# ASC 310-40-S99: Receivables — Troubled Debt Restructurings by Creditors — SEC 99 SEC Materials

Source: FASB Accounting Standards Codification, Basic View

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## ASC 310-40-S99: SEC 99 SEC Materials

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#### SEC Staff Guidance

##### [310-40-S99-1](https://asc.understandingaccounting.org/asc/310/40/#310-40-S99-1)

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The following is the text of SEC Observer Comment: Applicability of the Disclosures Required by Topic 310 when a Loan is Restructured in a Troubled Debt Restructuring into Two (or More) Loans.

-   Paragraph [310-40-50-5](https://asc.understandingaccounting.org/asc/310/40/#310-40-50-5) states that when a loan is restructured in a troubled debt restructuring into two (or more) loan agreements, the restructured loans should be considered separately when assessing the applicability of the disclosures in paragraphs [310-10-50-15(a) and (c)](https://asc.understandingaccounting.org/asc/310/10/#310-10-50-15) in years after the restructuring because they are legally distinct from the original loan. The creditor would continue to base its measure of loan impairment on the contractual terms specified by the original loan agreement in accordance with paragraphs
    
    [310-10-35-20 through 35-30](https://asc.understandingaccounting.org/asc/310/10/#310-10-35-20)
    
    . The SEC staff is concerned that disclosures of impaired loans after loans are restructured in troubled debt restructurings into multiple loan structures might, in some circumstances, imply that the quality of the loan portfolio had improved solely as a result of the troubled debt restructurings. Accordingly, the SEC staff believes that registrants should make clear to the users of the financial statements the impact of the multiple loan structures on the impaired loan disclosures.