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FEDERAL RESERVE BANK
OF NEW YORK

<s\'\oisq
January 6, 1995

FINANCIAL ACCOUNTING STANDARDS
—
Accounting by Creditors for Impairment of a Loan (FAS 114)
—
Accounting for Income Taxes (FAS 109)

To All Depository Institutions in the Second
Federal Reserve District:

Printed on the following pages is the text of a statement issued by the Federal Financial
Institutions Examination Council (FFIEC) through its Task Force on Supervision dealing with (1) the
reporting of allowances for loan losses (FASB Statement No. 114), and (2) the amount of deferred tax
assets that can be used to meet capital requirements (FASB Statement No. 109). Concerning the latter,
the Board of Governors of the Federal Reserve System has issued final amendments to its capital
adequacy guidelines for State member banks and bank holding companies to establish limitations, as
recommended by the FFIEC, on the amount of certain deferred tax assets that may be included in
Tier 1 capital; those amendments will be mailed to you shortly.
Questions regarding either of these matters may be directed to Stephanie Martin, Senior
Financial Specialist, Bank Analysis Department (Tel. No. 212-720-1418).




Christine M. Cumming,
Senior Vice President.

Federal Financial Institutions Examination Council

2100 Pennsylvania Avenue, NW, Suite 200 • Washington, DC 20037 • (202) 634-6526 • FAX (202) 634-6556

Press Release

The Task Force on Supervision of the Federal Financial
Institutions

Examination

Council

(FFIEC)1

announced

today

its

decision regarding the regulatory reporting treatment of allowances
established

under

Statement No.

114,

Financial

Accounting

Standards

Board

(FASB)

"Accounting by Creditors for Impairment of a

Loan” (FAS 114), and its recommendation to the agencies pertaining
to regulatory capital issues arising from FASB Statement No. 109,
"Accounting for Income Taxes" (FAS 109).

The Task Force's actions

were taken under delegated authority.
FAS 114
The

Task

Force

on

Supervision

has

decided

that

the

portion of an institution's allowance established pursuant to FAS
114 should be reported as part of the general allowance, which is

1 The FFIEC consists of representatives from the Board of
Governors of the Federal Reserve System (FRB), the Federal Deposit
Insurance Corporation (FDIC), the Office of the Comptroller of the
Currency (OCC), the Office of Thrift Supervision (OTS) (referred to
as the "agencies”) , and the National Credit Union Administration.
The Task Force on Supervision is comprised of staff members from
each of the agencies. The actions discussed in this press release
are not directed to credit unions.
Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration,
Office of the Comptroller of the Currency, Office of Thrift Supervision



2

includable in Tier 2 capital subject to a limit of 1.25 percent of
gross

risk-weighted

allowance
amounts

assets.

is general

identified

as

In

in nature,
losses

concluding
the Task

(i.e.,

loss

that

Force

the

114

that

notes

FAS

all

classifications)

are

excluded from the general allowance.
The Task Force has also reaffirmed existing supervisory
policies

that

require

banks

to

promptly

charge-off

identified

losses and require savings associations to promptly charge-off or
use specific allowances (which are reported separately from general
allowances)

for

identified

losses.

With

respect

to

impaired

collateral-dependent loans, the agencies generally classify as loss
any portion of the loan balance that exceeds the amount that is
adequately secured by the fair value of the collateral; such losses
on collateral-dependent loans will not be included in the general
allowance or Tier 2 capital.

Also,

as previously announced,

the

FFIEC has decided to maintain its existing regulatory nonaccrual
policies for problem loans.
FAS 109
The Task

Force

on Supervision

is recommending

to the

agencies that they finalize their proposed amendments to regulatory
capital

standards

to

limit

reported pursuant to FAS
requirements.
that,

to the

the

amount

109 that

of

deferred

can be used

As previously proposed,
extent the realization

tax

to meet

assets
capital

the Task Force recommends
of deferred

tax

assets

is

dependent on an institution's future taxable income, such deferred
tax assets be limited for regulatory capital purposes to the amount




3
that the

institution expects to realize within one year of the

quarter-end

report

whichever is less.

date,

or

ten

percent

of

Tier

1

capital,

Under the Task Force's recommendation, deferred

tax assets that can be realized from taxes paid in prior carryback
years

and

from

future

reversals

of

existing

differences would generally not be limited.




taxable

temporary