Last September, in anticipation of a potential CRE meltdown in the face of sharply escalating interest rates, the Office of the Comptroller of the Currency; the Treasury; Federal Deposit Insurance Corporation; and National Credit Union Administration published a proposed change to a 2009 policy addressing commercial real estate loan accommodations and workouts.
The final version of the rule is now out. "The updated statement also addresses relevant accounting standard changes on estimating loan losses and provides updated examples of classifying and accounting for loans modified or affected by loan accommodations or loan workout activity," as it stated. Many may find themselves immediately drawn to the appendices.
Appendix 1 has the examples. The second appendix is "a summary of selected references to relevant supervisory guidance and accounting standards for real estate lending, appraisals, restructured loans, fair value measurement, and regulatory reporting matters." Appendix 3 keeps information from the original statement about "valuation concepts for income-producing real property." And the fourth "provides the agencies' long-standing special mention and classification definitions that are applied to the examples in Appendix 1."
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