When a commercial property loan can no longer be repaid on its terms, the lender has several ways out: give the borrower more time, rewrite the loan, sell it to an investor, take the building by agreement, or foreclose. Each way returns a different amount of money, at a different time, with a different chance of going wrong. Workout analysis puts every one of them on the same assumptions and turns each into one number, what it is worth today, so a loan committee can compare them fairly.
This guide is for anyone who works, reviews or decides troubled commercial real estate loans: special assets officers and workout analysts, chief credit officers and loan committee members, credit risk review, finance teams who book the charge-offs, and the leaders deciding whether to automate the work. No background needed.
Imagine you are the special assets officer at Corvane Bank, a community bank in central Ohio. It is Monday, October 12, 2026. Your largest problem loan is Halvorsen Crossing: two suburban office buildings in Dublin, Ohio, 142,600 square feet, with $18.4 million still owed. The anchor tenant left on March 31 and occupancy fell from 91% to 62%. The loan matured on August 31; the bank gave a 60-day accommodation that ends October 30. Loan committee meets Thursday.
A new appraisal says the buildings are worth $13.2 million today. The owner, who guaranteed the loan personally, offers to pay down $750,000 if the bank extends for two years at 6.25%, interest only. Meanwhile three investors have bid for the loan itself. The best bid, page 1 of the adviser's summary, is $12,650,000.
Owner's offer · Sep 28
Paydown
$750,000
Extension
2 years, 6.25%
If it works
Full payoff, 2028
Chance it works
15 in 100
Worth today, at 9%
$11.38M
Best note bid · Oct 2
Price
$12.65M cash
Less costs
$186,500
Cash arrives
In 45 days
Chance it fails
5 in 100
Worth today, at 9%
$12.29M
Extend: $11.38M todaySell the note: $12.29M todaya difference of $0.90M on the same numbers.
On paper the extension looks generous: it could repay the whole loan. But the building earns $1.18 million a year against $1.10 million of interest, coverage of 1.07 times, and at today's value a full refinance in two years is unlikely; you put the chance at 15%.
You value all four paths on one set of assumptions (value falling 4% a year, a 9.0% discount rate, 20 months to foreclose and sell in Ohio) and they come out: sell the note $12.29M, restructure into two notes $11.70M, extend $11.38M, foreclose $11.11M. Selling means a $5.94 million charge-off now; it also ends the bank's exposure in 45 days.
That is what workout analysis catches: the offer that could repay the whole loan is worth $0.90 million less today than the best bid, once its 85-in-100 chance of ending in foreclosure is counted, and the memo can say what would have to change for the extension to win.
Valuing the ways out of a troubled commercial real estate loan: paths, rules, recoveries and time
The paths a lender can take, the rules that shape them, the arithmetic of net present recovery, the discount rate, what published data say about losses by path, how long foreclosure takes, what a guarantor adds and how each path is booked. Vendor-neutral. If you are new to problem loans, start here.
01 · In plain words
Loan workout analysis in plain words: five ways out of a troubled property loan, each priced at today's value
A commercial real estate loan is repaid from the property: the rent pays the interest, and at maturity a sale or a new loan pays off the balance. When the rent falls or the value falls, both can fail at once. The borrower cannot pay on time, and no other lender will refinance the loan for the full amount. The loan moves to a bank's special assets team, whose job is to get back as much of the money as possible.
That team has a short list of ways out. It can give the borrower more time. It can rewrite the loan, often splitting it into a part the property can carry and a part written off. It can sell the loan to an investor for less than the balance. It can accept the building from the borrower in place of a foreclosure, called a deed-in-lieu. Or it can foreclose, through the courts in some states, and sell the building later. A borrower may also file for bankruptcy, which pauses everything.
Each path returns money on a different schedule. A rewritten loan might pay $16 million over five years; a loan sale might pay $12.5 million in six weeks. Money in five years is worth less than money now, and a promise to pay can be broken. So the analyst turns each path into one figure, its net present recovery: the cash the bank expects, after costs, weighted by the chance each outcome happens, discounted back to today.
The comparison only works if every path uses the same facts: the same property value, the same rate of decline, the same discount rate, the same time to foreclose. Bank regulators expect the analysis behind a workout to rest on current values, realistic cash flow and a real look at the guarantors.1 They also say a bank that works out a loan prudently will not be criticized for it, even when the loan stays classified.1
From a missed refinance to a booked charge-off: where valuing the paths fits
The loan stops workingHalvorsen Crossing's anchor tenant leaves; income drops by half; the loan matures without a refinance.
The file is brought up to dateTwelve months of operating figures, the rent roll, a new appraisal, the guarantor's statement, bids from investors.
Every path is valued on one set of numbersExtend, restructure, sell the note, foreclose, and a deed-in-lieu if asked. This is the step this guide is about.
The committee choosesThe special assets officer recommends; the chief credit officer signs the rating and charge-off; the committee approves the path.
The path is carried out and bookedDocuments, a sale or a court filing; the charge-off, any modification disclosure, and foreclosed property if the bank takes title.
Step 3 is the subject of this guide. The bank, property, people and figures in the example are fictional.
Where intuition about workout paths goes wrong
The biggest cash total often loses
In the example, the restructure would collect $16.35 million before time value and the note sale $12.46 million. Discounted and weighted for the chance the restructured loan defaults again, the sale is worth $0.58 million more today.
Time is the largest cost
At failed banks, commercial real estate loans worked out within six months lost 17% on average; loans that took more than three years lost 70%.2
A modification often fails
In the same FDIC data, 35% of modified commercial real estate loans were later foreclosed, and those lost 66% against 48% for modifications that held.2
A classified loan can be a good workout
The 2023 interagency statement says examiners will not criticize a prudent workout done after a comprehensive review, even if the restructured loan is adversely classified.1
Net present recovery, discount rate, break-even and A/B note: the four terms this guide leans on
Net present recovery
What a path is worth today: expected cash in, less costs, each amount weighted by its chance and discounted to now.
Discount rate
The yearly rate used to turn future dollars into today's dollars. Higher rates favor paths that pay sooner.
Break-even
The value of one assumption at which a rival path would overtake the leader: a property value, a rate, a chance.
A/B note
A restructure that splits a loan into Note A, sized to what the property can repay, and Note B, which is charged off.
Extend, restructure, sell the note, take the deed or foreclose: what each workout path returns and when
In shortEvery path trades speed against amount and certainty. Extensions and restructures keep the borrower and collect more on paper, slowly, with a real chance of failing. A note sale or a discounted payoff turns the loan into cash within weeks at a price. A deed-in-lieu or a foreclosure gives the bank the building, after months of cost, and a sale later at whatever the market pays then.
Path
What happens
Where the cash comes from
What can go wrong
Short-term accommodation or forbearance
The bank defers payments, accepts partial payments or holds off on remedies for a set period.1
The property, later
Buys time without a plan; the problem returns larger
Extension
A new maturity, often with a paydown, a cash sweep or interest only
Interest now, a refinance or sale at the new maturity
No refinance at the new date; value keeps falling
Modification or A/B restructure
New terms the property can carry; with an A/B split, Note B is charged off1
Note A payments and repayment; sometimes part of Note B
The borrower defaults again and the loan ends in foreclosure
Discounted payoff
The borrower or a new lender pays an agreed amount below the balance
The borrower's new money, in weeks
The borrower cannot raise it; other borrowers ask for the same
Note sale
The bank sells the loan, usually all cash, to an investor
The buyer, at closing
The price; the buyer walks during diligence
Deed-in-lieu
The borrower deeds the property to the bank, often for a release of part of the guaranty
Rent while the bank owns it, then a sale
Junior liens stay on title; the borrower must agree3
Foreclosure
A court case or a sale under the mortgage's power of sale, often with a receiver collecting rent4
Rent through the receiver, a sale after title, any deficiency from guarantors
Time, legal cost, falling value, a bankruptcy filing
Borrower's bankruptcy
An automatic stay stops collection; for a single property, the borrower has 90 days to file a plausible plan or start paying interest5
A court-approved plan, or the property after stay relief
Months of delay; a plan that pays a court-set rate
No path is fast, certain, cheap and client-keeping at once
How each path tends to score on four things a committee weighs
LowMediumHigh
Speed to cashCertainty of amountLow cost to the bankKeeps the clientExtensionLowLowHighHighA/B restructureLowMediumHighHighDiscounted payoffHighMediumHighLowNote saleHighHighHighLowDeed-in-lieuMediumMediumMediumLowForeclosureLowMediumLowLow
Our reading of the sources1,2,4,5,3 · Our reading of the sources for a typical stabilized-income property; a single case can differ. Speed and certainty for a foreclosure depend heavily on the state.
Show the numbers
Speed to cash
Certainty of amount
Low cost to the bank
Keeps the client
Extension
Low
Low
High
High
A/B restructure
Low
Medium
High
High
Discounted payoff
High
Medium
High
Low
Note sale
High
High
High
Low
Deed-in-lieu
Medium
Medium
Medium
Low
Foreclosure
Low
Medium
Low
Low
Paths often run into one another. Most workouts start with a short accommodation while the file is updated. A failed extension becomes a foreclosure. A foreclosure filing often brings a discounted payoff offer, and a deed-in-lieu is often negotiated in the shadow of a foreclosure case. Good analysis values each path including its failure branch: the extension that fails is valued as an extension for some months and a foreclosure afterwards.
Why the cash total misleads. Halvorsen Crossing's four paths would collect, before any discounting, $16.35 million (restructure), $14.55 million (extension), $12.83 million (foreclosure) and $12.46 million (note sale). Ranked by what they are worth today, the order is almost reversed: note sale, restructure, extension, foreclosure. The longer a path waits for its cash and the more likely it is to fail, the more it loses in the conversion.
03 · The rules and their dates
Which rules shape a workout comparison in October 2026, and which choices they leave to credit policy
Status as of October 2026
In shortNo rule tells a bank how to compare workout paths. The 2023 interagency statement sets what the analysis must look at and how examiners grade the result. Accounting standards decide what is charged off and disclosed. The 2026 model guidance decides whether the spreadsheet or software behind the comparison is a model. Everything else, including the discount rate, is the bank's own credit policy.
The texts behind a 2026 workout memo date from 2001 to April 2026
May 10, 2001Loans held for sale guidance
SR 01-12: a loan moved to held for sale is written down to fair value, with a charge to the allowance.
Mar 2022ASU 2022-02
FASB ends troubled debt restructuring accounting for banks on CECL and requires disclosure of modifications to borrowers in financial difficulty.
Jan 1, 2023ASU 2022-02 in force
For calendar-year banks that had adopted CECL; fiscal years beginning after December 15, 2022.
Apr 2023Allowance policy statement revised
TDR references removed; collateral-dependent loans measured on collateral value.
