Comments Due to NAFCU: NCUA - Policy Statement on Prudent Commercial Real Estate Loan Accommodations and Workouts
NAFCU would like to highlight the following:
- The proposed policy statement, if finalized, will supersede the Federal Financial Institutions Examination Council’s (FFIEC) October 2009 Policy Statement on Prudent Commercial Real Estate Loan Workouts.
- In addition to providing updated guidance on loan workouts, the proposed policy statement includes a new section on short-term loan accommodations and reflects post-2009 changes in generally accepted accounting principles (GAAP), including the current expected credit losses (CECL) methodology.
- The agencies intend for the proposed policy statement to promote supervisory consistency among examiners and ensure supervisory policies do not inadvertently curtail sound commercial borrowers’ access to credit.
Comments due to NAFCU: September 26, 2022
Comments due to NCUA: October 3, 2022
NAFCU will send comments on behalf of its members to the NCUA by its deadline (October 3, 2022).