Loans and Allowance for Loan Losses | 4. Loans and Allowance for Loan Losses The Company’s loan and allowance for loan loss policies are as follows: Loans Held for Investment. Loans are stated at unpaid principal balances, less net deferred loan fees and the allowance for loan losses. The Company grants real estate mortgages, commercial business and consumer loans. A substantial portion of the loan portfolio is represented by mortgage loans to customers in southern Indiana. The ability of the Company’s customers to honor their contracts is dependent upon the real estate and general economic conditions in this area. Loan origination and commitment fees, as well as certain direct costs of underwriting and closing loans, are deferred and amortized as a yield adjustment to interest income over the lives of the related loans using the interest method. Amortization of net deferred loan fees is discontinued when a loan is placed on nonaccrual status. Nonaccrual Loans. The recognition of income on a loan is discontinued and previously accrued interest is reversed when interest or principal payments become 90 days past due unless, in the opinion of management, the outstanding interest remains collectible. Past due status is determined based on contractual terms. Generally, by applying the cash receipts method, interest income is subsequently recognized only as received until the loan is returned to accrual status. The cash receipts method is used when the likelihood of further loss on the loan is remote. Otherwise, the Company applies the cost recovery method and applies all payments as a reduction of the unpaid principal balance until the loan qualifies for return to accrual status. Interest income on impaired loans is recognized using the cost recovery method, unless the likelihood of further loss on the loan is remote. A loan is restored to accrual status when all principal and interest payments are brought current and the borrower has demonstrated the ability to make future payments of principal and interest as scheduled, which generally requires that the borrower demonstrate a period of performance of at least six consecutive months. Allowance for Loan Losses. The allowance for loan losses is established as losses are estimated to have occurred through a provision for loan losses charged to earnings. Additions to the allowance for loan losses are made by the provision for loan losses charged to earnings. Loan losses are charged against the allowance when management believes the uncollectability of a loan balance is confirmed. Subsequent recoveries, if any, are credited to the allowance. The Company uses a disciplined process and methodology to evaluate the allowance for loan losses on at least a quarterly basis that is based upon management’s periodic review of the collectability of the loans in light of historical experience, the nature and volume of the loan portfolio, adverse situations that may affect the borrower’s ability to repay, estimated value of any underlying collateral, and prevailing economic conditions. This evaluation is inherently subjective as it requires estimates that are susceptible to significant revision as more information becomes available. The allowance consists of specific and general components. The specific component relates to loans that are individually evaluated for impairment or loans otherwise classified as doubtful or substandard. For such loans that are classified as impaired, an allowance is established when the discounted cash flows or collateral value of the impaired loan is lower than the carrying value of that loan. The general component covers non-classified loans and classified loans that are found, upon individual evaluation, to not be impaired. Such loans are pooled by portfolio segment and losses are modeled using annualized historical loss experience adjusted for qualitative factors. The historical loss experience is determined by portfolio segment and is based on the Company’s actual loss history over the most recent twenty calendar quarters unless the historical loss experience is not considered indicative of the level of risk in the remaining balance of a particular portfolio segment, in which case an adjustment is determined by management. The Company’s historical loss experience is then adjusted for qualitative factors that are reviewed on a quarterly basis. Management’s determination of the allowance for loan losses considers changes and trends in the following qualitative loss factors: lending policies and procedures, including underwriting standards and collection, charge-off and recovery practices and management experience, national and local economic conditions, new loan trends, past due and nonaccrual loans, loan reviews, collateral values, credit concentrations and other internal and external factors such as competition, legal and regulatory changes. Each loan pool’s historical loss rate is adjusted based on positive or negative changes in the qualitative loss factor. This adjustment