I cannot determine if the FFIEC limits on re-aging, renewals etc. apply only to delinquent loans or to all loans. We are an OTS bank and their statement says they adopt the FFIEC policy. The FDIC statement, referenced several times in the BOL lending threads, defines retail credit at the very beginning of their statement but then goes on to apparently limit the revision to delinquent credits. We have a lot of extensions and renewals and I am about to go down the very long road of figuring out if we are doing them correctly and would like some help to at least stay on the right road as I go.

Extensions, renewals, deferrals are not just limited to delinquent loans. Regulators want to be sure that financial institutions are not abusing the use of extensions, renewals, deferrals to hide past due or non-performing loans. In addition the regulators want to be sure that financial institutions don't have "stale" debt on the books that are not being repaid. Add to the fact that financial institutions are not doing consumers a favor by allowing them to take on debt that they can't cash flow, add fees and perhaps continue the cycle of "hiding" poor credits with renewal, extensions....

When you say "we have a lot of extensions and renewal" you might want to review those to determine if there is any possibility those are being granted to consumers that have poor repayment capacity. You could also consider creating policy/procedures for the use of renewals, extensions, deferrals, rewrites.

Sigh. Thank you.