This proposal can be a very important step forward for credit unions which are struggling to work with home loan borrowers who have turned to their credit unions for help, or for other members who need workout plans due to changed financial circumstances.

We appreciate that that agency has listened to credit union concerns, expressed repeatedly by CUNA and the Leagues, that call report requirements actually discouraged credit unions from providing troubled debt restructuring (TDR). Also, credit unions have told us that a number of examiners were showing little flexibility in working with credit unions or may have even dissuaded credit unions from making TDRs or loan modifications for their members – even if the credit union is well prepared for the changes and fulfills all regulatory and accounting requirements.

This proposal has the potential to ensure consistent guidance from the agency to its examiners – and help credit unions help their members in this time of need. CUNA will give the proposal careful consideration and urges the agency to move forward to address TDRs and loan modifications as soon as possible after the 30 day comment period closes.