Jun 29, 2023CRE workout statement issued
OCC, Fed, FDIC and NCUA replace the 2009 statement; adds short-term accommodations and new examples.
Apr 17, 2026SR 26-2 replaces SR 11-7
New model risk guidance; spreadsheet arithmetic and fixed rules are outside the definition of a model.
Interagency statement on CRE accommodations and workouts
A plan built on "updated and comprehensive financial information on the borrower, real estate project, and all guarantors and sponsors", "current valuations of the collateral", and global debt service coverage "including realistic projections of the borrower's cash flow"; an analysis of the guarantors' available cash flow; a risk rating that reflects the workout; and an allowance that "recognizes loan losses in a timely manner".1
July 6, 2023; in force; supersedes 2009; the Fed applies it to every bank it supervises, including those of $10 billion or less8,11
ASU 2022-02
No separate troubled debt restructuring measurement; disclose modifications to borrowers in financial difficulty that are principal forgiveness, a rate reduction, an other-than-insignificant payment delay or a term extension.7
Fiscal years beginning after December 15, 2022, for banks on CECL
Allowance policy statement (revised April 2023)
Uncollectible amounts "should be promptly written off"; a collateral-dependent loan is measured on the fair value of collateral "regardless of whether foreclosure is probable", less costs to sell when repayment depends on a sale.9
In force
SR 01-12, loans held for sale
"A write-down of the loan to fair value upon transfer" to held for sale, with a charge to the allowance; later declines through a separate valuation allowance.6
May 10, 2001
OREO holding rules
A national bank disposes of foreclosed real estate "at the earliest time that prudent judgment dictates", within the five years the statute allows, which the OCC can extend by up to five more; a federal savings association may hold it up to five years, with up to five more on request.12,13
In force
Appraisal rules, 12 CFR 34.43
An existing loan can be renewed or restructured without a new appraisal when no new money is advanced beyond closing costs, or when no obvious and material change in the market or the property threatens the collateral; it still needs an evaluation. The FDIC's examination manual adds that when a workout modifies the terms, "a reappraisal or reevaluation may be prudent".14,15
In force; the commercial appraisal threshold is $500,000
SR 26-2 / OCC 2026-13 / FDIC FIL-15-2026
Model risk guidance that excludes simple spreadsheet arithmetic and deterministic rules from the definition of a model and leaves generative AI, and AI that acts on its own, to the bank's own governance.10
April 17, 2026
What the 2023 statement says about guarantors
The statement says a bank with enough information on a guarantor's "global financial condition, income, liquidity, cash flow, contingent liabilities" is better able to judge whether the guarantor can pay, including whether the guarantor can honor "the total number and amount of guarantees currently extended". Examiners consider whether the guarantor "has demonstrated the willingness to fulfill all current and previous obligations", and whether earlier payments under a guaranty were "voluntary or the result of legal or other actions".1 Section 10 turns that into numbers.
What the statement leaves to you. The method is yours: net present value, the discount rate and the way paths are compared are policy choices the statement leaves to each bank. Write them down, apply them to every loan, and show credit risk review how they changed.
04 · How examiners grade a path
How examiners grade an office loan workout: renewal, interest-only relief and an A/B split in the agencies' own examples
In shortThe 2023 statement's office example shows the terms of a workout matter as much as the numbers. Renewed at a market rate with coverage of 1.12 times, the loan is a pass. Renewed on a value the lender estimated without a new appraisal, it drops to special mention. Given a year of interest only at a below-market rate, it is substandard and goes on nonaccrual, though coverage is almost the same.
Example A in the statement is a $15 million office loan with a $13.6 million balloon due in year five. At origination the building was appraised at $20 million, a 75% loan-to-value, with coverage of 1.30 times. Hybrid work has forced rent concessions. The examples then change one thing at a time.1
Below-market interest-only terms push the office loan to substandard at almost the same coverage
Example A in the 2023 interagency statement: coverage, value used, grade and accrual under each scenario
WeakAdequateGood
CoverageValue usedExaminer's gradeAccrual1 · Renewed 1 year at market, 15-year amortizationAdequateGoodGoodGood2 · Renewed at market, lender's own estimate of valueAdequateWeakAdequateGood3 · 12 months interest only, below-market rateAdequateGoodWeakWeak
Source1 · Coverage 1.12x, 1.12x and 1.10x; values $13.3M as stabilized, $14.5M estimated with no new valuation, $14.5M appraised. Grades: pass, special mention, substandard. Accrual kept in 1 and 2; nonaccrual in 3. Shading is our summary of the statement's outcomes.
Show the numbers
Coverage
Value used
Examiner's grade
Accrual
1 · Renewed 1 year at market, 15-year amortization
Adequate
Good
Good
Good
2 · Renewed at market, lender's own estimate of value
Adequate
Weak
Adequate
Good
3 · 12 months interest only, below-market rate
Adequate
Good
Weak
Weak
Scenario
Terms and figures
Examiner's outcome
Example A, 1
$13.6M renewed for one year at a market rate, amortizing over 15 years; coverage 1.12x; value $13.3M; LTV 102%
Note A pass and back on accrual; Note B charged off1
The grades come from the examiners' classification scale. Special mention marks "potential weaknesses that deserve management's close attention" and is not an adverse classification. Substandard means the loan is inadequately protected by the borrower's paying capacity or the collateral, with a well-defined weakness. Loss means "uncollectible and of such little value" that it should be written off.15
Two lessons carry into any comparison. First, an extension on soft terms does not make the loss go away. In the retail example, the lender gave a year of interest only at a below-market rate, and the builder who guaranteed the loan could not cover any shortfall; the examiner classified the $1 million above the mall's "as is" value as loss, required it charged off, and put the rest on nonaccrual.1 In the example at the top, the owner's offer of 6.25% interest only would cover interest 1.07 times, from a guarantor with little cash to spare.
Second, an A/B split is the agencies' own pattern for a restructure that can return part of a loan to pass: size Note A to what the property can carry on market terms, and charge off the rest.1
The statement's owner-occupied example, Example G, is about a business line and its real estate; it is covered in the companion guide on problem loan management.
05 · Net present recovery
Net present recovery worked through: cash flows, costs and timing for four paths on one office loan
In shortFor each path, list every dollar in and out by month: payments, sale proceeds, rent collected by a receiver, legal and broker costs, fees. Weight each amount by the chance its branch happens. Discount each month's amount to today. Add up. On Halvorsen Crossing, at a 9.0% rate, the four paths land between $11.11 million and $12.29 million on an $18.4 million balance.
Net present recovery = Σ over months m of [ chance of the branch × cash in month m ÷ (1 + discount rate)m/12 ]
In words: take each month's cash, multiply it by the chance that it arrives, divide it by the discount for the wait, and add up all the months. The discount grows with time. At 9% a year, $1 due in 24 months is worth $1 ÷ 1.09 ÷ 1.09 = about $0.84 today, and $1 due in 60 months about $0.65.
Halvorsen Crossing's shared assumptions
Value as is $13.2 million from the new appraisal, falling 4% a year. Discount rate 9.0%, the bank's required return on troubled assets. Foreclosing and selling in Ohio takes 20 months. Sale costs 4.5% of the price; a receiver costs $9,000 a month; foreclosure counsel and court $420,000. Best bid $12.65 million. Net operating income $1.18 million today, rising to $1.72 million as space leases up over 30 months. Every path uses all of them.
Selling the note is worth $0.58 million more today than the next best path
Net present recovery on Halvorsen Crossing's $18.4M balance, one set of assumptions, 9.0% discount rate
Sell the note to the best bidder66.8% of balance · 45 days$12.3M
Restructure into Note A $12.4M and Note B $6.0M63.6% · 60 months$11.7M
Extend 24 months with a $750,000 paydown61.9% · 24 months$11.4M
Deed-in-lieu, then sell61.8% · 12 months$11.4M
Foreclose through the court and sell60.4% · 20 months$11.1M
Fictional example from this guide
Show the numbers
Path
Net present recovery
Sell the note to the best bidder
$12.3M
Restructure into Note A $12.4M and Note B $6.0M
$11.7M
Extend 24 months with a $750,000 paydown
$11.4M
Deed-in-lieu, then sell
$11.4M
Foreclose through the court and sell
$11.1M
The cash flows behind each path's figure
Path
Cash flows
Branches and chances
Note sale
$12,650,000 price at month 2, less a 1% adviser fee ($126,500) and $60,000 counsel and closing: $12,463,500
One branch; if the buyer walks, the next bid stands
Restructure
Note A $12.4M at 6.50%, 25-year amortization: $83,726 a month for 60 months, then $11.23M repaid; 20% of Note B recovered at month 60
72% performs; 28% pays 18 months, then foreclosure starts
Extension
$750,000 paydown now; interest at 6.25% on $17.65M, $91,927 a month; a refinance pays off $17.65M at month 24
15% refinances; 85% pays 10 months, then foreclosure starts at month 24
Foreclosure
Receiver collects 55% of monthly operating income less $9,000; $420,000 of legal cost at month 3; the property sold at month 20 at the trended value, less 4.5%; $400,000 from the guarantor at month 30
One branch; the risk is time and value
Three paths worked step by step
The same four steps produce every figure. Here they are for the note sale, the extension and the restructure, rounded to the nearest $10,000 after the first column.
Step
Sell the note
Extend 24 months
Restructure into Notes A and B
1. List what could happen
One outcome: the sale closes in month 2
The owner refinances (15 in 100), or pays 10 months and the bank forecloses (85 in 100)
Note A performs (72 in 100), or the borrower pays 18 months and the bank forecloses (28 in 100)
The $750,000 paydown now, in every outcome. Refinances: $2.21M of interest over 24 months + $17.65M payoff in month 24 = $19.86M. Fails: $0.92M of interest, then a foreclosure from month 24 that collects rent through a receiver and sells the building in month 44, $11.82M after costs = $12.74M
Performs: 60 payments of $83,726 ($5.02M) + Note A repaid, $11.23M + 20% of Note B, $1.20M, all in month 60 = $17.45M. Fails: 18 payments ($1.51M), then a foreclosure from month 18 that sells in month 38, $12.00M after costs = $13.51M
3. Turn each outcome into today's dollars at 9%
Two months' wait: $12,463,500 × 0.98574 = $12,285,767
Refinances: $19.86M is worth $16.87M today. Fails: $12.74M is worth $9.53M today
Performs: $17.45M is worth $12.15M today. Fails: $13.51M is worth $10.57M today
For comparison: chance-weighted cash before step 3
$12.46M
$14.55M
$16.35M
The order flips at step 3. The restructure collects the most cash, but most of it arrives in month 60, when each dollar is worth about 65 cents today, and 28 futures in 100 end in foreclosure. The sale's cash arrives in two months, so it loses less than 2 cents on the dollar to time.
