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Financial Services Law Insights and Observations

Banking Agencies Clarify Guidance On Troubled Debt Restructurings

FDIC Federal Reserve OCC NCUA Agency Rule-Making & Guidance

Consumer Finance

Last week, the Federal Reserve Board, the FDIC, the NCUA, and the OCC released interagency guidance related to the accounting treatment and regulatory credit risk grade or classification of commercial and residential real estate loans that have undergone troubled debt restructurings (TDRs). The guidance clarifies the definition of collateral-dependent loans and states that impaired collateral-dependent loans should be measured for impairment based on the fair value of the collateral rather than the present value of expected future cash flows.