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As discussed in ASC 310-40-15-5, the assessment of whether a loan modification or restructuring represents a TDR requires an assessment of (a) whether the borrower is experiencing financial difficulties and (b) whether the creditor has granted a concession. ASC 310-40-15-13 through 15-20 and provides additional guidance for creditors to consider in evaluating whether the borrower is experiencing financial difficulty and whether the creditor has granted a concession.

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