comment in 2008. These new guidelines were issued in response to heightened concerns that arose regarding collateral appraisals and credit quality in the aftermath of the financial crisis. Read more...

About Us

The Whitlock Company is a full-service accounting firm offering a range of audit, tax, technology, risk management and consulting services to the community banking industry.


The experiences our professionals have gained from these relationships allow us to offer you best practice ideas on business issues specific to community banks.

 

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www.whitlockco.com / 417.881.0145