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#1999358 - 03/03/15 02:19 PM FASB 91
FNB Offline
Junior Member
Joined: Feb 2014
Posts: 36
What is your stance on FASB fees on loan renewals?

Example: 5 year Term loan is maturing & being renewed for another 5 years. We are charging a Processing Fee with the renewal.

Would you put this in as a deffered FASB fee?

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Lending Compliance
#2000132 - 03/06/15 12:03 AM Re: FASB 91 FNB
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
There is a large "GAAP" between compliance and accounting. smile

You might try asking your external financial auditors. FASB 91 is no longer a close friend of mine, so I have to take a pass on the question. Their opinion is the one that will count anyway.
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#2000278 - 03/06/15 05:04 PM Re: FASB 91 rlcarey
fmissle Offline
Diamond Poster
Joined: Jul 2007
Posts: 1,016
Pac NW
Ha... nice rlcarey

I'm not an accountant or expert either, but I would refer to the actual "as issued" Statement. My personal interpretation would be to defer the processing fee over the life of the new loan and offset against your standard cost for that type of loan, if you have a standard.

http://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1218220128141&acceptedDisclaimer=true

Quote:
Fees and Costs in Refinancings or Restructurings
12. If the terms of the new loan resulting from a loan refinancing or restructuring other than a
troubled debt restructuring are at least as favorable to the lender as the terms for comparable
loans to other customers with similar collection risks who are not refinancing or restructuring a
loan with the lender, the refinanced loan shall be accounted for as a new loan. This condition
would be met if the new loan's effective yield is at least equal to the effective yield for such
loans.4 Any unamortized net fees or costs and any prepayment penalties from the original loan
shall be recognized in interest income when the new loan is granted.

13. If the refinancing or restructuring does not meet the condition set forth in paragraph 12 or
if only minor modifications are made to the original loan contract, the unamortized net fees or
costs from the original loan and any prepayment penalties shall be carried forward as a part of
the net investment in the new loan. In this case, the investment in the new loan shall consist of
the remaining net investment in the original loan,5 any additional amounts loaned, any fees
received, and direct loan origination costs set forth in paragraph 6 associated with the
refinancing or restructuring.

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#2000308 - 03/06/15 06:30 PM Re: FASB 91 FNB
osucpa Offline
Diamond Poster
Joined: May 2011
Posts: 1,406
There is a difference between a processing fee and an orgination fee. Any loan origination fee less than $1,000, we take straight to income. Any loan origination fee greater than $1,000 we amortize over the life of the loan. If the bank has a policy and appears reasonable, the external auditors tend to be ok with it.

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#2000907 - 03/10/15 11:56 PM Re: FASB 91 FNB
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
There actually is no difference in treatment, but if the amount is not deemed to be material, many accountants will allow to go straight to income. That means the answer could differ at each bank as each will have different accountants and different materiality thresholds.

If there was a flood (of $1,000) most banks would just charge $999 and take all straight to income.
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