is what determines the adjust loss rate used in management’s allowance for loan loss adequacy calculation. Management exercises significant judgment in evaluating the relevant historical loss experience and the qualitative factors. Management also monitors the differences between estimated and actual incurred loan losses for loans considered impaired in order to evaluate the effectiveness of the estimation process and make any changes in the methodology as necessary. The following portfolio segments are considered in the allowance for loan loss analysis: one-to-four family residential real estate, multi-family residential real estate, residential construction, commercial construction, commercial real estate non owner occupied, commercial real estate owner occupied, junior liens, home equity lines of credit, commercial business, and consumer loans. Residential real estate loans primarily consist of loans to individuals for the purchase or refinance of their primary residence, with a smaller portion of the segment secured by non-owner-occupied residential investment properties and multi-family residential investment properties. Also, included within the residential real estate loan portfolio are home equity loans and junior lien loans, which are secured by liens on the borrower’s personal residence. The risks associated with residential real estate loans are closely correlated to the local housing market and general economic conditions, as repayment of the loans is primarily dependent on the borrower’s or tenant’s personal cash flow and employment status. The Company’s construction loan portfolio consists of single-family residential properties, multi-family properties and commercial projects, and includes both owner-occupied and speculative investment properties. Risks inherent in construction lending are related to the market value of the property held as collateral, the cost and timing of constructing or improving a property, the borrower’s ability to use funds generated by a project to service a loan until a project is completed, movements in interest rates and the real estate market during the construction phase, and the ability of the borrower to obtain permanent financing. Commercial real estate loans are comprised of loans secured by various types of collateral including farmland, office buildings, warehouses, retail space and mixed-use buildings located in the Company’s primary lending area. Risks related to commercial real estate lending are related to the market value of the property taken as collateral, the underlying cash flows and general economic condition of the local real estate market. Repayment of these loans is generally dependent on the ability of the borrower to attract tenants at lease rates or general business operating cash flows that provide for adequate debt service and can be impacted by local economic conditions which impact vacancy rates and the general level of business activity. The Company generally obtains loan guarantees from financially capable parties for commercial real estate loans. Commercial business loans include lines of credit to businesses, term loans and letters of credit secured by business assets such as equipment, accounts receivable, inventory, or other assets excluding real estate and are generally made to finance capital expenditures or fund operations. Commercial loans contain risks related to the value of the collateral securing the loan and the repayment is primarily dependent upon the financial success and viability of the borrower. As with commercial real estate loans, the Company generally obtains loan guarantees from financially capable parties for commercial business loans. Consumer loans consist primarily of home improvement loans, automobile and truck loans, boat loans, mobile home loans, loans secured by savings deposits, and other personal loans. The risks associated with these loans are related to the local housing market and local economic conditions including the unemployment level. Loan Charge-Offs. For portfolio segments other than consumer loans, the Company’s practice is to charge-off any loan or portion of a loan when the loan is determined by management to be uncollectible due to the borrower’s failure to meet repayment terms, the borrower’s deteriorating or deteriorated financial condition, the depreciation of the underlying collateral, the loan’s classification as a loss by regulatory examiners, or for other reasons. A partial charge-off is recorded on a loan when the collectability of a portion of the loan has been confirmed, such as when a loan is discharged in bankruptcy, the collateral is liquidated, a loan is restructured at a reduced principal balance, or other identifiable events that lead management to determine the full principal balance of the loan will not be repaid. A specific reserve is recognized as a component of the allowance for estimated losses on loans individually evaluated for impairment. Partial charge-offs on nonperforming and impaired loans are