Q: TDR Categorization. Will FDIC examiners make banks categorize all loan modifications related to COVID-19 events as a TDR?
A: No. The FDIC continues to encourage financial institutions to work with borrowers who may be impacted by COVID-19, by offering to modify, extend, suspend, or defer the repayment terms. FDIC examiners have been directed to exercise significant flexibility in reviewing credits that are impacted by COVID- 19 and will work with financial institutions relative to any reporting issues. Please refer to interagency supervisory guidance, which provides more information on TDRs.
This Q&A was contained in the Frequently Asked Questions for Financial Institutions Affected by the Coronavirus Disease 2019 (Referred to as COVID-19) – As of March 3, 2021 (which may be updated from time to time). This may be found on the FDIC’s website here: https://www.fdic.gov/Coronavirus/faq-fi.pdf.