INVESTMENT SECURITIES
1B. Other-Than-Temporary Impairment
Bank Accounting Advisory Series
20
August 2018
Question 19
Should banks record OTTI on mortgage-backed securities with
subprime exposure or other
affected securities when there are adverse market conditions?
Staff Response
Measuring and recording OTTI is based on the specific facts and circumstances. Consistent with
OTTI guidance, the staff believes that banks should review their securities portfolios at each
reporting date and determine if write-downs are required in the current period. For example, if
the bank determines that the cause of the decline in a security’s value
is a result of a ratings
downgrade attributable to significant credit problems with the issuer, generally that decline
would be considered other than temporary, and that loss should be recorded in the current period.
Question 20
Some equity securities in the market, such as high-quality perpetual preferred stocks, are
similar
to debt instruments except that they have no maturity date. Are there any special OTTI
considerations for these equity securities?
Staff Response
One important consideration in an OTTI analysis is the existence of a maturity date. Because
these equity securities do not have a maturity date, bank management must determine the period
over which it expects the fair value to recover, and it must have the ability and intent to hold the
equity securities for a reasonable period of time to allow for the forecast recovery of fair value. A
reasonable recovery time frame for an equity security is typically of a
shorter duration than for a
debt security. The SEC staff stated that because of the challenges with assessing OTTI for
perpetual preferred stock, it would not object to “applying an impairment model (including an
anticipated recovery period) similar to a debt security.” This treatment may only be applied if
there has been no evidence of deterioration in credit of the issuer. Note that this does
not affect
the balance-sheet classification of the equity securities.
PBEs and non-PBEs
Under ASU 2016-01, equity securities must be measured at fair value, with changes in fair
value recognized through net income. Therefore, the evaluation of OTTI is not applicable.
If an equity security does not have a readily determinable fair value,
a bank may generally
elect to carry the equity security at cost minus impairment, if any, plus or minus observable
price changes in orderly transactions for the identical or similar investment of the same issuer.
LOANS
2A. Troubled Debt Restructurings
Bank Accounting Advisory Series
22
August 2018
Topic 2
Loans
2A.
Troubled Debt Restructurings
Question 1
What is a TDR?
Staff Response
Under GAAP, a modification of a loan’s terms constitutes a TDR if the creditor for economic or
legal reasons related to the debtor’s financial difficulties grants a concession to the debtor that it
would not otherwise consider. The concession could either stem from an agreement between the
creditor and the debtor or be imposed by law or a court. Accounting guidance for TDRs is
included in ASC 310-40.
Not all modifications of loan terms, however, automatically result in a TDR. For example, if the
modified terms are consistent with market conditions and representative of terms the borrower
could obtain from other sources, the restructured loan is not a TDR. If, however,
a concession
(e.g., below-market interest rate, forgiving principal, or forgiving previously accrued interest) is
granted based on the borrower’s financial difficulty, the TDR designation is appropriate.
If a modification meets the definition of a TDR in accordance with ASC 310-40, the TDR loan
must be measured for impairment under ASC 310-10-35. Banks should have policies and
procedures in place to identify and evaluate loan modifications for TDR designation.
With the exception of loans accounted for at fair value under the fair-value option
and loans
modified within a pool accounted for under ASC 310-30, TDR accounting rules apply to all
types of restructured loans HFI.
Question 2
What are some examples of modifications that may represent TDRs?
Staff Response
The following are some examples of modifications that may represent TDRs:
•
Reduction (absolute or contingent) of the stated interest rate for the remaining original life of
the debt.
•
Extension of the maturity date or dates at a stated interest rate lower than the current market
rate for new debt with similar risk.
•
Reduction (absolute or contingent) of the face amount or maturity amount of the debt as
stated in the instrument or other agreement.