January 6, 2014 - 2:51pm
#1
I am looking to see which of you have a Policy in place or rely on procedures in evaluating a loan deemed a TDR or for modification. Does your CU have a Board approved Policy in place on TDRs and Modified Loans that define eligibility requirements, limits on the number of times a loan may be modified, ensure loan workouts a decisioned based on the borrower's renewed willingness and ability to repay the loan and establish sound controls to ensure workout actions are appropriately structured as per Appendix C to Part 741? Or are these items covered in procedures that are approved by management rather than your Board?
