OCC Bulletin

Published December 13, 2013

See the attached OCC Bulletin 2012-10 which is a good authoritative source on your question.  See the “once a TDR always a TDR?” section on page 4 of 5.


Basically the A note in a A/B note restructure can be “de-recognized” for reporting purposes in the calendar year after the restructuring, assuming that it is performing under the restructured terms.  However, for measurement purposes, that loan would continue to be considered impaired and accounted for under ASC 310-10 and not ASC 450. 


Doesn’t make a lot of sense to be honest, but those appear to be rules.

Associated Files

Occ bulletin 2012-10 on tdrs dtd 4-5-12 (146.5 KB / pdf)

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