Time and risk take $4.64 million off the restructure and $0.18 million off the sale
Expected cash before discounting against net present recovery, Halvorsen Crossing
Expected cash before time valueNet present recovery at 9.0%
Restructure$16.3M$11.7M
Extension$14.6M$11.4M
Foreclosure$12.8M$11.1M
Note sale$12.5M$12.3M
Fictional example from this guide
Show the numbers
Path
Expected cash before time value
Net present recovery at 9.0%
Restructure
$16.3M
$11.7M
Extension
$14.6M
$11.4M
Foreclosure
$12.8M
$11.1M
Note sale
$12.5M
$12.3M
Inside the foreclosure figure
Foreclosure is worth $11.11 million: the sale of the building after 20 months contributes $10.68 million at today's value, rent collected by the receiver $1.16 million and the guarantor's $400,000 another $0.32 million; legal cost takes $0.41 million, sale costs $0.48 million and the receiver's fee $0.17 million. The building is sold for $12.33 million in month 20, after value falls 4% a year from today's $13.2 million, so the falling market costs more than any single fee.
The figures come from the fictional example's model; the percentages of operating income a receiver collects and the chance of each branch are that bank's assumptions. Use your own.
06 · Chance of failure
Weighting each path by its chance of failing, and the break-even that flips the answer
In shortAn extension or a restructure has two futures: it works, or the borrower defaults again and the bank forecloses later on a lower value. Weight both futures by their chances. Then solve the break-even: the chance of success at which the path would overtake the leader. A committee can argue about a chance; it should see the number that would change its decision.
The extension refinances in 15 of 100 futures; the other 85 end in foreclosure two years later
15 in 100
Chance the owner refinances Halvorsen Crossing in full within 24 months, as the example bank judges it at a $13.2M value falling 4% a year
Fictional example from this guide
Show the numbers
Measure
Value
Chance the owner refinances Halvorsen Crossing in full within 24 months, as the example bank judges it at a $13.2M value falling 4% a year
15 of 100
A chance like 15% comes from the gap between the debt and what the property could borrow at the new maturity. The loan would still owe $17.65 million after the paydown. At a value falling 4% a year, the building would be worth about $12.2 million in two years; a new lender at a typical loan-to-value would lend far less than the balance. A full refinance needs the building to lease up and values to recover. The FDIC's data give a reference point for re-default: 35% of modified commercial real estate loans at failed banks were later foreclosed.2
The extension overtakes the note sale only if the chance of a full refinance passes 27%
Net present recovery against the chance of a full refinance within 24 months, Halvorsen Crossing, 9.0% discount rate
ExtensionNote sale
$10M$11M$12M$13M$14M$13.9M$12.3M
5%15%25%35%45%
Fictional example from this guide
Show the numbers
Refinance chance
Extension
Note sale
5%
$10.7M
$12.3M
10%
$11M
$12.3M
15%
$11.4M
$12.3M
20%
$11.8M
$12.3M
25%
$12.1M
$12.3M
30%
$12.5M
$12.3M
35%
$12.8M
$12.3M
40%
$13.2M
$12.3M
45%
$13.6M
$12.3M
50%
$13.9M
$12.3M
Halvorsen Crossing's four break-evens
Rival path
Overtakes the note sale if
Today
What it would take
Foreclosure
the value is above $14.73M
$13.2M
12% more than the appraisal, about $103 a square foot for a building 62% leased
Restructure
the discount rate is below 7.6%
9.0%
A lower required return on troubled assets
Extension
the chance of a full refinance is above 27%
15%
Signed leases, or evidence values have stopped falling
Note sale stays first
the best bid stays above $12.05M
$12.65M
The lead holds unless the bid falls about 5%
Each break-even is found the same way: move one assumption, re-value every path, and stop where the rival's figure equals the leader's. For the extension, each extra 5 points of refinance chance adds about $0.37 million, so its line crosses the sale's $12.29 million at a 27% chance, as the chart above shows.
Break-evens turn an argument into a question with an answer. "Is there a version where we keep the client?" becomes "Do we believe a 27% chance of a refinance, against our 15%?" A recommendation that names its break-evens is easier to challenge and easier to defend in front of an examiner.
07 · The discount rate
Choosing the discount rate for a workout comparison, and how far it moves the ranking
In shortThe discount rate decides how much a slow path is penalized. Banks use one of three: the loan's own interest rate, a market rate that reflects the risk of the cash flows, or the bank's required return on troubled assets. Research shows the choice changes measured losses by several points. Pick one in policy, use it for every path, and show how the answer moves if it changes.
Option 1
The loan's own rate
Simple and common in research: the FDIC's study of failed-bank losses discounted at each loan's rate.2 It is often too low for risky cash flows, which flatters slow paths.
Option 2
A market rate for the risk
Bank capital guidance for advanced loss models requires discounting at a market rate; some argue the loan rate is too low in bad times.2 Discounting at the higher of 15% or the loan rate raised measured losses by 3 to 5 points.2
Option 3
The bank's required return
A rate set in credit policy for troubled assets, the same across loans. Easy to apply and to audit; it should be reviewed when market rates move.
Below a 7.6% discount rate the restructure beats the note sale; above it the sale leads
Net present recovery at discount rates from 6% to 12%, Halvorsen Crossing
RestructureNote saleExtension
$10M$11M$12M$13M$14M$10.6M$12.2M$10.6M
6%7%8%9%10%11%12%
Fictional example from this guide
Show the numbers
Discount rate
Restructure
Note sale
Extension
6%
$13M
$12.3M
$12.3M
7%
$12.6M
$12.3M
$12M
8%
$12.1M
$12.3M
$11.7M
9%
$11.7M
$12.3M
$11.4M
10%
$11.3M
$12.3M
$11.1M
11%
$10.9M
$12.2M
$10.8M
12%
$10.6M
$12.2M
$10.6M
The sale barely moves because its cash arrives in two months. The restructure moves most because most of its cash arrives in year five. That is the general rule: the longer a path waits, the more the rate matters.
Market reference points, October 2026
Rates
Bank prime loan rate: 7.00% on October 27, 2026.16
Five-year Treasury yield: averaged 4.94% in October 2026 to the 29th.17
In bankruptcy
A court that rewrites a secured loan over the lender's objection sets an interest rate. In Till v. SCS Credit Corp. (2004), the plurality started from the prime rate and noted that courts "have generally approved adjustments of 1% to 3%".18 Chapter 11 courts differ on how far they follow it.
The example bank's 9.0% is its own policy figure. A rate below the loan's own coupon would make a long path look better than holding the loan as written, which is a sign the rate is too low.
08 · Losses by path
What FDIC and Moody's data show about loss given default by workout path, collateral and time
In shortThe largest public study of bank commercial loan losses, from the FDIC, covers more than 50,000 defaulted loans at banks that failed from 2008 to 2013. On those loans, losses rose with every extra six months of workout, foreclosed loans lost 14 points more than those resolved without foreclosure, and modifications that later failed lost almost as much as foreclosures. Moody's figures for securitized loans show office losses above 70% in 2022.
Loss given default, or LGD, is the share of the balance at default a lender does not get back, counting lost interest and costs, discounted to the default date. Shibut and Singer's FDIC study measured it on loans at failed banks that the FDIC sold with loss-sharing agreements, so the acquiring banks reported every charge-off, recovery and expense.2 The banks were small and the period was a crisis, so treat the levels as stressed; the differences between paths are the useful part.
Construction loans lost the most at failed banks; other commercial real estate the least
Mean loss given default by loan type, FDIC loss-share data, banks failed 2008–2013
Securitized loans are larger and are worked out by special servicers under pooling agreements, and loans that reach liquidation are the hardest cases, so severities run higher than bank averages. The FDIC paper cites Fitch's 53% for CMBS defaults in 2010.2 Special servicers also charge for the work: a CMBS special servicer "typically earns a management fee of 25 to 50 basis points on the outstanding principal balance of a loan in default", plus 75 basis points to 1% of the net recovery, according to the Congressional Oversight Panel's 2010 report, which the FDIC study also quotes.20,2
What no one publishes. There is no public dataset of recoveries by workout path at healthy banks today, of note sale prices as a share of balance, or of what banks collect from guarantors. Your own resolved loans are the best evidence you have: pull the last five years, record the path, the time and the loss, and compare them with the paths you did not take.
09 · Foreclosure time by state
Judicial and nonjudicial foreclosure: what the state's process adds in months and losses
In shortSome states foreclose through the courts; others let the lender sell under a power of sale in the mortgage after notice. In the FDIC data, foreclosed commercial real estate loans in judicial states took 926 days to resolve against 757 elsewhere and lost 7 more points. Published state timelines cover homes only; for commercial property, the months to foreclose and sell are your own assumption, and they move the answer.
Court foreclosure added more than five months to foreclosed CRE loans at failed banks
Days from default to resolution, other commercial real estate loans that did not cure, by state foreclosure process
Nonjudicial statesJudicial states
Foreclosed757 days926 days
Not foreclosed441 days514 days
Source2 · Mean loss given default on the foreclosed loans: 62.4% in nonjudicial states, 69.7% in judicial states.
Show the numbers
Loans
Nonjudicial states
Judicial states
Foreclosed
757 days
926 days
Not foreclosed
441 days
514 days
Texas shows what nonjudicial means: a sale under a power of sale is a public auction "between 10 a.m. and 4 p.m. of the first Tuesday of a month", with notice "at least 21 days before the date of the sale".4 Judicial states require a lawsuit, a judgment and a court-ordered sale, and many give the borrower time to redeem. The FDIC authors also found banks foreclosed less often in judicial states, and that loans not foreclosed lost more there too, a sign borrowers use the slower process when they negotiate.2
The only published state timelines are for homes
Home foreclosures took 155 days in Texas and 2,007 in New York in the second quarter of 2026
Average days in the foreclosure process for homes foreclosed in Q2 2026
ATTOM's figures describe residential foreclosures, which carry consumer protections a commercial loan does not. They are still the clearest public evidence of how much state process varies.21 For a commercial loan, ask your foreclosure counsel in each state for a realistic time to title and add your own marketing time to sell.
Even a six-month foreclosure would not beat the bid on Halvorsen Crossing
Net present recovery of foreclosure by months to foreclose and sell, against the note sale's $12.29M
$12M6 months
$11.7M10 months
$11.3M16 months
$11.2M18 months
$11.1M20 (Ohio)
$10.9M24 months
Fictional example from this guide · The example bank's settings use 20 months for Ohio, 16 for Indiana, 18 for Kentucky and 10 for Michigan; these are its own assumptions.
