LOANS
2A. Troubled Debt Restructurings
Bank Accounting Advisory Series
23
August 2018
•
Reduction (absolute or contingent) of accrued interest.
•
Payment deferral
Said another way, the modification is a TDR if the borrower cannot go to another lender and
qualify for and obtain a loan with similar modified terms.
Question 3
If the modification is a TDR, is the loan impaired?
Staff Response
Yes. TDR loans are impaired loans. A loan is impaired when, based on current information and
events, it is probable that an institution will be unable to collect all amounts due, according to the
original contractual terms of the loan agreement. Usually, a commercial loan that underwent a
TDR already would have been individually evaluated and identified as impaired, with
impairment measured under ASC 310-10-35.
Loans whose terms have been modified in TDR transactions should be measured for impairment
in accordance with ASC 310-10-35. This includes loans that were originally not subject to that
standard before the restructuring, such as individual loans that were included in a large group of
smaller-balance, homogeneous loans collectively evaluated for impairment (i.e., retail loans).
For a TDR loan, all amounts due according to the contractual terms means the contractual terms
specified by the original loan agreement, not the contractual terms in the restructuring
agreement. Therefore, if impairment is measured using an estimate of the expected future cash
flows, the interest rate used to calculate the present value of the cash flows is based on the
original effective interest rate on the loan, and not the rate specified in the restructuring
agreement. The original effective interest rate is the original contractual interest rate adjusted for
any net deferred loan fees or cost or any premium or discount existing at the origination or
acquisition of the loan.
Facts
Borrower A cannot service his $100,000 loan from the bank because of his financial
difficulties. On June 1, the loan is restructured, with interest of 5 percent payable annually for the
first two years and a final payment of $105,000 (principal plus interest at 5 percent) required at
the end of the third year. The 5 percent interest rate is below the current market rate of 12 percent
for new customers meeting the bank’s underwriting criteria. Borrower A is expected to make two
interest-only payments of $5,000 each and, due to continued poor performance, a final payment
of $95,000.
The present value of the expected payments under the restructured terms, discounted at
10 percent (the original effective interest rate), is approximately $80,000. The loan is not
collateral dependent, nor does it have an observable market price.
LOANS
2A. Troubled Debt Restructurings
Bank Accounting Advisory Series
24
August 2018
Question 4
How should a bank account for this restructuring?
Staff Response
This modification of terms should be accounted for as a TDR in accordance with ASC 310-40.
Given the facts and circumstances, impairment should be measured in accordance with
ASC 310-10-35 based on the present value of the expected future cash flows discounted at the
effective interest rate of the original loan. In this example, the measure of impairment is the
difference between the present value of the expected payments (approximately $80,000) of the
restructured loan, discounted at the loan’s original effective interest rate, and the recorded
investment ($100,000) in the loan, or approximately $20,000.
Facts
Consider the same facts as question 4, except that Borrower A transfers the collateral to a
new borrower (Borrower B) not related to Borrower A. The bank accepts Borrower B as the new
debtor. The loan with Borrower B provides for interest-only payments of 5 percent for two years
and a final payment of $105,000 (principal plus interest at 5 percent) at the end of the third year.
The fair value of the loan, discounted at a current market interest rate of 12 percent, is $83,200.
Question 5
How should a bank account for this restructuring?
Staff Response
ASC 310-40-40 requires that the receipt of a loan from a new borrower be accounted for as an
exchange of assets. Accordingly, the asset received (new loan) is recorded at its fair value
($83,200 in this example). In question 4, which involves a modification of terms, the impairment
is recorded through a valuation allowance, whereas here a loss of $16,800 (i.e., the $100,000
recorded investment in the old loan less the $83,200 fair value of the new loan), to the extent it is
not offset against valuation allowance, is recognized in earnings.
Facts
A bank makes a construction loan to a real estate developer. The loan is secured by a
project of new homes. The developer is experiencing financial difficulty and has defaulted on the
construction loan. To assist the developer in selling the homes, the bank agrees to give the home
buyers permanent financing at a rate that is below the market rate being charged to other new
home buyers.
Question 6
Must a loss be recorded on the permanent loan financings to the home buyers?
LOANS
2A. Troubled Debt Restructurings
Bank Accounting Advisory Series
25
August 2018
Staff Response
Yes. The bank is granting a concession it would not have otherwise considered because of the
developer’s financial condition. Therefore, this transaction is a TDR. Furthermore, it represents
an exchange of assets. The permanent loans provided to the home buyers must be recorded at
their fair value. The difference between fair value and recorded investment in the loan satisfied is
charged to the ALLL.
Facts
Assume that the real estate developer described in question 6 has not yet defaulted on the
construction loan. The developer is in technical compliance with the loan terms. Because of the
general problems within the local real estate market and specific ones affecting this developer,
however, the bank agrees to give the home buyers permanent financing at below-market rates.
Question 7
Must a loss be recorded on these permanent loan financings?
Staff Response
Yes. Even though the loan is not in default, the staff believes that the concession was granted
because of the developer’s financial difficulties. ASC 310-40-15-20 states that a creditor may
conclude that a debtor is experiencing financial difficulty even though the debtor is not currently
in payment default.
Therefore, this restructuring would be accounted for as an exchange of assets under the
provisions of ASC 310-40. Again, the permanent loans provided to the home buyers must be
recorded at their fair value.
Facts
A borrower owes the bank $100,000. The debt is restructured because of the borrower’s
precarious financial position and inability to service the debt. In partial satisfaction of the debt,
the bank accepts preferred stock of the borrower with a face value of $10,000 but with only an
estimated $1,000 fair value. The bank agrees to reduce the interest rate from 10 percent to
5 percent on the remaining $90,000 of debt. The present value of the modified combined
principal and interest payments due over the next five years, discounted at the effective interest
rate in the original loan agreement, is $79,000.
Question 8
How should the bank account for this transaction?
Staff Response
Securities (either equity or debt) received in exchange for cancellation or reduction of a troubled
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