ASC 310-10-50-39 indicates that the disclosure requirements apply to assets for which the accounting for modifications is within the scope of
ASC 310-20. This would include loans, but would not include leases.
These disclosure requirements apply to modifications of instruments with borrowers experiencing financial difficulty that result in a direct change in the timing or amount of contractual cash flows. As a result, the disclosures are applicable to situations when there is
- principal forgiveness,
- interest rate reductions,
- other-than-insignificant payment delays,
- term extensions, or
- a combination of the above.
ASC 310-10-50-39
The disclosures in paragraphs 310-10-50-42 through 50-44 shall be provided for modifications of receivables to borrowers experiencing financial difficulty in the form of principal forgiveness, an interest rate reduction, an other-than-insignificant payment delay, or a term extension made within the scope of this Topic. For purposes of those disclosures, covenant waivers and modifications of contingent acceleration clauses would not be considered term extensions.
Since the concept of a concession was removed in conjunction with the elimination of TDRs for creditors, disclosures are required for modifications of loans with borrowers experiencing financial difficulty, regardless of whether the modification is considered to be a concession as defined in previous guidance. That is, modifications of loans with borrowers experiencing financial difficulty that may not have been considered concessions and therefore not accounted for or disclosed as TDRs may now be within the scope of the required disclosures. For example, if a creditor lowers the interest rate on a loan to a borrower experiencing financial difficulty in exchange for receiving additional collateral, the modification may have not been considered a concession under previous GAAP; however, such a modification is in the scope of the disclosures required by the revised guidance.
Other situations, such as covenant waivers and modifications of contingent acceleration clauses, may have only indirect changes to the timing of cash flows. For example, as a result of a covenant waiver, a loan’s principal amount may no longer be subject to potential acceleration. Since this is not a direct change to the timing or amount of contractual cash flows,
ASC 310-10-50-39 indicates that in the absence of other modifications, the loan would not be required to be included in the disclosures.
With respect to delays in payments, if a modification of a loan with a borrower experiencing financial difficulty only involves an insignificant delay in payment, it is not required to be included in the disclosures. The guidance requires the consideration of a 12-month lookback period when determining whether a delay in payment resulting from the current restructuring is insignificant.
ASC 310-10-50-47
If the debt has been previously restructured, an entity shall consider the cumulative effect of past restructurings made within the 12-month period before the current restructuring when determining whether a delay in payment resulting from the current restructuring is insignificant.
Summary of disclosures
ASC 310-10-50-42 through
ASC 310-10-50-44 provide disclosure requirements designed to provide users with information about the types of modifications made to receivables with borrowers experiencing financial difficulty, the magnitude of those modifications, and the degree of success of the modifications in mitigating potential credit losses. The disclosures are applicable regardless of whether a modification of a receivable from a troubled debtor is treated as a new loan or a continuation of an existing loan.
Certain financing receivables (such those that are measured at fair value with changes in fair value reported in current earnings) are not subject to the disclosures. The disclosures required in the guidance are applicable regardless of whether a modification to a receivable from a debtor experiencing financial difficulty results in a new receivable or a modified receivable.
For all income statement periods presented,
ASC 310-10-50-42 requires reporting entities to disclose the following for modifications of receivables made to debtors experiencing financial difficulty that are in the form of principal forgiveness, an interest rate reduction, an other-than-insignificant payment delay, or a term extension:
- Qualitative and quantitative information, by class of financing receivable, including:
- By type of modification, the total period-end amortized cost basis of modified receivables, and the percentage relative to the total period-end amortized cost basis of receivables in the class of financing receivable.
- The financial effect of the modification, providing information about the changes to the contractual terms as a result of the modification, including:
- the incremental effect of principal forgiveness on the amortized cost basis, and/or
- the reduction in the weighted-average interest rate (versus a range) for interest rate reductions.
- The performance of the asset in the 12 months following the modification.
- Qualitative information, by portfolio segment, discussing how such modifications factored into the determination of the allowance for credit losses.
ASC 310-10-50-43 requires that if the same receivable is modified in more than one manner (e.g., an interest rate reduction and principal forgiveness), the modification be shown in a separate category of modification type.
ASC 310-10-50-44 requires that for all income statement periods presented, if there was a payment default during the period and the receivable had been modified in the form of principal forgiveness, an interest rate reduction, an other-than-insignificant payment delay, or a term extension within the previous 12 months preceding the payment default when the debtor was experiencing financial difficulty, the reporting entity should also disclose the following:
● Qualitative and quantitative information, by class of financing receivable, about:
○ the types of contractual change that the modification provided. and
○ the amount of financing receivables that defaulted, including the period-end amortized cost basis for financing receivables that defaulted.
● Qualitative information, by portfolio segment, discussing how such defaults factored into the determination of the allowance for credit losses.
For an illustration of the disclosures noted above, refer to Example 3 within
ASC 310-10-55-12A. These disclosures are required to be included in annual and interim periods in accordance with
ASC 270-10-50-1.