included in the Company’s historical loss experience used to estimate the general component of the allowance for loan losses as discussed above. Specific reserves are not considered charge-offs in management’s evaluation of the general component of the allowance for loan losses because they are estimates and the outcome of the loan relationship is undetermined. At March 31, 2020, the Company had six loans for which partial charge-offs in the aggregate of $156,000 had been recorded. Consumer loans not secured by real estate are typically charged off at 90 days past due, or earlier if deemed uncollectible, unless the loans are in the process of collection. Overdrafts are charged off after 60 days past due. A charge-off is typically recorded on a loan secured by real estate when the property is foreclosed upon when the carrying value of the loan exceeds the property’s fair value less the estimated costs to sell. Impaired Loans. A loan is considered impaired when, based on current information and events, it is probable that the Company will be unable to collect the scheduled payments of principal or interest when due according to the contractual terms of the loan agreement. Factors considered by management in determining impairment include payment status, collateral value, and the probability of collecting scheduled principal and interest payments when due. Loans that experience insignificant payment delays and payment shortfalls generally are not classified as impaired. Management determines the significance of payment delays and payment shortfalls on a case-by-case basis, taking into consideration all of the circumstances surrounding the loan and the borrower, including the length of the delay, the reasons for the delay, the borrower’s prior payment record, and the amount of the shortfall in relation to the principal and interest owed. Impairment is measured on a loan-by-loan basis by either the present value of expected future cash flows discounted at the loan’s effective interest rate, the loan’s obtainable market price, or the fair value of the collateral if the loan is collateral dependent. Values for collateral dependent loans are generally based on appraisals obtained from independent licensed real estate appraisers, with adjustments applied for estimated costs to sell the property, costs to complete unfinished or repair damaged property and other factors. New appraisals or valuations are generally obtained for all significant properties (if the value is estimated to exceed $100,000) when a loan is identified as impaired. Subsequent appraisals are obtained or an internal evaluation is prepared annually, or more frequently if management believes there has been a significant change in the market value of a collateral property securing a collateral dependent impaired loan. In instances where it is not deemed necessary to obtain a new appraisal, management bases its impairment evaluation on the original appraisal with adjustments for current conditions based on management’s assessment of market factors and inspection of the property. At March 31, 2020 and December 31, 2019, there were no loans secured by residential real estate property for which formal foreclosure proceedings are in process. Loans at March 31, 2020 and December 31, 2019 consisted of the following: March 31, December 31, (In thousands) 2020 2019 Real estate mortgage loans: One-to-four family residential $ 69,270 $ 71,606 Multi-family residential 9,260 9,260 Residential construction 828 367 Commercial real estate 33,210 32,311 Commercial real estate construction 2,817 2,867 Commercial business loans 6,626 6,456 Consumer loans 1,746 1,875 Total loans 123,757 124,742 Deferred loan origination fees and costs, net 22 28 Allowance for loan losses (1,541) (1,498) Loans, net $ 122,238 $ 123,272 The following table provides the components of the Company’s recorded investment in loans at March 31, 2020: One-to-Four Family Multi-Family Commercial Commercial Residential Residential Construction Real Estate Business Consumer Total (In thousands) Recorded Investment in Loans: Principal loan balance $ 69,270 $ 9,260 $ 3,645 $ 33,210 $ 6,626 $ 1,746 $ 123,757 Accrued interest receivable 219 21 8 104 27 5 384 Net deferred loan fees/costs 21 (10) (36) (12) 13 46 22 Recorded investment in loans $ 69,510 $ 9,271 $ 3,617 $ 33,302 $ 6,666 $ 1,797 $ 124,163 Recorded Investment to Loan as Evaluated for Impairements: Individually evaluated for impairment $ 1,327 $ — $ — $ 614 $ 403 $ — $ 2,344 Collectively evaulated for impairment 68,183 9,271 3,617 32,688 6,263 1,797 121,819 Ending balance $ 69,510 $ 9,271 $ 3,617 $ 33,302 $ 6,666 $ 1,797 $ 124,163 The following table provides the components of the Company’s recorded investment in loans at December 31, 2019: One-to-Four Family Multi-Family Commercial Commercial Residential Residential Construction Real Estate Business Consumer Total (In thousands) Recorded Investment in Loans: Principal loan balance $ 71,606 $ 9,260 $ 3,234 $ 32,311 $ 6,456 $ 