Show the numbers
Months
Net present recovery
6 months
$12M
10 months
$11.7M
16 months
$11.3M
18 months
$11.2M
20 (Ohio)
$11.1M
24 months
$10.9M
Bankruptcy resets the clock
A borrower can stop a foreclosure by filing for bankruptcy. For a single-property borrower the Bankruptcy Code shortens the pause: unless, within 90 days of the order for relief, the borrower files a plan "that has a reasonable possibility of being confirmed within a reasonable time" or starts monthly payments of interest at the contract rate on the value of the lender's interest, the lender can ask the court to lift the stay. If the court rules later that the case is a single-asset case, the deadline moves to 30 days after that ruling.5
Add a bankruptcy branch to the foreclosure path when the borrower has the means and the motive to file.
10 · What a guarantor is worth
What a personal guaranty is worth in a workout: liquidity, contingent liabilities and willingness to pay
In shortA guarantor's net worth is the wrong starting point. Count what is liquid, subtract what the guarantor already owes and has guaranteed elsewhere, and judge whether the guarantor pays willingly or only when sued. Then decide how a guaranty enters each path: as a paydown in an extension, as a deficiency claim after foreclosure, or as a release traded for a deed. No public study measures what lenders collect on commercial guaranties, so this figure is a judgment you document.
An $11.6 million net worth turns into $400,000 the example bank expects to collect
Erik Halvorsen's statement, from net worth to the amount used in the foreclosure path
Net worth on his statement$11.6M
Real estate equity, at his own values$9.4M
Cash and marketable securities$1.9M
Liquid after the offered $750,000 paydown$1.1M
Deficiency the bank expects to collect, 30 months out$400K
Fictional example from this guide
Show the numbers
Step
Amount
Net worth on his statement
$11.6M
Real estate equity, at his own values
$9.4M
Cash and marketable securities
$1.9M
Liquid after the offered $750,000 paydown
$1.1M
Deficiency the bank expects to collect, 30 months out
$400K
The guarantor in the example reports $11.6 million of net worth, but $9.45 million of it is equity in seven buildings at his own values, and he has guaranteed $42.3 million of other loans, 3.6 times his net worth. One of those loans is already with a special servicer. His $750,000 offer is credible because it leaves $1.15 million liquid, about seven months of carrying costs on his other properties; a larger paydown would mean selling buildings he has not offered to sell.
What to collect
A recent signed personal financial statement and two years of tax returns.
A schedule of every contingent liability, with lenders and status, checked against a credit report.1
Global cash flow across the guarantor's properties.
History: did the guarantor pay earlier calls voluntarily, or after a lawsuit?1
How it enters each path
Extension or restructure: a paydown or reserve now, often the most certain value a guaranty yields.
Foreclosure: a deficiency claim after the sale, late, after legal cost, and limited by state law and by other creditors.
Deed-in-lieu: a partial release that gets the borrower's cooperation and saves months.
Note sale: the guaranty usually goes to the buyer with the loan.
Every guaranty competes for the same cash. The 2023 statement lists contingent liabilities among what a bank needs to know before relying on a guaranty.1 A guarantor with many guaranties is exposed to every one of those lenders at the same time, and the first to sue may collect first.
11 · Accounting by path
Charge-offs, held for sale, foreclosed property and modification disclosure: the accounting each path triggers
In shortOn a collateral-dependent loan like this one, every path recognizes the loss now; the paths differ in disclosure, accrual and who ends up owning the building. A note sale writes the loan down to fair value on transfer to held for sale. An A/B restructure charges off Note B. A below-market interest-only extension, with a guarantor who cannot cover shortfalls, leads examiners to charge off the balance above the property's "as is" value. Once the bank decides to foreclose or take a deed, the balance above fair value less costs to sell is classified loss. Extensions, rate cuts and forgiveness to a borrower in financial difficulty are disclosed under ASU 2022-02.
Every path books the loss now; they differ in disclosure, accrual and who owns the building
What each path triggers at the decision, for a collateral-dependent loan in financial difficulty
NoPartlyYes
Loss charged off nowModification disclosureStays on nonaccrualBank owns propertyExtension, below-market interest onlyYesYesYesNoA/B restructureYesYesPartlyNoNote saleYesNoNoNoDeed-in-lieuYesNoNoYesForeclosureYesNoYesYes
Our reading of the sources1,7,9,6 · Our reading of the 2023 statement and the allowance policy statement for the example loan. Partly: Note A may return to accrual after six months of payments. The extension row follows the statement's retail example (below-market interest only, a guarantor unable to support the loan). The allowance often already holds much of the loss, so the new provision is only the difference.
Show the numbers
Loss charged off now
Modification disclosure
Stays on nonaccrual
Bank owns property
Extension, below-market interest only
Yes
Yes
Yes
No
A/B restructure
Yes
Yes
Partly
No
Note sale
Yes
No
No
No
Deed-in-lieu
Yes
No
No
Yes
Foreclosure
Yes
No
Yes
Yes
Path
What the bank books
Halvorsen Crossing, $4.9M allowance
Note sale
Write-down to fair value on transfer to held for sale, charged to the allowance6
$18,400,000 − $12,463,500 net proceeds = $5,936,500 charge-off; provision $1,036,500 over the allowance
A/B restructure
Note B charged off; Note A rated on its own terms; modification disclosed1,7
$6,000,000 charge-off; Note A substandard; may return to accrual after six payments
Extension
Uncollectible amounts "promptly written off"; in the statement's retail example, a below-market interest-only renewal with a guarantor unable to help led the examiner to charge off the balance above the "as is" value, with no costs to sell because repayment did not depend on a sale; term extension and rate reduction disclosed1,7,9
$17,650,000 after the paydown − $13,200,000 = $4,450,000 charged off against the allowance; the rest substandard, nonaccrual. The product's screens show $0 here.
Foreclosure or deed-in-lieu
Once repayment depends on selling the property, the balance above fair value less costs to sell is classified loss and charged off; at transfer the property is booked as foreclosed real estate at its fair value less costs to sell then1,9,12
$18,400,000 − ($13,200,000 × 95.5%) = $5,794,000 at the decision; the product's screens book it at transfer
Let the economics pick the path, and use the accounting to show what each choice books. On this loan the charge-offs run from $4.45 million to $6.0 million whichever path is chosen, so an extension does not spare the bank a charge-off; it leaves a larger balance exposed to further decline. The committee still needs to see each path's entries, because disclosure, accrual and ownership differ. The FDIC reported $11.6 billion of modified commercial real estate loans at year-end 2025, 0.38% of the CRE-secured portfolio, 82% of it performing.22
12 · Common errors
Nine mistakes that make a workout comparison wrong, and the evidence that catches each
In shortMost bad workout decisions come from comparisons that were never fair: each path on its own assumptions, cash totals without discounting, no failure branch, an old value, a guarantor counted at net worth. The fixes are cheap: one assumption set, one discount rate, a failure branch on every hopeful path, a current value, and break-evens in the memo.
Different assumptions per path and a missing failure branch are both common and costly
How much it can move the answer →
Rare, costly
Common, costly
Rare, minor
Common, minor
Paths on different numbersNo failure branchUndiscounted totalsGuarantor at net worthCosts left outBankruptcy ignored
How often we see it →
Our reading of the sources1,2,23 · Our judgment from the sources and practice; place your own findings.
Show the numbers
Item
How often we see it (0–1)
How much it can move the answer (0–1)
Paths on different numbers
0.78
0.72
No failure branch
0.66
0.58
Undiscounted totals
0.12
0.68
Guarantor at net worth
0.12
0.26
Costs left out
0.78
0.26
Bankruptcy ignored
0.12
0.10
Mistake
Why it happens
The evidence that catches it
1. Each path on its own numbers
The extension uses the borrower's rent projection, the foreclosure the old appraisal, the sale the bid
One assumption set, versioned, shown at the top of the memo
2. No failure branch
Hope; the borrower's plan is the only plan modeled
A chance of failure on every extension and restructure; 35% of modified CRE loans at failed banks were later foreclosed2
3. Cash totals left undiscounted
Totals are easy to add in a spreadsheet
Every path discounted at the policy rate
4. A stale or estimated value
Ordering an appraisal takes weeks
A new appraisal or evaluation; Example A's lender estimate drew special mention1
5. The guarantor counted at net worth
The statement's bottom line is easy to quote
Liquidity, contingent liabilities and payment history1
6. Costs left out
Legal, receiver, broker, carry and servicing costs sit in other budgets
A cost list in policy, applied to every path; expenses and interest were nearly a quarter of measured CRE losses at failed banks2
7. Extend and pretend
An extension defers the charge-off and protects capital this quarter
Weakly capitalized banks extended more and built up near-term maturities, a New York Fed study found23
8. Soft terms graded as pass
Coverage on interest only looks fine
Example A, scenario 3: substandard and nonaccrual1
9. Modification as the default answer
It keeps the client
Fed researchers found bank modification policies associated with more delinquency on less-stressed loans, "consistent with modification policies encouraging strategic default"24
The Federal Reserve's May 2026 Financial Stability Report said lenders' willingness to extend or modify maturing loans "has helped to limit this risk to date", and that "this option may be increasingly limited going forward", a particular concern for securitized loans outside the government-sponsored programs (non-agency CMBS).25 An extension that would not survive a fair comparison only postpones the decision, usually on a lower value.
13 · The market in 2026
Distressed commercial real estate in 2026: maturities, special servicing and the shift toward foreclosure
In short$875 billion of commercial and multifamily mortgages fall due in 2026, $396 billion of them serviced by banks and other depositories. Office loans are the weakest: 17% of office CMBS balances were with special servicers in June 2026. Securitized workouts moved toward foreclosure in 2025, while note sales held a stable share. Banks held $11.6 billion of modified CRE loans at year-end 2025, 82% of it performing.
$875B
of commercial and multifamily mortgages mature in 2026, 17% of $5.0 trillion outstanding; $396 billion of loans serviced by depositories.26
MBA, February 9, 2026
17.11%
of office CMBS balances were in special servicing in June 2026; 11.20% across all property types.27
Trepp, via CRE Daily, July 15, 2026
$11.6B
of modified CRE loans at banks at year-end 2025, 0.38% of the CRE-secured portfolio; 82% performing.22
FDIC 2026 Risk Review
Scheduled maturities fall from $957 billion in 2025 to $652 billion in 2027
Commercial and multifamily mortgages scheduled to mature, by year (MBA surveys)
CRED iQ's founder wrote that higher rates, valuation pressure, refinancing problems and sponsor fatigue had reduced the chance of successful extensions, making foreclosure the main way losses were resolved.28 Securitized loans follow other rules: special servicers work under pooling and servicing agreements.20 After a default, banks extend the loans they hold significantly more often than securitized loans get extended,29 and Fed researchers found that banks' readiness to modify improves loan performance when property income falls.24 The FDIC reported CMBS delinquency at 7.30% in December 2025 and office CMBS at 11.31%, above the 2012 peak.22
14 · Software and AI
Software and AI in workout analysis: what SR 26-2 covers and what stays with the officer
Status as of October 2026
In shortSoftware can read the operating statement, rent roll, appraisal, guarantor statements and bids, value every path on one set of assumptions, solve break-evens and draft the memo with every figure cited. The April 2026 model guidance treats arithmetic on stated assumptions as outside the definition of a model and leaves generative AI to the bank's own governance. The officer still owns the chances, the recommendation and every conversation with the borrower.
