Is it a requirement that a loan be placed in non-accrual status at a certain number of days late (90, 120 days)? In the past we've automatically placed them at 90 days but wonder if we have a choice and can decide on a case by case basis.

UNIFORM RETAIL CREDIT CLASSIFICATION AND ACCOUNT MANAGEMENT POLICY

The Call Reporting instructions state that, unless the loan is both well-secured and in the process of collection (i.e. litigation, foreclosure), it must be placed in non-accrual when it reaches 90 days past due. There is an exception for consumer loans and loans secured by 1 - 4 family residential property but states that these loans should be subject to other methods of evaluation to assure that the bank's income is not materially overstated.

Definitely go to the "Uniform Retail Credit Classification and Account Management Policy"--FDIC Statements of Policy. Pages move a little but was on pg. 5081-5083.

The URCC policy statement referred to above primarily applies to personal loans, consumer loans, credit card loans and first-lien residential mortgages (it does not apply to commercial loans) ... but I don't recall any non-accrual guidance in the policy statement. I believe it provides guidance for retail credits only in regard to adverse loan classification and when to charge-off a loan ... as well as guidance on renewals/extenstions/etc. But for non-accrual policy guidance ... I am with KYAuditor ... follow the call report instructions (because those instructions for non-accrual status are consistent with GAAP).