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prepaid or settled so that the investor does not recover substantially all of the recorded
investment?
Staff Response
No. Institutions with beneficial interests in securitized financial assets within the scope of
ASC 325-40 should apply the OTTI measurement framework prescribed in ASC 320-10-35-18.
Question 12
If OTTI measurements now follow the requirements of ASC 320-10-35, why is there still a need
for ASC 325-40?
Staff Response
ASC 325-40 is needed because guidance on interest income recognition remains applicable.
Question 13
Do market conditions affect the requirement to account for certain securities at fair value and
assess the presence of OTTI?
Staff Response
No. Bank management is required to account for certain securities at fair value and assess OTTI
on a quarterly basis for call report purposes. Bank management must
estimate fair value by using
observable market data to the extent available or otherwise make assumptions that a market
participant would use in assessing fair value as required by ASC 820-10. Fair value accounting is
discussed further in Topic 11D.
Question 14
How is OTTI on a debt security reflected in a bank’s financial statements and call reports?
Staff Response
In the income statement, banks must present the total amount of OTTI that has been recorded
during the period, the portion of the loss recognized in AOCI (non-credit component for debt
securities), and the portion of loss recognized in earnings. As an example, the following
presentation may be made:
INVESTMENT SECURITIES
1B. Other-Than-Temporary Impairment
Bank Accounting Advisory Series
18
August 2018
Total OTTI losses
$ XXX
Portion of loss recognized in AOCI
(XX)
Net impairment loss recognized
in earnings
$ XXX
Additionally, when reporting the total amount of AOCI, the bank must separately disclose the
amounts related to AFS securities and HTM debt securities.
Question 15
After an OTTI loss has been recorded for a debt security, the security has a new cost basis. How
is the debt security accounted for in subsequent periods?
Staff Response
The subsequent accounting for a debt security with OTTI depends on whether it is classified as
HTM or AFS.
For HTM debt securities, the amount of OTTI recorded in AOCI should be accreted from AOCI
to the amortized cost of the security. This transaction does not affect net income. Accretion of
amount in AOCI will continue until
the security is sold, matures, or suffers additional OTTI.
For AFS debt securities, subsequent increases or decreases in fair value will be reflected in
AOCI, as long as the decreases are not further OTTI losses. The difference between the new cost
basis of the AFS debt security and the cash flows expected to be collected will be accreted into
interest income as long as the security is not placed on nonaccrual. (See question 16.)
Question 16
When should a bank place a debt security on nonaccrual status and therefore not accrete or
amortize the discount or reduced premium created through the OTTI write-down?
Staff Response
GAAP does not address when a holder of a debt security would
place a debt security on
nonaccrual status or how to subsequently report income on a nonaccrual debt security. Banks
should apply its nonaccrual policies and regulatory guidance in determining when a debt security
should be placed on nonaccrual status.
Facts
A bank holds a debt security that has an amortized cost basis of $100 and is currently
trading in the active market at $70. The bank determined that the debt security is other-than-
temporarily impaired in accordance with GAAP, as of the reporting date. The fair value as of the
reporting date is the market quote of $70. The bank holds approximately 25 percent of the entire
debt security issuance. The sale of the bank’s holdings would affect the market pricing on the
INVESTMENT SECURITIES
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August 2018
debt securities, because of the market’s inability to readily absorb the
volume of securities being
traded.
Question 17
May the bank consider the volume of securities being held in the determination of fair value?
Staff Response
No. Consistent with ASC 820-10, the best evidence of fair value is quoted market prices of an
individual security in an active market. Although the sale of all the bank’s holdings could affect
the market pricing, an adjustment of fair value or a valuation adjustment due to the size of an
entity’s holdings (i.e., a “block discount”) is not permitted under GAAP.
Facts
Two severe hurricanes, Hurricane Katrina and Hurricane Rita (the hurricanes), caused
severe damage to certain Gulf Coast areas late in the third quarter of 2005.
Question 18
How should banks holding municipal bonds from issuers in the areas of a major hurricane on
which fair value is less than the amortized cost, assess these bonds for OTTI to
prepare their
quarterly call reports?
Staff Response
Under GAAP, when the fair value of a municipal bond has declined below its amortized cost, the
bank holding the bond must assess whether the decline represents an “other-than-temporary”
impairment. When making the OTTI assessment, banks should apply relevant OTTI guidance,
including ASC 320-10-35.
If a bank decided before the end of the quarter that it would sell a municipal bond after quarter-
end and management did not expect the fair value of the bond, which
is less than its amortized
cost, to recover before the expected time of sale, a write-down for OTTI should be recognized in
earnings in the bank’s quarterly financial statements. Otherwise, management should consider all
information available before filing this report when assessing hurricane-affected municipal bonds
for OTTI. If the bank determined the impairment on the bond
was other-than-temporary, but it
did not intend to sell the bond and it was not likely it would be required to sell the bond, the
portion of the decrease in value attributed to credit loss should be recognized in earnings, and the
change related to all other factors (i.e., the non-credit component) should be recognized in AOCI,
net of applicable taxes.
In each
subsequent reporting period, banks should continue to assess whether any declines in fair
value below amortized cost of these municipal bonds are other-than-temporary.