Inside the model guidance
SR 26-2 defines a model as a complex quantitative method that applies statistical, economic or financial theories, and excludes "simple arithmetic calculations, such as those found within spreadsheets" and deterministic rule-based processes. Generative AI, and AI that acts on its own, are outside its scope; the bank's own risk management decides their controls.10 A probability-of-default or value-forecasting model feeding a workout comparison can be a model.
What examiners will read
The 2023 statement's list: updated financial information on the borrower, the property and every guarantor, current collateral value, global debt service coverage on realistic cash flow projections, the guarantors' available cash flow, an accurate risk rating and timely loss recognition.1 A tool earns its place if it makes each of those quicker to produce and easier to check against its document.
Judgments the special assets officer keeps
The chance a borrower refinances, a buyer closes, or a guarantor pays: judgments, written down and owned.
Every conversation with the borrower, the bidders and counsel.
The recommendation, the rating, the charge-off and the committee's vote.
Changing the policy: the discount rate, the cost list and the paths always compared.
15 · How teams do it today
Building a workout recommendation by hand: the officer, the analyst, the outside experts and a spreadsheet per loan
In shortA special assets officer owns the loan and the recommendation, an analyst builds the numbers, outside parties supply the appraisal, the bids and the legal timeline, and the chief credit officer and the committee decide. Most of the time goes into rebuilding the cash flows and writing the memo, usually in a fresh spreadsheet for each loan.
Five roles around one troubled loan
SA
Special assets officer
Owns the troubled loan, talks to the borrower and counsel, recommends the path.
Cares about: the most money back, with a plan the committee will approve.
WA
Workout analyst
Builds cash flows for each path, updates them when the appraisal, rent roll or a bid arrives, drafts the memo tables.
Cares about: not starting from a blank spreadsheet each time.
CC
Chief credit officer
Signs the rating and charge-off up to a limit, chairs the committee.
Cares about: what would change the recommendation.
LC
Loan committee and lending
Approves the path; the lending side asks whether the client can be kept.
Cares about: the relationship and the precedent.
RR
Credit risk review and finance
Test the rating, the allowance, the charge-off and the disclosure afterwards.
Cares about: which value, rate and timeline were used, and why.
From standstill to committee vote
A workout recommendation passes through five hands before the vote
Committee approves the path; rating and charge-off signed.
Chief credit officer, committee
One meeting
How the analyst's and officer's days split
Modeling the paths and writing the memo take more than half of a hand-built recommendation
Working days for one troubled CRE loan, from a complete file to a committee memo, by hand
Reading financials and rent rollValue, comparables and ratesGuarantor and sponsorModeling each pathMemo and term sheet
By hand, about 5.5 days110.51.51.5
Illustrative · replace with your own numbers · An estimate used in the solution's design; no public source measures it. Time three of your own.
Show the numbers
Reading financials and rent roll
Value, comparables and rates
Guarantor and sponsor
Modeling each path
Memo and term sheet
By hand, about 5.5 days
1
1
0.5
1.5
1.5
Spreadsheets, advisers or software: three ways banks staff the analysis
In house
A spreadsheet per loan
Flexible and familiar. The weak points: each path built separately, assumptions that drift between tabs, no link from a figure to its document, and a memo typed from the spreadsheet by hand.
Outside help
Advisers and counsel
Loan sale advisers run bid processes and price the note; workout consultants and counsel model foreclosure and bankruptcy. Useful for large or unusual loans; the bank still owns the decision and the documentation.
Software
Workout and special assets tools
Modules that track problem loans and document decisions, and newer tools that read documents and value the paths. They differ most on whether every path shares one assumption set and whether each figure links to its source.
Credit analysts, the occupation closest to workout analysts in federal wage data, earned a median of $83,510 in 2025, $40.15 an hour before benefits.30
Part B · See it working
Botminds Loan Workout Analysis on one $18.4 million office loan at a central Ohio bank
Part A described the work without naming a product. This part shows how Botminds does it, at a fictional community bank in central Ohio with twelve troubled loans and a committee on Thursday. Every bank, borrower, bidder, person and figure in the screens is sample data.
16 · One loan, start to finish
Halvorsen Crossing in the product: four paths valued, a note sale chosen and a $5.94 million charge-off signed
In shortThis is the example from the top of the page. Six agents read the file's 47 documents and value extension, restructure, note sale and foreclosure on one strip of shared assumptions. Dana Okafor, the special assets officer, sees the note sale lead by $0.58 million, checks what would change the answer, edits the drafted term sheet and memo, and sends them. On Thursday the committee approves the sale 4–0 and Ruth Castellano, the chief credit officer, signs the charge-off.
1
Twelve troubled loans, every one compared the same way
Monday morning Dana opens her workouts: twelve troubled loans, $106.8 million in all, each compared on four paths at the bank's 9.0% policy rate. Each row shows what went wrong, the rating, when the accommodation ends, the path that leads today and by how much.
Halvorsen Crossing is at the top: substandard, accommodation to October 30, committee on Thursday, October 15. Selling the note leads by $581,130.
Every workout. The leading path across the book by balance, and each troubled loan with its best path and how far ahead it is.
2
Four ways out, on one strip of numbers
The comparison opens with the shared assumptions across the top: value $13.20 million from the September 9 appraisal, falling 4% a year, a 9.0% discount rate, 20 months to foreclose and sell in Ohio, the best bid of $12.65 million, and 30 months to lease up. Every column uses all of them; each value carries a SAME tag.
Sell the note leads at $12.29 million, 66.8% of the balance, with cash in 45 days. The restructure follows at $11.70 million, the extension at $11.38 million with an 85% chance of failing, and foreclosure at $11.11 million. Each column shows cash before time value and what time costs.
Compare the paths. Extend, restructure, sell the note and foreclose valued on the same assumptions, the leader highlighted. The extension column's coverage reads 1.10x on $1,075,000 of interest; at 6.25% on $17,650,000 the interest is $1,103,125 and coverage is 1.07x.
3
What would change the answer, solved on the same model
Under the columns, the break-even for each rival: foreclosure wins only if the value is above $14.73 million, 12% higher than the appraisal; the restructure only if the discount rate falls below 7.6%; the extension only if the chance of a full refinance in 24 months is above 27%, against 15% today. The note sale stays first while the bid is above $12.05 million.
Owen Pacheco, the chief lending officer, asked whether there is a version that keeps the client. This is his answer, in numbers the committee can argue with.
What would change the answer. Each rival's break-even against the leader, with a Try it link that moves the assumption and re-values every column.
4
A term sheet drafted from the best bid
The memo and term sheet writer lays the three bids side by side: Gravenstein Capital at $12,650,000 closing in 45 days, Ashbury Credit Partners at $12,180,000 in 60 days, Pell Street Opportunity Fund at $11,720,000 in 75 days. It drafts a non-binding loan sale term sheet from the best: all cash, 10% deposit, 15 business days of diligence, no recourse, the guaranty assigned to the buyer.
The accounting line carries the charge-off at signing, $5,936,500, and the provision of $1,036,500 over the $4,900,000 allowance. Nothing goes to a buyer from here; Dana edits and sends.
Term sheet. Three bids compared and a draft term sheet from the best one. The screen discounts each bid at two months; at its 75-day close the third bid would be worth $11.34 million, which does not change the order.
5
The committee decides, on the record
Thursday at 8:52 am the committee approves the note sale 4–0. Ruth Castellano signs the $5,936,500 charge-off and the rating of Loss on the charged-off part; the purchase agreement goes to counsel, with closing by November 30.
The case history keeps every step: who changed an assumption, which agent valued what, and the memo sent with the assumptions locked as version 3.
Loan committee. The agenda, four votes, the decision with the charge-off signed, and the case history by person or agent.
The solution's design target is one day from a complete file to a committee-ready comparison, against an estimated four to six days by hand. It is a target, to be measured on your own loans.
17 · Every screen
Ten more screens behind the recommendation, from the building's income to the bank's valuation rules
In shortThe recommendation rests on these: the building's income and coverage under each path, the value and rates with their sources, the guarantor's balance sheet, the agents' run, a Try it that flips the leader, a fifth path added on the same assumptions, the cash flows behind two columns, the cited memo and the bank's own rules.
Cash flow today. Income fell from $2.31 million in 2024 to $1.18 million for the twelve months to September, coverage 0.71x as written. The extension line should read $1,103,125 and 1.07x; the restructure's 1.17x on $1,004,700 of Note A payments is right.
Value and rates. The value path against the $18.4 million balance, and every rate with its source. The Treasury and SOFR figures are the product's sample rate sheet.
Guarantor and sponsor. Net worth $11.6 million, $1.9 million liquid, $42.3 million of other guarantees; the $750,000 paydown is credible, and $400,000 is used as a deficiency recovery after foreclosure.
Re-value on today's numbers. One press re-reads the file; each agent's step appears with its source as it finishes.
Try it. At $14.9 million, just past the break-even, foreclosure leads at $12.42 million and the sale falls to second. Back to the file restores the appraisal.
Add a path. A deed-in-lieu on the same assumptions: $11.37 million, ahead of foreclosure because it saves eight months, behind the note sale. The charge-off lines differ from the 2023 statement: the extension's $0 would be about $4.45 million, and the foreclosure's $5.79 million belongs at the decision to foreclose, where the screen shows it at transfer (section 11).
The note sale's cash flows. Price, fee and closing costs, discounted at 9.0%: $12,285,767.
The restructure's cash flows. Expected cash by year with both branches weighted: the 72% that performs and the 28% that ends in foreclosure.
Committee memo. Six sections with seven margin notes back to the documents, and a checklist drawn from the points in the 2023 interagency statement, in the product's own short wording; "options compared on one basis" is the bank's own policy, which the statement does not require. Section 14.3 is the fictional bank's policy.
Your valuation rules. The discount rate, costs, foreclosure months by state, the paths always compared and who approves what; changes are versioned and shown to credit risk review.
Select any screen to open it larger. Wherever the extension column shows coverage of 1.10x on $1,075,000 of interest, the correct figures are 1.07x on $1,103,125. Wherever it shows a $0 charge-off, the 2023 statement's retail example points to about $4.45 million, the balance after the paydown above the $13.2 million "as is" value; the foreclosure's charge-off falls at the decision to foreclose. The rankings stay the same. The bank, borrowers, bidders, people and figures are fictional; market rates on the screens are sample data.
