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ARTICLE · 20 APRIL 2020

COVID-19: When A Bank Loan Restructure May Not Be A Troubled Debt Restructuring

Thompson Coburn LLP
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On March 22, 2020, the Federal banking and credit union regulators (FRB, FDIC, NCUA, OCC and CFPB) (collectively, the "Agencies")

United StatesFinance and Banking
John Manning, V
John Manning, V
Sarah Wade
Sarah Wade
Garrett Fischer
Garrett Fischer
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On March 22, 2020, the Federal banking and credit union regulators (FRB, FDIC, NCUA, OCC and CFPB) (collectively, the "Agencies"), along with the Conference of State Bank Supervisors published an Interagency Statement on Loan Modifications and Reporting for Financial Institutions Working with Customers Affected by the Coronavirus (the "Statement") discussing the appropriate accounting and reporting for Coronavirus Disease 2019 ("COVID-19") related loan restructurings. The Statement encourages banks to work with their customers to resolve pandemic-related issues, characterizing such workouts as "positive actions." In addition, it provides a restructuring roadmap for banks and credit agencies that decide to work with customers on issues related to the pandemic. As provided in the Statement,

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