Hello!

We don't run into this a lot, but we are considering a TDR for a borrower. However, I know that FASB issued guidance, which eliminates the TDR altogether IF we have adopted CECL. I am trying to read guidance, but it is hard to understand. With the changes, what are exactly supposed to do to remain compliant? I see there are new disclosures, but I can't find a template or anything for that. Do we still report TDRs on call reports?

Thank you!

TDRs are gone once you have adopted CECL.
But, you will likely have a "Modification to a Borrower Experiencing Financial Difficulty" if you make a modification or new loan to a borrower with financial difficulties. See ASU 2022-02. The definition is very similar to TDRs, but not the same. For instance, the new "MBEFDs" are tracked only for 12 months after the modification or origination date. One article:
https://www.elliottdavis.com/wp-con...dbye-to-Troubled-Debt-Restructurings.pdf

For the call report, impaired loans and TDRs go away once you've adopted CECL. But you'll report any "MBEFDs" (or whatever better acronym the industry eventually comes up with).
See page 3: March 2023 Call Report Materials: https://www.fdic.gov/news/financial-institution-letters/2023/fil23011a.pdf
“For Call Report purposes, institutions that have adopted ASU 2022-02 should report all loans modified since adoption of the new standard to borrowers experiencing financial difficulty that are performing in accordance with their modified terms on Schedule RC-C, Part I, Memorandum items 1.a. through 1.g. If a loan is not performing in accordance with its modified terms, it should be reported on Schedule RC-N, Memorandum items 1.a through 1.g. Institutions should use loan modifications to borrowers experiencing financial difficulty in the calculation of the 10 percent threshold for the itemization of loan categories for Memorandum item 1.f on Schedules RC-C and RC-N. Institutions that have adopted ASU 2022-02 should no longer report TDRs in Memorandum items 1.a through 1.g on Schedules RC-C and RC-N.”
“Upon adoption of this standard, institutions have an option to apply a modified retrospective transition method for the elimination of the TDR recognition and measurement guidance. The option to apply a modified retrospective transition method would result in a cumulative effect adjustment to retained earnings in the period of adoption. The cumulative-effect adjustment to bank equity capital for this change in accounting principle should be reported in Schedule RI-A, Changes in Bank Equity Capital, item 2, and disclosed in Schedule RI-E, Explanations, item 4.c or 4.d, with a write-in descriptor indicating “ASU 2022-02.” Institutions that have adopted both ASU 2016-13 and ASU 2022-02 in 2023 and have not isolated the impact to retained earnings for ASU 2022-02 may report the total impact of ASU 2016-13 and its subsequent amendments in Schedule RI-E, Explanations, item 4.a.”