1,875 $ 124,742 Accrued interest receivable 254 25 11 88 26 6 410 Net deferred loan fees/costs 23 (11) (36) (6) 10 48 28 Recorded investment in loans $ 71,883 $ 9,274 $ 3,209 $ 32,393 $ 6,492 $ 1,929 $ 125,180 Recorded Investment to Loan as Evaluated for Impairements: Individually evaluated for impairment $ 1,431 $ — $ — $ 600 $ 412 $ — $ 2,443 Collectively evaulated for impairment 70,452 9,274 3,209 31,793 6,080 1,929 122,737 Ending balance $ 71,883 $ 9,274 $ 3,209 $ 32,393 $ 6,492 $ 1,929 $ 125,180 An analysis of the allowance for loan losses as of March 31, 2020 is as follows: One-to-Four Family Multi-Family Commercial Commercial Residential Residential Construction Real Estate Business Consumer Total (In thousands) Ending allowance balance attributable to loans: Individually evaluated for impairment $ 26 $ — $ — $ 19 $ 33 $ — $ 78 Collectively evaluated for impairment 942 92 40 293 72 24 1,463 Ending balance $ 968 $ 92 $ 40 $ 312 $ 105 $ 24 $ 1,541 An analysis of the allowance for loan losses as of December 31, 2019 is as follows: One-to-Four Family Multi-Family Commercial Commercial Residential Residential Construction Real Estate Business Consumer Total (In thousands) Ending allowance balance attributable to loans: Individually evaluated for impairment $ 25 $ — $ — $ 19 $ 34 $ — $ 78 Collectively evaluated for impairment 930 83 44 270 68 25 1,420 Ending balance $ 955 $ 83 $ 44 $ 289 $ 102 $ 25 $ 1,498 An analysis of the changes in the allowance for loan losses for the three months ended March 31, 2020 is as follows: One-to-Four Family Multi-Family Commercial Commercial Residential Residential Construction Real Estate Business Consumer Total (In thousands) Allowance for Loan Losses: Beginning balance $ 955 $ 83 $ 44 $ 289 $ 102 $ 25 $ 1,498 Provisions 24 9 (4) 23 3 2 57 Charge-offs (12) — — — — (6) (18) Recoveries 1 — — — — 3 4 Ending balance $ 968 $ 92 $ 40 $ 312 $ 105 $ 24 $ 1,541 An analysis of the changes in the allowance for loan losses for the three months ended March 31, 2019 is as follows: One-to-Four Family Multi-Family Commercial Commercial Residential Residential Construction Real Estate Business Consumer Total (In thousands) Allowance for Loan Losses: Beginning balance $ 1,012 $ 59 $ 48 $ 259 $ 98 $ 28 $ 1,504 Provisions (30) 16 (10) 24 5 (5) — Charge-offs — — — — — (5) (5) Recoveries 10 — — — — 5 15 Ending balance $ 992 $ 75 $ 38 $ 283 $ 103 $ 23 $ 1,514 The following table summarizes the Company’s impaired loans as of March 31, 2020 and for the three months ended March 31, 2020. The Company did not recognize any interest income on impaired loans using the cash receipts method of accounting for the three-month period ended March 31, 2020: Three Months Ended At March 31, 2020 March 31, 2020 Unpaid Average Interest Recorded Principal Related Recorded Income Investment Balance Allowance Investment Recognized (In thousands) Loans with no related allowance recorded: One-to-four family residential $ 1,070 $ 1,148 $ — $ 1,121 $ 2 Multi-family residential — — — — — Construction — — — — — Commercial real estate 253 246 — 244 — Commercial business 31 30 — 31 — Consumer — — — — — $ 1,354 $ 1,424 $ — $ 1,396 $ 2 Loans with an allowance recorded: One-to-four family residential $ 257 $ 282 $ 25 $ 258 $ — Multi-family residential — — — — — Construction — — — — — Commercial real estate 361 359 19 363 5 Commercial business 372 419 34 376 5 Consumer — — — — — $ 990 $ 1,060 $ 78 $ 997 $ 10 Total: One-to-four family residential $ 1,327 $ 1,430 $ 25 $ 1,379 $ 2 Multi-family residential — — — — — Construction — — — — — Commercial real estate 614 605 19 607 5 Commercial business 403 449 34 407 5 Consumer — — — — — $ 2,344 $ 2,484 $ 78 $ 2,393 $ 12 The following table summarizes the Company’s impaired loans for the three-month period ended March 31, 2019. The Company did not recognize any interest income on impaired loans using the cash receipts method of accounting for the three-month period ended March 31, 2019: Three Months Ended March 31, 2019 Average Interest Recorded Income Investment Recognized (In thousands) Loans with no related allowance recorded: One-to-four family residential $ 1,424 $ 8 Multi-family residential — — Construction — — Commercial real estate 385 1 Commercial business 48 — Consumer — — $ 1,857 $ 9 Loans with an allowance recorded: One-to-four family residential $ 454 $ 3 Multi-family residential — — Construction — — Commercial real estate 354 5 Commercial business 415 6 Consumer — — $ 1,223 $ 14 Total : One-to-four family residential $ 1,878 $ 11 Multi-family residential — — Construction — — Commercial real estate 739 6 Commercial business 463 6 Consumer — — $ 3,080 $ 23 The following table summarizes the Company’s impaired loans as of December 31, 2019: At December 31, 2019 Unpaid Recorded Principal Related Investment Balance Allowance (In thousands) Loans with no related allowance recorded: One-to-four family residential $ 1,172 $ 1,457 $ — Multi-family residential — — — Construction — — — Commercial real estate 235 389 — Commercial business 32 32 — Consumer — — — $ 1,439 $ 1,878 $ — Loans with an allowance recorded: One-to-four family residential $ 259 $ 284 $ 25 Multi-family residential — — — Construction — — — Commercial real estate 365 364 19 Commercial business 380 426 34 Consumer — — — $ 1,004 $ 1,074 $ 78 Total: One-to-four family residential $ 1,431 $ 1,741 $ 25 Multi-family residential — — — Construction — — — Commercial real estate 600 753 19 Commercial business 412 458 34 Consumer — — — $ 2,443 $ 2,952 $ 78 Nonperforming loans consists At March 31, 2020 At December 31, 2019 Loans 90+ Loans 90+ Days Total Days Total Nonaccrual Past Due Nonperforming Nonaccrual Past Due Nonperforming Loans Still Accruing Loans Loans Still Accruing Loans (In thousands) One-to-four family residential $ 991 $ — $ 991 $ 947 $ — $ 947 Multi-family residential — — — — — — Construction — — — — — — Commercial real estate 253 — 253 235 — 235 Commercial business — — — — — — Consumer — — — — — — Total $ 1,244 $ — $ 1,244 $ 1,182 $ — $ 1,182 The following tables present the aging of the recorded investment in loans at March 31, 2020 and December 31, 2019: Over 90 30‑59 Days 60‑89 Days Days Total Total Past Due Past Due Past Due Past Due Current Loans March 31, 2020 (In thousands) One-to-four family residential $ 1,370 $ — $ 52 $ 1,422 $ 68,088 $ 69,510 Multi-family residential — — — — 9,271 9,271 Construction — — — — 3,617 3,617 Commercial real estate 482 — — 482 32,820 33,302 Commercial business 11 — — 11 6,655 6,666 Consumer — — — — 1,797 1,797 Total $ 1,863 $ — $ 52 $ 1,915 $ 122,248 $ 124,163 December 31, 2019 One-to-four family residential $ 1,425 $ 575 $ 238 $ 2,238 $ 69,645 $ 71,883 Multi-family residential — — — — 9,274 9,274 Construction 152 — — 152 3,057 3,209 Commercial real estate 477 134 — 611 31,782 32,393 Commercial business — — — — 6,492 6,492 Consumer 7 — — 7 1,922 1,929 Total $ 2,061 $ 709 $ 238 $ 3,008 $ 122,172 $ 125,180 The Company categorizes loans into risk categories based on relevant information about the ability of borrowers to service their debt such as: current financial information, public information, historical payment experience, credit documentation, and current economic trends, among other factors. The Company classifies loans based on credit risk at least quarterly. The Company uses the following regulatory definitions for risk ratings: Special Mention : Loans classified as special mention have a potential weakness that deserves management’s close attention. If left uncorrected, these potential weaknesses may result in deterioration of the repayment prospects for the loan or of the institution’s credit position at some future date. Substandard : Loans classified as substandard are inadequately protected by the current net worth and paying capacity of the obligor or of the collateral pledged, if any. Loans so classified have a well-defined weakness or weaknesses that jeopardize the liquidation of the debt. They are characterized by the distinct possibility that the institution will sustain some loss if the deficiencies are not corrected. Doubtful : Loans classified as doubtful have all the weaknesses inherent in those classified as substandard, with the added characteristic that the weaknesses make collection or liquidation in full, on the basis of currently existing facts, conditions, and values, highly questionable and improbable. Loss : Loans classified as loss are considered uncollectible and of such little value that their continuance on the institution’s books as an asset is not warranted. Loans not meeting the criteria above that are analyzed individually as part of the above described process are considered to be pass rated loans. The following table presents the recorded investment in loans by risk category as of the dates indicated: One-to- Multi- Four Family Family Commercial Commercial Residential Residential Construction Real Estate Business Consumer Total March 31, 2020 (In thousands) Pass $ 68,288 $ 9,271 $ 3,617 $ 32,676 $ 6,263 $ 1,797 $ 121,912 Special mention — — — 207 — — 207 Substandard 1,222 — — 419 403 — 2,044 Doubtful — — — — — — — Loss — — — — — — — Total $ 69,510 $ 9,271 $ 3,617 $ 33,302 $ 6,666 $ 1,797 $ 124,163 December 31, 2019 Pass $ 70,611 $ 9,274 $ 3,209 $ 31,949 $ 6,080 $ 1,929 $ 123,052 Special mention — — — — — — — Substandard 1,272 — — 444 412 — 2,128 Doubtful — — — — — — — Loss — — — — — — — Total $ 71,883 $ 9,274 $ 3,209 $ 32,393 $ 6,492 $ 1,929 $ 125,180 Modification of a loan is considered to be a troubled debt restructuring ("TDR") if the debtor is experiencing financial difficulties and the Company grants a concession to the debtor that it would not otherwise consider. By granting the concession, the Company expects to obtain more cash or other value from the debtor, or to increase the probability of receipt, than would be expected by not granting the concession. The concession may include, but is not limited to, reduction of the stated interest rate of the loan, reduction of accrued interest, extension