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May loans receiving payment accommodations need to be reported as TDRs?

Yes, such loans may need to be reported as TDRs. A TDR is a loan restructuring in which an institution, for economic or legal reasons related to a borrower's financial difficulties, grants a concession to the borrower that it would not otherwise consider. However, a loan deferred, extended, or renewed at a stated interest rate equal to the current interest rate for new debt with similar risk is not reported as a TDR. Credit unions may refer to Accounting Standards Code (ASC) 310-40 (formerly Financial Accounting Standards Board (FASB) Statement No. 15) for additional guidance on determining whether a loan with renegotiated terms should be accounted for as a TDR. A SC 310-10-35 (formerly FASB Statement No. 114) also provides guidance on accounting for impairment losses on TDRs.

Consistent with present interagency and federal practices, short-term modifications made on a good faith basis in response to COVID-19 to borrowers who were current prior to any relief are not necessarily TDRs. This includes short-term (e.g. up to six months) modifications such as payment deferrals, fee waivers, extensions of repayment terms, or other delays in payment that are insignificant. Credit unions must make the individual TDR determinations and document such. TDRs must continue to be tracked for reporting purposes.