Should all TDRs be classified as Non accrual? If so, where is this in the regulation? I am looking for information on how and when a loan modification should be treated as a TDR and why it should be considered on a cash basis instead of accrual basis?

I don't know a lot about TDR's, but know some. TDR's don't have to be on non-accrual. Our Loan Review Officer has a chart that shows (this may be Kentucky only - I don't know for sure) events that may create a TDR. One of those is the bank is 'giving up' something to the customer to assist them. We just lowered the rate on one loan to 1% (via modification) to help the customer - this loan is now classifed as a TDR.

I don't know if this helps but hopefully it does.

Thanks Skittles - do you think you could message me a copy of the chart?