ASC 310-10-50-41
The disclosures required in paragraphs 310-10-50-42 through 50-44 are applicable regardless of whether a modification of a receivable to a debtor experiencing financial difficulty results in a new loan in accordance with paragraphs 310-20-35-9 through 35-11. As a practical expedient, an entity may exclude the accrued interest receivable balance that is included in the amortized cost basis of financing receivables for the purposes of the disclosure requirements in Subtopic 326-20. If an entity has applied that practical expedient, an entity may do the same for the disclosures in paragraphs 310-10-50-42 through 50-44 and shall disclose the total amount of accrued interest excluded from the disclosed amortized cost basis.
ASC 310-10-50-42
For each period for which a statement of income is presented, an entity shall disclose the following information related to modifications of receivables that are in the form of principal forgiveness, an interest rate reduction, an other than-insignificant payment delay, or a term extension (or a combination thereof) made to debtors experiencing financial difficulty during the reporting period:
a. By class of financing receivable, qualitative and quantitative information about:
- The types of modifications utilized by an entity, including the total period-end amortized cost basis of the modified receivables and the percentage of modifications of receivables made to debtors experiencing financial difficulty relative to the total period-end amortized cost basis of receivables in the class of financing receivable.
- The financial effect of the modification by type of modification, which shall provide information about the changes to the contractual terms as a result of the modification and shall include the incremental effect of principal forgiveness on the amortized cost basis of the modified receivables, as applicable, or the reduction in weighted-average interest rates (versus a range) for interest rate reductions.
- Receivable performance in the 12 months after a modification of a receivable made to a debtor experiencing financial difficulty.
b. By portfolio segment, qualitative information about how those modifications and the debtors’ subsequent performance are factored into determining the allowance for credit losses.
ASC 310-10-50-43
Receivables may be modified in more than one manner. An entity that modifies the same receivable in more than one manner shall provide disclosures sufficient for users to understand the different types of combinations of modifications provided to borrowers. For example, a receivable may be modified to provide both principal forgiveness and an interest rate reduction. In that case, an entity shall disclose the period-end amortized cost basis of that receivable in a separate category that reflects that a combination of modification types has been granted. If another receivable was modified to provide both an interest rate reduction and a term extension, the period-end amortized cost basis of that receivable shall be presented in a different category. Multiple separate combination categories may be necessary if significant. The same receivable’s period-end amortized cost basis shall not be presented in multiple categories.
ASC 310-10-50-44
For each period for which a statement of income is presented, an entity shall disclose the following information about financing receivables that had a payment default during the period and had been modified in the form of principal forgiveness, an interest rate reduction, an other-than-insignificant payment delay, or a term extension (or a combination thereof) within the previous 12 months preceding the payment default when the debtor was experiencing financial difficulty at the time of the modification:
a. By class of financing receivable, qualitative and quantitative information about those defaulted financing receivables, including the following:
- The type of contractual change that the modification provided
- The amount of financing receivables that defaulted, including the period-end amortized cost basis for financing receivables that defaulted.
b. By portfolio segment, qualitative information about how those defaults are factored into determining the allowance for credit losses.
ASC 310-10-50-36 also requires creditors to disclose the amount of any commitments to lend additional funds to debtors experiencing financial difficulty for which the creditor has modified the terms of the receivables in the form of principal forgiveness, an interest rate reduction, other-than-insignificant payment delay, or a term extension in the current reporting period.
Question LI 12-1Is the same population of loans captured in the different disclosures in
ASC 310-10-50-42(a)?
PwC response
It depends.
ASC 310-10-50-42(a)(3) requires disclosure of the performance of receivables in the 12-months after a modification to a debtor experiencing financial difficulty.
ASC 310-10-50-44 requires information about receivables that had a payment default during the period and had been modified in the form of principal forgiveness, an interest rate reduction, an other-than-insignificant payment delay, or a term extension (or combination thereof) within the previous 12 months preceding the payment default. For these disclosures, the 12-month period begins the date the receivable was modified (i.e. the date of the most recent modification). However, the disclosures in
ASC 310-10-50-42(a)(1) through
50-42(a)(2) are based on modifications made
during the reporting period. The example in
ASC 310-10-55-12A illustrates these disclosures in annual financial statements. The amounts included in these disclosures for
interim reporting periods may not tie to amounts disclosed in accordance with
ASC 310-10-50-42(a)(3) and
ASC 310-10-50-44. For example, if a calendar year reporting entity modified a receivable in the middle of November of the current period:
- The current year annual financial statements would include information related to this modification under ASC 310-10-50-42(a)(1) through 50-42(a)(3) (and ASC 310-10-50-44, if applicable).
- Next year’s first, second, and third quarter financial statements would include information related to this modification under ASC 310-10-50-42(a)(3) and ASC 310-10-50-44 (if applicable); Disclosures related to this modification under ASC 310-10-50-42(a)(1) through 50-42(a)(2) would not be required because the modification occurred in a previous reporting period.
- Next year’s annual financial statements would include information related to this modification only in the comparative information presented.