18 · Agents, and who signs
Six narrow agents and three signing limits: the officer to $1 million, the chief credit officer to $5 million, the committee for larger charge-offs and every note sale
In shortEach agent has one job and limits it does not cross. None sets a rating, contacts the borrower or a buyer, or gives one path friendlier numbers. The special assets officer recommends; the chief credit officer signs ratings and charge-offs up to $5 million; any larger charge-off and every note sale goes to the loan committee, recorded with its votes.
What each agent values, and the line it never crosses
Financials reader
Reads the operating statement, rent roll, leases and borrower statements, and sets current income, occupancy and coverage at today's terms and at each path's terms.
Never adjusts a figure without the line it came from.
Value and rate updater
Reads the new appraisal, comparable sales and the rate sheet; sets value, value trend, cap rate and rates.
Never uses a value outside the appraisal without a flagged reason; flags any assumption older than 12 months.
Guarantor and sponsor analyst
Reads the personal financial statement, returns and credit report; builds global cash flow; lists every contingent liability; says what the guarantor can credibly bring.
Never treats contingent liabilities as zero.
Option modeler
Values every path on one shared set of assumptions at the policy rate, weights each branch by its chance, and solves the break-evens.
Never uses a different assumption for one path; adds a deed-in-lieu only on request.
Classification and accounting checker
Sets out each path's rating, accrual, modification disclosure, allowance and charge-off effect.
Never sets the final rating; the chief credit officer does.
Memo and term sheet writer
Drafts the committee memo in the bank's six sections and the term sheet for the chosen path, every figure cited.
Never sends anything to the borrower or a buyer; the officer edits and sends.
Approval limits for recommendations, ratings and charge-offs
RecommendsSpecial assets officerChanges assumptions with a reason, edits and sends the memo, signs charge-offs up to $1,000,000.
SignsChief credit officerSigns ratings and charge-offs up to $5,000,000 and chairs the committee.
VotesLoan committeeFour members approve any path with a larger charge-off and every note sale; votes are recorded.
Every assumption change is versioned with its source and who made it; the memo goes to committee with the assumptions locked, and a later change is flagged in it. Credit risk review reads every case, version and vote.
Corvane Bank's cast in the sample data
Fictional, from the sample data
DO
Dana Okafor · special assets officer
Twelve troubled loans and a committee memo most weeks.
"I need the four options on one page, on the same numbers, before Thursday."
MT
Miles Tran · workout analyst
Built every cash-flow model by hand until now.
"Every memo starts with a blank spreadsheet."
RC
Ruth Castellano · chief credit officer
Chairs the committee; signs ratings and charge-offs.
"Show me what would change your answer."
OP
Owen Pacheco · chief lending officer
Owns the relationship with the sponsor.
"Is there a version where we keep the client?"
EH
Erik Halvorsen · guarantor
Owns Halvorsen Crossing and six other properties.
"Give me two years and I'll fill the building."
19 · What goes in and out
Rent rolls, appraisals, guarantor statements and bids become valued paths, break-evens, a cited memo and a term sheet
In shortIt reads the documents a workout file already holds and the bank's own policy, and leaves behind every path valued on one set of assumptions, the break-evens, a recommended path with reasons, a cited memo and a draft term sheet. Your systems of record stay where they are.
From the file
Operating statements, rent roll and leases
The new appraisal and comparable sales
Guarantor statements, returns and credit report
Loan terms, rating, accrual and allowance
Note bids and the borrower's offers
From the bank
Discount rate and cost assumptions
Foreclosure months by state
Paths always compared
Approval limits and memo template
Agents read, value and draftEvery path on one set of assumptions, under your credit policy
The officer recommends
Every figure tied to its document
Outputs
Every path's net present recovery, time, chance of failing, charge-off and classification
The break-even for each rival
A recommended path with reasons
A committee memo, every figure cited
A draft term sheet for the chosen path
The decision and votes on the case history
What changes for the team
No blank spreadsheet per loan
Assumptions argued once, used everywhere
Memos that answer "what would change it"
Eight systems a workout comparison draws on
Core and loan servicingBalances, rating, accrual, allowance
Appraisal managementNew appraisals and evaluations
Problem loan trackingWatch list and special assets records
Committee workflowAgendas, memos, votes
General ledgerCharge-offs, held for sale, foreclosed property
Identity and accessApproval limits, separation of duties
Email and secure file exchangeBids and borrower letters in
For each, check whether it has an API, a file feed or only screens, and who owns it.
One assumption set, a source for every figure, a person for every decision
1
One set of assumptions
Value, trend, rate, months to foreclose, bid and lease-up drive every path at once.
2
Every figure cited
Operating statement line, appraisal page, guarantor statement or bid letter, one click away.
3
Agents value; people decide
The officer recommends, the chief credit officer signs, the committee votes, on the record.
Part C · Are you ready to automate?
Automating loan workout analysis: what a wrong path costs, what better analysis returns, and how to test it
You work troubled loans, run the team that does, or vote on the paths. This part is written for you: what slow or unfair comparisons cost today, what automating the analysis could return, whether your team is ready, and what to ask any vendor of workout software, including us.
20 · What a wrong path costs
Recoveries lost to delay and to failed modifications: the price of picking the wrong workout path
In shortThe largest costs are recoveries lost to time and to paths that fail. Published bank data show both are large. Analyst time is the smaller cost, though it is the one that delays decisions. Start from your own resolved loans: the evidence of what your paths returned is in your files.
17% vs 70%
mean loss on commercial real estate loans at failed banks resolved within six months, against those that took more than three years.2
FDIC, loss-share data, 2008–2013 failures
+14 pts
higher mean loss on foreclosed commercial real estate loans than on those resolved another way, 65.3% against 51.6%.2
FDIC, loans that did not cure
35%
of modified commercial real estate loans were later foreclosed; they lost 65.8% against 47.8% for modifications that held.2
FDIC, same dataset
A committee-ready comparison in one day, against four to six days by hand
Working days from a complete workout file to a committee-ready comparison and memo
By hand (estimate)With automation (design target)
One troubled CRE loan5.5 days1 day
Illustrative · replace with your own numbers · The solution's own estimate and design target; neither is a measurement. Time three of your own.
Show the numbers
By hand (estimate)
With automation (design target)
One troubled CRE loan
5.5 days
1 day
The gaps in public data. Section 8 lists what nobody publishes about recoveries, note sale prices and guarantors. Three more matter here: there is no public figure for the time a workout analysis takes, the share of bank workouts resolved by each path, or what a bank would have recovered on the path it did not take. The table below shows where your own numbers sit.
Six workout costs to measure from your own resolved loans
Cost
Where it hides
How to find your number in a week
Recovery by path
Charge-off and recovery records, never joined to the path chosen
List the last five years of resolved problem loans: path, months, net recovery as a share of balance
Failed workouts
Extensions and modifications that came back
Count modified or extended loans that re-defaulted within two years, and what they lost
Months to resolve
Accommodation after accommodation
Median months from first downgrade to final resolution, by path
Analyst and officer time
Rebuilding cash flows, rewriting memos
Log the hours on the next three committee memos
Foreclosure cost
Legal, receiver and carrying costs booked elsewhere
Total them for the last five foreclosures, by state
Exam and review findings
Comments on stale values, weak guarantor analysis, soft terms
Your last two exam reports and credit risk review findings on workouts
Expired bids, hidden losses and other costs outside the calculator
The extension that hid a lossA year of interest only, then a foreclosure on a lower value.
The bid that expiredA buyer's price holds for weeks; a slow memo can lose it.
The committee's confidenceA recommendation without break-evens invites another round of questions and another week.
The precedentSoft terms for one borrower become the ask from the next.
Knowledge that walks outWhen the analyst leaves, the spreadsheet's assumptions go too.
21 · Your return
Loan workout analysis software ROI: how much recovery uplift pays for the tool
In shortTwo levers matter: a small improvement in the recovery on the loans you work out each year, and the analyst and officer days released per loan. Put in your own numbers. Every default marked illustrative is an assumption to replace; the recovery uplift in particular is the figure to measure on your own resolved loans before you believe any vendor, including us.
Six ways a better path choice pays back
Recovery
The better path, more often
Every path valued fairly, with failure branches and break-evens, so the committee picks the one worth most.
workouts × average balance × recovery uplift
Time
Days per memo released
Cash flows, comparisons and the memo drafted from the file, cited, for the officer to edit.
workouts × days saved × loaded daily cost
Speed
Earlier resolution
FDIC data show losses rise with every half-year of workout; a decision a month sooner is worth more than the hours.2
months saved × monthly carry and value decline
Bids
Offers that do not expire
A committee memo in a day keeps a note buyer's price inside its window.
bids kept × price difference to the next path
Exams
Documentation ready
Borrower, guarantor, value and cash-flow analysis on file for every workout, as the 2023 statement expects.1
hours assembling support for reviews and exams
Consistency
One policy for every loan
The same discount rate, costs and timelines, versioned, so two officers value the same loan the same way.
findings on inconsistent valuation, before and after
Workout analysis return calculator
The daily cost starts from the 2025 median wage for credit analysts, $40.15 an hour,30 times eight hours, loaded about 43% for benefits. Every input marked illustrative is an assumption.
Your bookYour timeYour cost
Illustrative yearly value
Added recovery$0
Time released, valued$0
After your yearly cost$0
Days released a year0
Cost left after time released$0
Recovery uplift that covers your cost0
Formulas, per year: Added recovery = workouts × average balance × uplift ÷ 100 Time released = workouts × (days today − days with automation) × daily cost After your cost = added recovery + time released − yearly cost Cost left = yearly cost − time released Break-even uplift = cost left ÷ (workouts × average balance) × 100, shown to one decimal
The 0.5% uplift default is a placeholder, far below the 3.2% gap between the best and next-best path in this guide's example; measure it by re-valuing ten of your resolved loans. Not counted: earlier resolution, bids kept, exam evidence. Released days are value only when you decide what they are for.
With released days counted, a 0.07% recovery uplift on $120 million a year covers a $120,000 cost
Recovery uplift needed to cover $120,000 a year, after the value of released days, at 20 workouts a year
Average balance $3M ($60M worked out a year)0.13%
Average balance $6M ($120M a year)0.07%
Average balance $12M ($240M a year)0.03%
Illustrative · replace with your own numbers · Time released: 20 × 4.5 days × $460 = $41,400; remaining $78,600 ÷ balance worked out. Our arithmetic on the calculator's defaults.
Show the numbers
Book
Break-even uplift
Average balance $3M ($60M worked out a year)
0.13%
Average balance $6M ($120M a year)
0.07%
Average balance $12M ($240M a year)
0.03%
A bank that works out a handful of small loans a year should say so before buying anything; the time saved may be the whole case. A bank with a large book of office and multifamily maturities will find the recovery lever dominates.
Start here22 · Readiness check
How ready your special assets team is to automate workout analysis: volume, policy, data and sign-off
In shortPick the answer closest to your team today. Eight questions score 0 to 2; the last is for reflection. The meter adds up your score as you go, and each question says why it matters and what a strong answer sounds like.
