A joint agency proposed policy statement on commercial real estate (CRE) loan accommodations and workouts is a thorough and well-supported update to existing guidance, CUNA wrote to NCUA Monday. NCUA—and other federal financial regulators—proposed the update, as the last one was made in 2009.

It would build on existing guidance on the need for financial institutions to work prudently and constructively with creditworthy borrowers during times of financial stress, update existing interagency guidance on commercial real estate loan workouts, and add a new section on short-term loan accommodations.

The proposed statement contains several changes, including:

• A new section on short-term loan accommodations, which CUNA supports, as longer-term workouts are often much more complex, and a short-term solution can also be possible. CUNA also agrees with the risk management practices and internal controls.
• Information about changes in accounting principles since 2009, including the current expected credit loss (CECL) standard, Troubled Debt Restructuring, and other updates since the policy statement was last updated in 2009.