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#1657185 - 01/27/12 05:01 PM TDR triggers for loan
Allie Offline
New Poster
Joined: May 2011
Posts: 17
Hoping I am in the proper forum for this question!!!
We (the Bank)have a customer relationship with several loans, all of which have matured.
The Loan Officer wrote up the credit extension for 90 days in order to allow collection of financials from customer and would then restructure with amortization, etc.; however, the approving Committee has instructed the LO to identify the ONE of the loans as a TDR???
We have made NO concession to the borrower (i.e.; rate reduction, principal forgiveness or payment reduction) through any modification or otherwise.
I am really apprehensive about reporting this loan, since, in my opinion, it is not validated by the "triggers" I would associate with reporting a loan as a TDR.
Anyone out there agree with my gut instinct?? Thanks for any reply!!

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Lending Compliance
#1657218 - 01/27/12 05:58 PM Re: TDR triggers for loan Allie
HRH Okie Banker Offline
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Joined: Jan 2003
Posts: 3,070
Oklahoma
From what you've wrote I tend to agree. A 90 day extension to allow the lender to gather further financial information doesn't seem like the basis of TDR.

Perhaps the loan approval will include additional information that supports this decision?

You could consider creating a "Troubled Debt Restructuring Form" to document and justify how the TDR designation was arrived upon?

Our loan approval starts the process with:
Is the borrower experiencing financial difficulty?
Has concession been granted?
If yes to both questions please complete and attach "Troubled Debt Restructuring and Impairment Analysis" Form.
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Just working here until I get my letter from Hogwarts.

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#1657240 - 01/27/12 06:15 PM Re: TDR triggers for loan HRH Okie Banker
Allie Offline
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Joined: May 2011
Posts: 17
Originally Posted By: Okie Banker
From what you've wrote I tend to agree. A 90 day extension to allow the lender to gather further financial information doesn't seem like the basis of TDR.


The LO even sites in the write-up that the borrower is current on the debt and believes they will remain able to service the debt.

Thanks for the reply, and that is a good idea about the identification form. I'm in Loan Admin, so I'm sure I'll get some flack for putting yet another dasterdly form in the folder for them to complete wink

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#1657260 - 01/27/12 06:38 PM Re: TDR triggers for loan Allie
osucpa Offline
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Joined: May 2011
Posts: 1,406
The bank granting a concession is the major issue when identifying a TDR.

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#1657262 - 01/27/12 06:42 PM Re: TDR triggers for loan Allie
renniks Offline
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renniks
Joined: Sep 2003
Posts: 2,162
New England
Also, remind your Committee that "once a TDR, always a TDR" until the relationship ends or the loan is paid-off (not refinanced with you).

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#1657268 - 01/27/12 06:47 PM Re: TDR triggers for loan Allie
osucpa Offline
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Joined: May 2011
Posts: 1,406

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#1657390 - 01/27/12 08:51 PM Re: TDR triggers for loan Allie
HRH Okie Banker Offline
Power Poster
Joined: Jan 2003
Posts: 3,070
Oklahoma
Originally Posted By: Allie
Originally Posted By: Okie Banker
From what you've wrote I tend to agree. A 90 day extension to allow the lender to gather further financial information doesn't seem like the basis of TDR.


The LO even sites in the write-up that the borrower is current on the debt and believes they will remain able to service the debt.

Thanks for the reply, and that is a good idea about the identification form. I'm in Loan Admin, so I'm sure I'll get some flack for putting yet another dasterdly form in the folder for them to complete wink


I you'd like to PM me your email I would be glad to share our form. It will at least give you a place to start without reinventing whole wheel.
_________________________
Just working here until I get my letter from Hogwarts.

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