1
Volume
How many troubled commercial loans does your team work out or recommend on in a year?
Why it mattersVolume and balance turn a small uplift into real dollars, and maturities are rising.26
A strong answer"About 25 a year, mostly office and multifamily, with more maturing next year."
2
Written policy
Does your credit policy set the discount rate, cost assumptions and the paths always compared?
Why it mattersSoftware applies a policy; it cannot settle one. Without a written rate, two officers value the same loan differently.
A strong answer"9% on troubled assets, a cost list, four paths minimum, all in section 14."
3
Your evidence
Do you know what each path has returned on your own resolved loans, and how long it took?
Why it mattersNo public dataset covers healthy banks' workouts by path; your history is the benchmark for chances, timelines and costs.
A strong answer"Five years of resolutions with path, months and loss, joined to the charge-off records."
4
The file
Are operating statements, rent rolls, appraisals, guarantor statements and bids kept in one place per loan, electronically?
Why it mattersReading the file is the first step; a file spread across inboxes slows any tool.
A strong answer"One folder per relationship in our document system, with an API."
5
Findings
Have examiners or credit risk review commented on workout valuations, stale values or guarantor analysis in the last two years?
Why it mattersThe 2023 statement sets what examiners look for: current values, realistic cash flow, guarantor capacity.1
A strong answer"Review found three memos valued on lender estimates without a new appraisal."
6
Decision record
Are committee decisions, votes and the assumptions behind them recorded in one place?
Why it mattersA recommendation is only as defensible as the record of what was assumed and who approved it.
A strong answer"Every memo, version and vote in the committee system."
7
Owner and budget
Is there a named owner of special assets with a budget to change how recommendations are built?
Why it mattersWorkouts cross special assets, credit, lending, finance and IT; without one owner a pilot stalls.
A strong answer"The chief credit officer sponsors it; the head of special assets owns it."
8
Governance
Do you have a way to approve AI in credit work: vendor due diligence, a view on SR 26-2, named sign-offs and an audit trail?
Why it mattersThe 2026 model guidance leaves generative AI to your own framework.10
A strong answer"Model risk and vendor management have a path for AI tools; people sign every rating and charge-off."
9
Vision · for reflection
If your committee asked tomorrow "what value would make foreclosure the better choice?" for every loan on the agenda, what would have to be true to answer in the meeting?
Why it mattersYour answer lists the gaps: one assumption set, a current value, a failure branch, a model that re-values on demand.
A strong answerA short, specific list, for example: "one policy rate, appraisals under a year old, every path in one model, break-evens in every memo."
Next steps at each readiness score
0–6
Explore
Build the evidence first: write the discount rate and cost list into policy, pull five years of resolved loans by path, and name an owner. Start narrow, for example with one assumption set and break-evens in every memo.
7–11
Ready to pilot
Re-value ten of your resolved loans blind and compare with what happened, then run live beside your analysts on new workouts for six weeks, with people signing every recommendation.
12–16
Ready to implement
Plan the full desk: your policy as settings, approval limits, the document and committee systems, credit risk review access, and the evidence examiners will ask for.
23 · Questions for any vendor
Testing a workout analysis vendor: twelve questions on one assumption set, failure branches, sources and your policy
In shortAsk every vendor the same questions, us included. The answers show whether every path shares one set of numbers, whether failure is modeled honestly, whether each figure can be traced, whose policy applies, and how you would test it on your own loans.
Ask
A good answer
A warning sign
The comparison
Do all paths use one set of assumptions, and can I see it?
One visible strip: value, trend, rate, months, bid, lease-up
Each path configured separately
How are failure branches modeled for extensions and restructures?
An explicit chance, with the foreclosure that follows valued on the same numbers
Only the borrower's plan
Can it solve the break-even for each rival?
Value, rate, chance and bid, solved on the same model
Sensitivity tables to read by eye
Which paths can it value?
Extension, restructure, note sale, foreclosure, deed-in-lieu, discounted payoff, forbearance
Modification only
Evidence
Can every figure in the memo be opened at its source?
Operating statement line, appraisal page, statement line, bid letter
A confidence score in place of a source
Are assumption changes versioned, with who and why?
Yes; the memo is sent with assumptions locked and later changes flagged
The latest numbers overwrite the last
Your policy
Who sets the discount rate, costs and timelines?
Your policy owner, versioned, visible to credit risk review
Vendor defaults
Does it set ratings or send anything to borrowers or buyers?
No; it drafts, people decide and send
Automatic notices
Your data and AI
Which AI models do you use, where do they run, and does our data train them?
Named models, a region you choose, no training on your data, in writing
"Proprietary AI", no more detail
How should we classify each part under SR 26-2?
A component-by-component answer for your model risk team
"It's all a model" or "none of it is"
Proof
Can we test it on our own resolved loans before we sign?
Yes, blind, and compared with what actually happened
We found no published independent test of any workout analysis tool, as of October 2026. Re-valuing your own resolved loans is the fairest test, and it measures your current process too.
24 · How to start
A twelve-week workout analysis pilot: ten resolved loans valued blind, then six weeks live
In shortWrite the policy down, test on the past, then run live. Your resolved loans are the test set: you know what each path returned. None of these steps commits you to a vendor.
Write the valuation policy: discount rate, cost list, months to foreclose by state, the paths always compared.
Pull ten resolved workouts from the last five years with their files as they stood at decision time, and their outcomes.
Re-value them blind on your policy and compare the ranking with the path taken and what it returned.
Run live for six weeks on new workouts beside your analysts, with your officers recommending and your committee deciding.
Decide with three numbers: paths where the ranking differed and why, figures traced to source, and officer hours per memo.
A twelve-week pilot ends with a decision on three numbers
Your teamVendor
Write the valuation policy; pull ten resolved files
Load your policy, memo template and limits
Re-value the ten files blind
Compare with outcomes; review differences
Run live on new workouts
Score and decide
Week 04812
Illustrative · replace with your own numbers
Show the numbers
Activity
From
To
Write the valuation policy; pull ten resolved files
0
3
Load your policy, memo template and limits
1
4
Re-value the ten files blind
3
5
Compare with outcomes; review differences
5
6
Run live on new workouts
6
11
Score and decide
11
12
Five pilot results to score
Measure
How
Why
Ranking differences
Loans where the leading path differs from the one taken, with the reason
Shows whether the comparison would have changed decisions
Recovery difference
Valued gap between the path taken and the leader, against the actual outcome
Sizes the recovery lever on your own book
Figures traced
Sample 50 memo figures; share that open at their source
Examiners and review will try the same
Officer hours
Hours from complete file to sent memo, before and during
The time lever
Assumption errors
Values, rates or timelines the officer had to correct
Whether the reading is reliable
The full working-session questions: 15 questions in five groups
Bring special assets, credit administration, lending, finance, credit risk review, model risk and IT into one room. Each question says why it matters, what a strong answer looks like, and the warning sign.
A
How many workouts, and which kinds
A1
How many troubled loans do we work out a year, by property type and balance?
Why it mattersSets the size of both levers.
Strong answer · warning sign
A list by type and size.
"It depends on the year."
A2
How much of the book matures in the next two years without an obvious refinance?
Why it mattersNext year's workouts are already on this year's maturity schedule.26
Strong answer · warning sign
A maturity wall by quarter.
Nobody has run it.
A3
Which paths does policy require us to compare?
Why it mattersBecomes the minimum set on every loan.
Strong answer · warning sign
Four or more, written.
"Whatever the officer thinks relevant."
B
Our discount rate, timelines and failure chances
B1
What discount rate do we use, and why that one?
Why it mattersIt decides how slow paths rank.
Strong answer · warning sign
A policy rate with its reasoning.
The loan rate, by habit.
B2
What do we assume for months to foreclose and sell in each state we lend in?
Why it mattersJudicial states add months and losses.2
Strong answer · warning sign
A table from counsel, reviewed yearly.
One number for every state.
B3
How do we set the chance an extension or restructure fails?
Why it mattersIt is the most argued number in the memo.
Strong answer · warning sign
Our own re-default history, adjusted per loan.
Not modeled.
C
What our past workouts and exams show
C1
What did examiners and review say about our workouts in the last two years?
Why it mattersFindings show where documentation breaks.
Strong answer · warning sign
A list by type.
Nobody tracks them.
C2
What did our last ten resolutions return, by path?
Why it mattersThe only benchmark that fits our book.
Strong answer · warning sign
Path, months, loss, joined.
Charge-offs without the path.
C3
How do we evaluate guarantors, and do we count contingent liabilities?
Has model risk policy moved from SR 11-7 to SR 26-2, and how does it treat AI tools?
Why it mattersSR 26-2 replaced SR 11-7 on April 17, 2026.10
Strong answer · warning sign
Updated, with an AI path.
Still cites SR 11-7.
D3
Who sponsors the change, and what budget can move?
Why it mattersA pilot without a sponsor ends as a demonstration.
Strong answer · warning sign
A named executive.
No sponsor.
E
If every troubled loan were re-valued on demand
E1
What if every troubled loan were re-valued the day a new appraisal, rent roll or bid arrived?
Why it mattersTests appetite for a standing comparison.
Strong answer · warning sign
"We would decide sooner and on fewer surprises."
"The memo is the bottleneck anyway."
E2
What if every memo carried its break-evens?
Why it mattersLinks analysis to the committee's questions.
Strong answer · warning sign
Shorter committee debates.
Nobody would read them.
E3
Which steps would we never let software do without a person?
Why it mattersTells you where the signatures belong.
Strong answer · warning sign
Ratings, charge-offs, borrower and buyer contact, policy changes.
"All of it": then start with reading and drafting.
25 · Questions people ask
Note sale vs foreclosure, workout NPV, deed-in-lieu and A/B notes: short answers for special assets teams
In shortThe questions special assets teams and buyers search for most, each answered on its own.
What is loan workout analysis?
Loan workout analysis is the valuation of every way out of a troubled loan, such as an extension, a restructure, a note sale, a deed-in-lieu or a foreclosure, on the same assumptions, so a lender can choose the one worth most. Each path's expected cash flows, after costs and weighted by the chance each outcome happens, are discounted to today. The result is a net present recovery for each path and a recommendation for the loan committee.
How do you calculate net present recovery on a workout option?
List every cash flow the path produces by month, such as payments, sale proceeds, rent collected by a receiver, legal and broker costs, and fees. Weight each amount by the chance its branch happens, discount it to today at the policy rate, and add the results. For example, a $12,650,000 note bid less $186,500 of costs, received in two months and discounted at 9%, is worth $12,285,767.
Is it better to sell a note or foreclose on a commercial property?
