LOANS
2A. Troubled Debt Restructurings
Bank Accounting Advisory Series
36
August 2018
Question 26
When determining an appropriate ALLL, how should a bank
measure impairment on TDR
loans?
Staff Response
ASC 310-40 requires a bank to measure impairment on all TDRs, including retail and
commercial TDRs, in accordance with ASC 310-10-35.
When measuring impairment on an individual basis under ASC 310-10-35, a bank must choose
one of the following methods:
•
The present value of expected future cash flows discounted at the loan’s effective interest
rate (i.e., the contractual interest rate adjusted for any net deferred loan fees or costs,
premium, or discount existing at the origination or acquisition of the loan).
•
The loan’s observable market price.
•
The
fair value of the collateral, if the loan is collateral dependent.
For call report purposes, a bank must use the fair value of collateral method if the loan is
collateral dependent. ASC 310-10-35 also requires the use of the fair value of collateral method
if foreclosure is probable.
Question 27
How is the effective interest rate determined when measuring impairment of a TDR loan?
Staff Response
The effective interest rate of a loan is the rate of return implicit in the original loan. That is, the
contractual interest rate adjusted for any net deferred loan fees or costs, premium, or discount
existing at the origination or acquisition of the loan. The effective
interest rate represents the
bank’s expected yield over the contractual life of the loan upon its origination or acquisition, and
is the discount rate used to measure impairment using the present value of expected
future cash
flows method. It is inappropriate to use the teaser or introductory rate as the effective interest
rate. The effective interest rate is not based on the interest rate charged under the modified terms
of the loan.
If a loan’s contractual interest rate varies based on subsequent changes in an independent factor,
such as an index or rate (for example, the
prime rate, the LIBOR, or the U.S. Treasury bill rate
weekly average), the loan’s effective interest rate may be calculated based on the factor as it
changes over the life of the loan or be fixed at the rate in effect at the date the loan meets the
impairment criteria. The method used shall be applied consistently for such loans. Further,
projections of future changes in the factor should not be considered when determining the
effective interest rate or estimate of expected future cash flows.
LOANS
2A. Troubled Debt Restructurings
Bank Accounting Advisory Series
37
August 2018
Question 28
How should expected future cash flows be estimated when the present value of expected future
cash flows method is appropriate to measure impairment of TDR loans?
Staff Response
The estimate of expected future cash flows (timing and amount) should be based on reasonable
and supportable assumptions and projections.
The key assumptions the bank should consider include, but are not limited to, prepayments,
defaults,
loss severity, and recoveries. If applicable, the bank should also consider the estimated
timing and amount of cash flows expected from collateral disposition net of estimated costs to
sell. The assumptions should be developed with greater weight placed on assumptions supported
by verifiable, objective evidence.
For practical reasons and as allowed in ASC 310-10-35, expected future cash flows for smaller-
balance homogeneous TDRs (generally retail loans) could be estimated
on a pooled basis for
impairment measurement if the loans within the pool share common risk characteristics. When
aggregating loans with common risk characteristics and using the present value of expected
future cash flows to measure impairment, the bank may use historical statistics, such as average
recovery period and average amount recovered, along with a composite effective interest rate.
Given the unique characteristics of TDR loans, some historical statistics, such as prepayment
rates for performing loans, may not be a reasonable basis for projecting expected future cash
flows on TDRs. Borrowers granted TDRs are likely to have reduced ability and financial
incentive to prepay because, by definition, they have experienced financial difficulty and were
provided a concession (implying more favorable loan terms than those available in the open
market).
When estimating expected future cash flows for TDR loans, the bank needs to consider all
available current information, including existing “environmental” factors (e.g.,
industry,
geographical, economic, and political factors) that are relevant and affect the loan collectibility.
Question 29
Can a TDR be collateral dependent immediately following the loan modification (on day 1)?
Staff Response
Yes. A TDR can be collateral dependent at the time of or immediately after the loan
modification. A loan is collateral dependent if repayment of the loan is expected to be provided
solely by the underlying collateral and there are no other available and reliable sources of
repayment. A modified loan requiring only a nominal monthly payment from the borrower with
no support that the borrower can repay the recorded loan balance may result in a loan that
ultimately is repaid only through the liquidation of the underlying collateral.
Management