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    FED Seeks Comments on Commercial Real Estate Loan Accomodations

    September 27, 2022

    The Board of Governors of the Federal Reserve System (FED) is seeking comments, until November 14, 2022, on a proposed policy statement for prudent commercial real estate loan accommodations and workouts. The proposed statement will be applicable to all financial institutions supervised by the FED.

    The proposed statement builds on existing guidance on the need for financial institutions to work prudently and constructively with creditworthy borrowers during times of financial stress, to update and expand the existing interagency guidance on commercial real estate loan workouts, and to add a new section on short-term loan accommodations. The proposed statement would also address recent accounting changes on estimating loan losses and provide updated examples of how to classify and account for loans subject to loan accommodations or loan workout activity. The proposed statement is identical to a proposal issued by the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the National Credit Union Administration (NCUA), on August 02, 2022, in consultation with state bank and credit union regulators.

    The proposed statement discusses the importance of working constructively with commercial real estate borrowers that are experiencing financial difficulty and would be appropriate for all supervised financial institutions engaged in commercial real estate lending that apply U.S. generally accepted accounting principles (GAAP). While focused on commercial real estate loans, the proposed statement includes general principles that are relevant to a financial institution's commercial loans that are collateralized by either real property or other business assets of a borrower. Additionally, the proposed statement includes updated references to supervisory guidance and would revise language to incorporate current industry terminology.


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    Keywords: Americas, US, Banking, Commercial Real Estate, Credit Risk, Lending, GAAP, CRE, OCC, FDIC, NCUA, FED

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