It depends on the bid, the property's value and trend, and how long foreclosure takes in the state. A note sale turns the loan into cash in weeks and ends the exposure; foreclosure can recover more if the value is high and the process quick, but costs legal fees, receiver fees and months. FDIC data show foreclosed commercial real estate loans at failed banks lost about 14 points more than loans resolved another way.
What is an A/B note restructure?
An A/B note restructure splits a troubled loan into Note A, sized to what the property can repay on market terms, and Note B, the remainder. Under the 2023 interagency workout statement, Note B is classified loss and charged off, and Note A can be rated on its own terms and returned to accrual after sustained performance, generally at least six months of payments.
What discount rate should a bank use for a workout NPV?
No regulation sets one. Banks use the loan's own rate, a market rate that reflects the risk of the cash flows, or a required return on troubled assets set in credit policy. Pick one in policy and apply it to every path, because the rate decides how heavily slow paths are penalized; in one worked example, an A/B restructure beat a note sale at discount rates below 7.6% and lost to it above.
How long does commercial foreclosure take?
It depends on the state. In nonjudicial states the lender can sell under a power of sale after notice; in Texas, for example, the sale is held on the first Tuesday of a month after at least 21 days' notice. Judicial states require a lawsuit and a court-ordered sale. In FDIC failed-bank data, foreclosed commercial real estate loans took 926 days to resolve in judicial states and 757 in other states.
What is a deed-in-lieu of foreclosure for commercial property?
A deed-in-lieu is an agreement under which the borrower deeds the property to the lender in place of a foreclosure, often in exchange for a partial release of a guaranty. It saves months and legal cost but needs the borrower's agreement, and junior liens stay on title, so lenders keep their mortgage alive with anti-merger language in order to foreclose them out if needed.
What did ASU 2022-02 change for loan modifications?
ASU 2022-02 removed troubled debt restructuring accounting for banks that have adopted CECL, effective for fiscal years beginning after December 15, 2022. Banks now decide whether a modification is a new loan or a continuation of the old one under the general refinancing guidance, and disclose modifications to borrowers in financial difficulty that are principal forgiveness, a rate reduction, an other-than-insignificant payment delay or a term extension.
Will examiners criticize a bank for restructuring a CRE loan?
Not for a prudent workout. The 2023 interagency policy statement says institutions that implement prudent accommodations and workouts after a comprehensive review of the borrower's financial condition will not be criticized for it, even if the restructured loans remain adversely classified. Soft terms are another matter: in the statement's office example, a year of interest only at a below-market rate led to a substandard grade and nonaccrual.
How much do lenders lose on defaulted commercial real estate loans?
The largest bank study, of more than 50,000 defaulted loans at banks that failed between 2008 and 2013, found a mean loss of 43.8% on commercial real estate other than construction, 57.4% on construction and development, and 50.6% on business loans. Losses rose with workout time, from 17% for loans resolved within six months to 70% for those taking over three years. Moody's put 2022 losses on liquidated office CMBS loans at 73.9%.
How do you value a personal guaranty in a workout?
Start from liquid assets and subtract what the guarantor already owes and has guaranteed elsewhere. Judge willingness from whether earlier calls were paid voluntarily or only after a lawsuit, as the 2023 statement asks. Then decide how the guaranty enters each path: a paydown now, a deficiency claim after foreclosure, or a release traded for a deed-in-lieu. No public dataset measures what lenders collect, so document the judgment.
What is extend and pretend in commercial real estate?
Extend and pretend describes lenders extending maturing loans they do not expect to be repaid, to defer recognizing a loss. A Federal Reserve Bank of New York study found weakly capitalized banks extended distressed CRE loans to preserve capital, building up near-term maturities. A fair comparison guards against it by valuing an extension with its chance of failing and its foreclosure branch.
26 · One-page summary
Valuing a troubled CRE loan's ways out, condensed: six method steps, the rules in force and 13 terms
Print this page
In shortThe whole guide on one screen: the method, the rules as of October 2026, what the data say and the terms.
The method
Refresh the file: income, rent roll, a current appraisal, guarantor statements, bids.
Set one assumption set: value and trend, discount rate, months to foreclose, costs, best bid.
Value every path month by month, with a failure branch for every hopeful one.
Discount at the policy rate; rank by net present recovery.
Solve the break-evens; write them in the memo.
Set out each path's charge-off, accrual and disclosure; recommend; let the committee decide.
Evidence: FDIC failed-bank CRE losses rise from 17% (under six months) to 70% (over three years); foreclosed loans lose about 14 points more; 35% of modifications later foreclosed.
As of October 2026: 2023 interagency CRE workout statement in force · ASU 2022-02 for CECL banks since fiscal 2023 · allowance policy statement revised April 2023 · SR 26-2 replaced SR 11-7 on April 17, 2026 · readiness 0–6 explore, 7–11 pilot, 12–16 implement.
13 terms
Workout
The plan to resolve a troubled loan: extend, restructure, sell, take the deed or foreclose.
Net present recovery
Expected cash after costs, weighted by chance, discounted to today.
Discount rate
The yearly rate that converts future cash into today's dollars.
Break-even
The assumption value at which a rival path overtakes the leader.
Accommodation
Deferring payments, taking partial payments or holding off remedies for a time.
A/B note
Note A the property can carry; Note B charged off.
Note sale
Selling the loan itself, usually for cash below the balance.
Discounted payoff
The borrower pays an agreed amount below the balance to retire the loan.
Deed-in-lieu
The borrower deeds the property to the lender in place of foreclosure.
Judicial foreclosure
Foreclosure through a court case and a court-ordered sale.
LGD
Loss given default: the share of the balance not recovered, with costs and lost interest.
Collateral-dependent
A loan to a borrower in financial difficulty that is expected to be repaid substantially from the operation or sale of its collateral.
OREO
Other real estate owned: property the bank holds after foreclosure or a deed.
27 · Sources
Sources
Accessed October 2026. Regulatory status statements are as of October 2026.
OCC, Federal Reserve, FDIC and NCUA, "Policy Statement on Prudent Commercial Real Estate Loan Accommodations and Workouts", 88 FR 43115, July 6, 2023. govinfo.gov
L. Shibut and R. Singer, "Loss Given Default for Commercial Loans at Failed Banks", FDIC Center for Financial Research Working Paper 2015-06, October 2015. fdic.gov
Katten, "Deeds in Lieu: Merger Doctrine Does Not Apply Where Grantee Is Senior Lienholder", January 30, 2015. katten.com
Texas Property Code §51.002, "Sale of Real Property Under Contract Lien" (FindLaw, current as of January 1, 2026). codes.findlaw.com
Federal Reserve, SR 01-12, "Interagency Guidance on Loans Held for Sale", May 10, 2001. federalreserve.gov
FASB, Accounting Standards Update 2022-02, "Financial Instruments—Credit Losses (Topic 326): Troubled Debt Restructurings and Vintage Disclosures", March 2022. storage.fasb.org
Federal Reserve, "Agencies finalize policy statement on commercial real estate loan accommodations and workouts", press release, June 29, 2023. federalreserve.gov
OCC, Federal Reserve, FDIC and NCUA, "Interagency Policy Statement on Allowances for Credit Losses (Revised April 2023)". federalreserve.gov
Federal Reserve, SR 26-2, "Revised Guidance on Model Risk Management", April 17, 2026 (issued jointly with OCC Bulletin 2026-13 and FDIC FIL-15-2026). federalreserve.gov
Federal Reserve, SR 23-5, "Prudent Commercial Real Estate Loan Accommodations and Workouts", June 30, 2023 (applies to all Fed-supervised institutions, including those of $10 billion or less; supersedes SR 09-7). federalreserve.gov
12 CFR 34.82, Holding period for other real estate owned (Cornell Legal Information Institute). law.cornell.edu
12 U.S.C. §29, Power to purchase, hold, and convey real estate (five-year holding period; OCC may approve up to five more years) (Cornell Legal Information Institute). law.cornell.edu
12 CFR 34.43, Appraisals required; transactions requiring a State certified or licensed appraiser, paragraphs (a)(7), (a)(13) and (b) (Cornell Legal Information Institute). law.cornell.edu
FDIC, RMS Manual of Examination Policies, Section 3.2, Loans (March 2026): classification definitions and appraisals for loan workouts. fdic.gov
Federal Reserve Bank of St. Louis, FRED, Bank Prime Loan Rate (DPRIME), observation of October 27, 2026. fred.stlouisfed.org
Federal Reserve Bank of St. Louis, FRED, Market Yield on U.S. Treasury Securities at 5-Year Constant Maturity (DGS5), October 2026. fred.stlouisfed.org
Till v. SCS Credit Corp., 541 U.S. 465, decided May 17, 2004 (Cornell Legal Information Institute). law.cornell.edu
MBA NewsLink, "Moody's: CMBS Loss Severities Drop" (Moody's 2022 Loss Severities Report), April 3, 2023. newslink.mba.org
Congressional Oversight Panel, "February Oversight Report: Commercial Real Estate Losses and the Risk to Financial Stability", February 10, 2010 (special servicer fees and pooling and servicing agreements). govinfo.gov
ATTOM, "2026 Mid-Year Foreclosure Market Report", July 16, 2026. attomdata.com
FDIC, 2026 Risk Review, April 22, 2026, Section 4.1, Commercial Real Estate. fdic.gov
M. Crosignani and S. Prazad, "Extend-and-Pretend in the U.S. CRE Market", Federal Reserve Bank of New York Staff Report 1130, October 2024, revised June 2026. newyorkfed.org
D. Glancy, R. Kurtzman and L. Loewenstein, "Loan Modifications and the Commercial Real Estate Market", Federal Reserve Board, FEDS 2022-050, July 26, 2022. federalreserve.gov
Federal Reserve, Financial Stability Report, May 2026, "Asset Valuations". federalreserve.gov
MBA NewsLink, "MBA: 17% of Commercial and Multifamily Mortgage Balances to Mature in 2026", February 9, 2026. newslink.mba.org
CRE Daily, "US CMBS Special Servicing Rate Rises on Retail, Office Loans" (Trepp data), July 15, 2026. credaily.com
M. Haas (CRED iQ), "Special Servicers Pivot Toward More Foreclosures", Commercial Observer, January 20, 2026. commercialobserver.com
L. Black, J. Krainer and J. Nichols, "From Origination to Renegotiation: A Comparison of Portfolio and Securitized Commercial Real Estate Loans", Journal of Real Estate Finance and Economics 55(1), July 2017 (Federal Reserve economists). ideas.repec.org
O*NET OnLine, Credit Analysts (13-2041.00), 2025 wages from the Bureau of Labor Statistics. onetonline.org
Next step
See it on your own troubled loans.
Explore the solution, or bring two or three of your own workout files and your credit policy, and we will value every path with you on one set of assumptions, every figure tied to its document.
We use essential cookies to make this site work, and cookieless, anonymised analytics to understand how it's used. "Accept all" also turns on Google Analytics, which sets cookies. Privacy policy