LOANS
2B. Nonaccrual Loans
Bank Accounting Advisory Series
56
August 2018
Question 16
Is this an acceptable treatment?
Staff Response
No. Because doubt exists about the ultimate collectibility of the recorded loan balance, all
payments must be applied to reduce principal until such doubt is removed.
Facts
A loan is guaranteed by the U.S. government (or a government-sponsored enterprise).
The guarantee covers 90 percent of the principal and interest. The borrower experiences financial
difficulty and is past due more than 90 days on loan payments. Collection of the guaranteed
portion is expected; however, collection of the unguaranteed portion is uncertain.
The bank proposes to place 90 percent of the loan (the guaranteed portion) on accrual status and
classify the remaining 10 percent as nonaccrual. Interest income would also be recognized
accordingly.
Question 17
Is the proposed accounting treatment that would place the guaranteed portion of the loan on
accrual status and recognize interest income thereon acceptable?
Staff Response
No. The call report instructions require that accrual of interest income cease on a loan when it is
90 days or more past due, unless it is both well secured and in the process of collection. These
instructions apply to the remaining contractual obligation of the borrower. In this situation,
collection of the full contractual balance is not expected. Accordingly, the entire loan must be
placed on nonaccrual status.
Question 18
In determining when a loan is “in the process of collection,” a 30-day collection period has
generally been applied. Is this 30-day collection period intended as a benchmark or as an outer
limit?
Staff Response
The 30-day period is intended as a benchmark, not as an outer limit. Each loan must be evaluated
separately when determining whether it should be considered “in the process of collection.”
When the timing and amount of repayment is reasonably certain, a collection period of greater
LOANS
2B. Nonaccrual Loans
Bank Accounting Advisory Series
57
August 2018
than 30 days should not prevent a loan from being considered to be “in the process of
collection.”
Facts
A bank placed a loan on nonaccrual status, because the borrower’s financial condition
had deteriorated and the bank did not expect full repayment of contractual principal and interest.
Accrued interest was reversed and, as a result of the bank’s credit evaluation, a charge-off of
principal was recorded. One year later the borrower’s financial condition has improved greatly,
however, and the bank expects to recover all amounts contractually due.
Question 19
May the bank reverse the charge-off and rebook the principal and accrued interest?
Staff Response
No. The decision to place the loan on nonaccrual indicates that there was doubt about full
collection of principal and interest. The charge-off was based on management’s determination
that recovery of the principal was not expected. The reversal of the interest was based on the
determination that the accrued interest may not be collected. The determination of collectibility
is an accounting estimate as defined by ASC 250-10. That standard requires changes in
accounting estimates to be accounted for in the period of change and future periods when the
change affects both. Accordingly, payments would be accounted for in accordance with GAAP,
and recoveries recorded as received. This would apply to both principal and interest payments.
Facts
A bank pursues collection efforts on a past-due loan by a state-mandated mediation
process. The state requires mediation before banks may foreclose on real estate. Sufficient
collateral exists to support all contractual principal and interest. The call report instructions
indicate an asset is “in the process of collection” if collection of the asset is proceeding in due
course through legal action, including judgment enforcement procedures.
Question 20
May this loan remain on accruing status because it is “in process of collection”?
Staff Response
No. The meaning of “in process of collection” requires that the timing and amount of repayment
be reasonably certain. The definition entails more than initiating legal action or pursuing a well-
reasoned plan for collection. The following factors do not in and of themselves meet the “in
process of collection” definition:
•
Commencement of collection efforts
•
Plans to liquidate collateral
LOANS
2B. Nonaccrual Loans
Bank Accounting Advisory Series
58
August 2018
•
Ongoing workouts
•
Foreclosing on or repossessing collateral
•
Restructuring or settlement
There must be evidence that collection in full of amounts due and unpaid will occur shortly.
The same reasoning applies to a mandated mediation process, which may be part of a well-
documented plan of liquidation. In actuality, the mediation process will likely prolong the
collection process and infuse additional uncertainty into the timing and amount of repayment.
Facts
A bank has designated a loan of $200,000 in nonaccrual status, because payment in full
of principal and interest was not expected. The bank had previously accrued late fees of $500
before the loan’s designation in nonaccrual status.
Question 21
May the bank continue to accrue late fees on a loan that has been designated in nonaccrual
status?
Staff Response
No. Loan fees, including late fees, should not be accrued on a loan designated in nonaccrual
status. The loan was placed in nonaccrual, because the full payment of the principal and interest
is not expected. The staff believes the uncertainty in the collectibility of principal and interest
raises doubt as to the collectibility of all payments, including late fees. Therefore, the bank
should not continue to accrue the late fees while the loan is in nonaccrual status.
Question 22
How should the late fee receivable of $500 be accounted for because of this uncertainty?
Staff Response
As set forth in the call report instructions for previously accrued interest, one acceptable
accounting treatment includes a reversal of all previously accrued, but uncollected, amounts
applicable to assets placed in a nonaccrual status against appropriate income and balance sheet
accounts. Hence the late fees that are also accrued, but uncollected, should be reversed. This
would also apply to any other fees that may have been accrued on this loan.
Facts
A bank has a $150,000 loan secured by a single-family residence with an estimated fair
value of $200,000 based on a recent appraisal. The loan is 110 days past due. The mortgage loan
agreements allow the bank to pay delinquent real estate taxes and add the amount to the
contractual balance of the loan. Accordingly, the bank paid $4,000 in delinquent property taxes
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