Accounting rules for debt prepayment fees with COVID-19 crisis

In the wake of the financial impacts of COVID-19 and several interest rate cuts by the Federal Reserve, many financial institutions are working to reassess their balance sheet.

With the rapidly changing interest rate environment, some financial institutions have considered the possibility of prepaying or modifying outstanding borrowings (such as Federal Home Loan Bank advances). This has raised questions about proper accounting for prepayment penalties related to early extinguishment or modification of outstanding debt.

ASC 470-50 governs the accounting for exchanges and modification of debt in nontroubled debt restructurings. The guidance distinguishes between debt extinguishment and debt modifications.

If the early repayment of debt is considered a debt extinguishment, then the entire prepayment penalty should be expensed when incurred. However, if the early debt repayment qualifies as a debt modification, the prepayment penalty is to be amortized as a yield adjustment over the life of the remaining debt.

To qualify as a debt modification, the prepaid debt must be replaced with new debt from the same issuer that cannot be “substantially different.” The accounting standards define a debt instrument to be “substantially different” if the present value of cash flows under the new debt terms is at least 10 percent different from the present value of the remaining cash flows under the original debt.

Some lenders, such as the Federal Home Loan Bank, have designed programs to simplify the accounting for debt prepayments. In some instances, these lenders are offering to modify the debt by adjusting the yield of the replacement loan to account for the impact of the prepayment penalty.

In these arrangements, no prepayment penalty is paid up front, but instead the yield of the replacement debt is increased over the standard market rate over its duration. By eliminating the prepayment penalty, no expense is recognized upfront regardless of whether the restructure meets the definition of a modification.

If you have more complicated debt arrangements, such as convertible debt, a more thorough analysis of the debt restructuring would be necessary.

In summary, situations where debt is paid off early, without being replaced with new debt, will not qualify as a modification, and any prepayment penalty would need to be expensed upfront. Situations where the debt is being replaced by new debt will need to be analyzed more carefully to compare the present value of cash-flows to determine if the new borrowing is substantially different.

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