CREDIT LOSSES
12B. Troubled Debt Restructurings
Bank Accounting Advisory Series
260
August 2018
Early adopters only
For repayment expected
through sale of collateral, costs to sell should be deducted from the
fair value of the collateral. The bank should not adjust the value of the collateral for expected
future changes in the collateral’s fair value; rather, changes in the fair value of the collateral
should be recognized in the period in which the change occurs.
For all other TDRs, if a TDR shares similar risk characteristics with other loans in the
portfolio, the expected credit losses should be measured on a collective (pool) basis. If a bank
determines that the TDR does not share risk characteristics with other loans in the portfolio,
the bank should measure expected credit losses on an individual basis.
Whether calculated on
an individual or collective basis, the ACL for non-collateral dependent TDRs can be
determined using various methods. For example, a bank may use a DCF method, loss rate
method, roll-rate method, probability-of-default method, or other appropriate method. There
may be
circumstances, however, that require the DCF method to be used. Refer to question 3
below.
Question 3
Although the ACL on TDRs can be determined using various methods, are there
circumstances that would require a bank to use the DCF method, even if the bank does not
apply the DCF method to measure expected credit losses on other loans in the portfolio?
Staff Response
Yes. The DCF method (or a method that reconciles to a DCF method) must be used
to measure
the value of a concession given to a borrower in a TDR if the value of that concession cannot
be measured by any other method. While the accounting guidance provides flexibility
regarding different measurement methods, the requirement in paragraph ASC 310-40-35-10
that concessions be reflected in the ACL cannot be ignored. Examples of concessions that can
only be measured using a DCF method include interest rate concessions or term extension
concessions. Further, when an individual loan is specifically identified as a reasonably
expected TDR, an entity must use a DCF method (or reconcilable method) if the TDR involves
a concession that can be captured only by using a DCF method (or reconcilable method).
Question 4
When a bank uses the DCF method to determine the ACL for TDRs, how should expected
future cash flows be estimated?
N
EW
CREDIT LOSSES
12B. Troubled Debt Restructurings
Bank Accounting Advisory Series
261
August 2018
Early adopters only
Staff Response
The estimate of expected future cash flows (timing and amount) should
be based on reasonable
and supportable assumptions and projections. The bank should consider all available, relevant
information, including current “environmental” factors (e.g., industry, geographical,
economic, and political factors) that affect the loans’ collectibility, as well as reasonable and
supportable forecasts about future conditions.
The key assumptions the bank should consider include prepayments, defaults,
loss severity,
and recoveries. If applicable, the bank should also consider the estimated timing and amount
of cash flows expected from the borrower’s collateral disposition, net of estimated costs to
sell. The assumptions should be developed with greater weight placed on assumptions
supported by verifiable, objective evidence.
As required by ASC 326-20, the ACL, even for TDRs, should be determined
on a collective
basis, unless the TDRs do not share similar risk characteristics with other TDRs or other loans
in the portfolio. When aggregating loans with similar risk characteristics and using the DCF
method to determine the ACL, the bank may use historical
statistics, such as average
repayment period and average amount collected, 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).
Facts
Borrower A cannot service its $100,000 loan from the bank
because it is experiencing
financial difficulties. The loan does not share similar risk characteristics with other loans. On
June 1, the loan is restructured to reduce the interest rate from 10 percent payable annually to
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 for loans in this risk category. 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, which represents a shortfall of $10,000 of the contractual amount due.
The present value of the expected payments under the restructured terms, discounted at
10 percent (the original effective interest rate), is approximately $80,000.
Question 5
How should a bank account for this restructuring?
N
EW