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July 3, 2012 – NAFCU member credit unions looking for an overview of NCUA's final rule on troubled debt restructurings, adopted in May, can find it in the July issue of the NAFCU Compliance Monitor.

The TDR final rule, which took effect Monday, has a staggered implementation schedule. This rule is the lead story for the association's July compliance newsletter.

In approving the final rule, the NCUA Board eliminated some onerous reporting provisions that NAFCU, in a long series of communications on this issue, identified as being onerous and unnecessary.

The provision of the rule that kicked in Monday requires credit unions to calculate the past-due status of all workout loans consistent with the loan contract terms, including amendments made through a formal restructuring. NCUA updated the Call Report instructions to reflect this change effective for the quarter ending June 30, 2012.

Compliance dates ahead are:

• Oct. 1: By this date, federally insured credit unions must adopt written policies addressing loan workouts and nonaccrual practices.
• Dec. 31: As of this date, NCUA will begin collecting data required under guidance issued with the rule in the Call Report for the quarter ending this Dec. 31. The guidance was published as an interpretive ruling and policy statement and included in Appendix C of NCUA's rule on loan workouts.

For a monthly email about the latest Compliance Monitor, send a request to compliance@nafcu.org.

For more, download the July Compliance Monitor (login required).