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Jan. 27, 2012
Great analysis as aways. Thanks Mike!
Couple of questions:
Is NCUA creating a departure from GAAP on consumer loans determined to be TDR? If so, this would add to the Pooling vs. Purchase departure and another step toward RAP (Regulatory Accounting Principles) vs GAAP like we had in the 1980's.
How will this impact acquiring loan portfolios in an acquisition? Impaired loans treatment for MBL's only or all loans of a troubled CU in an acquisition?
I heard NCUA finalized this yesterday but haven't been able to locate a published version of the final rule.
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