of the maturity date or reduction of the face amount of the debt. A concession will be granted when, as a result of the restructuring, the Company does not expect to collect all amounts due, including interest at the original stated rate. A concession may also be granted if the debtor is not able to access funds elsewhere at a market rate for debt with similar risk characteristics as the restructured debt. The Company’s determination of whether a loan modification is a TDR considers the individual facts and circumstances surrounding each modification. A TDR can involve loans remaining on nonaccrual, moving to nonaccrual, or continuing on accrual status, depending on the individual facts and circumstances of the restructuring. A TDR on nonaccrual status is restored to accrual status when the borrower has demonstrated the ability to make future payments in accordance with the restructured terms, including consistent and timely payments for at least six consecutive months in accordance with the restructured terms. The Coronavirus Aid, Relief, and Economic Security Act of 2020 signed into law on March 27, 2020 ("CARES Act") provides guidance around the modification of loans as a result of the COVID-19 pandemic, which outlined, among other criteria, that short-term modifications made on a good faith basis to borrowers who were current as defined under the CARES Act prior to any relief, are not TDRs. This includes short-term (e.g. six months) modifications such as payment deferrals, fee waivers, extensions of repayment terms, or other delays in payment that are insignificant. Borrowers are considered current under the CARES Act if they are less than 30 days past due on their contractual payments at the time a modification program is implemented. At March 31, 2020, the Bank had no modified loans related to the COVID-19 pandemic. The following table summarizes the Company’s TDRs by accrual status as of March 31, 2020 and December 31, 2019: March 31, 2020 December 31, 2019 Related Related Allowance for Allowance for Accruing Nonaccrual Total Loan Losses Accruing Nonaccrual Total Loan Losses (In thousands) One-to-four family residential $ 336 $ — $ 336 $ 25 $ 484 $ — $ 484 $ 25 Commercial real estate 361 135 496 19 365 137 502 19 Commercial business 403 — 403 34 412 — 412 34 Total $ 1,100 $ 135 $ 1,235 $ 78 $ 1,261 $ 137 $ 1,398 $ 78 At both March 31, 2020 and December 31, 2019 there were no commitments to lend additional funds to debtors whose loan terms have been modified in a TDR (both accruing and nonaccruing). There were no TDRs that were restructured during the three months ended March 31, 2020. The following table summarizes information in regard to TDRs that were restructured during the three months ended March 31, 2019: Three Months Ended March 31, 2019 Pre-Modification Post-Modification Number of Outstanding Outstanding Contracts Balance Balance (In thousands) Commercial real estate 1 $ 158 $ 158 Total 1 $ 158 $ 158 For TDRs that were restructured during the three months ended March 31, 2019, the terms of modifications included a reduction of the stated interest rate, extension of the maturity date, and the renewal or refinancing of loans where the debtor was unable to access funds elsewhere at a market interest rate for debt with similar risk characteristics. There were no principal charge-offs recorded as a result of TDRs and there was no specific allowance for loan losses related to TDRs modified during the three-month periods ended March 31, 2020 and 2019. There were no TDRs modified within the previous 12 months for which there was a subsequent payment default (defined as the loan becoming more than 90 days past due, being moved to nonaccrual status, or the collateral being foreclosed upon) during the three-month periods ended March 31, 2020 and 2019. In the event that a TDR subsequently defaults, the Company evaluates the restructuring for possible impairment. As a result, the related allowance for loan losses may be increased or charge-offs may be taken to reduce the carrying amount of the loan. On March 22, 2020, federal banking regulators issued an interagency statement that included guidance on their approach for the accounting of loan modifications in light of the economic impact of the COVID-19 pandemic. The guidance interprets current accounting standards and indicates that a lender can conclude that a borrower is not experiencing financial difficulty if short-term modifications are made in response to COVID-19, such as payment deferrals, fee waivers, extensions of repayment terms, or other delays in payment that are insignificant related to the loans in which the borrower is less than 30 days past due on its contractual payments at the time a modification program is implemented. The agencies confirmed in working with the staff of the Financial Accounting Standards Board (“FASB”) that short-term modifications made on a good faith basis in response to COVID-19 to borrowers who were current prior to any relief are not TDRs. |