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Loans and ALLL
12 Months Ended
Dec. 31, 2020
Receivables [Abstract]  
Loans and ALLL Loans and ALLL
We grant commercial, agricultural, residential real estate, and consumer loans to customers situated primarily in Clare, Gratiot, Isabella, Mecosta, Midland, Montcalm, and Saginaw counties in Michigan. The ability of the borrowers to honor their repayment obligations is often dependent upon the real estate, agricultural, manufacturing, retail, gaming, tourism, higher education, and general economic conditions of this region. Substantially all of our consumer and residential real estate loans are secured by various items of property, while commercial loans are secured primarily by real estate, business assets, and personal guarantees. A portion of loans are unsecured.
Loans that we have the intent and ability to hold in our portfolio are reported at their outstanding principal balance adjusted for any charge-offs, the ALLL, and any deferred fees or costs. Interest income is accrued over the term of the loan based on the principal amount outstanding. Loan origination fees and certain direct loan origination costs are capitalized and recognized as a component of interest income over the term of the loan using the appropriate amortization methods.
The accrual of interest on commercial and agricultural loans, as well as residential real estate loans, is discontinued at the time a loan is 90 days or more past due unless the credit is well-secured and in the process of short-term collection. Upon transferring a loan to nonaccrual status, we perform an evaluation to determine the net realizable value of the underlying collateral. This evaluation is used to help determine if a charge-off is necessary. Consumer loans are typically charged-off no later than 180 days past due. Past due status is based on the contractual term of the loan. In all cases, a loan is placed in nonaccrual status or charged-off at an earlier date if collection of principal or interest is considered doubtful.
When a loan is placed in nonaccrual status or charged-off, all interest accrued in the current calendar year, but not collected, is reversed against interest income while interest accrued in prior calendar years, but not collected, is charged against the ALLL. Loans may be returned to accrual status after six months of continuous performance and achievement of current payment status.
Commercial and agricultural loans include loans for commercial real estate, commercial operating loans, advances to mortgage brokers, farmland and agricultural production, and loans to states and political subdivisions. Repayment of these loans is dependent upon the successful operation and management of a business. We minimize our risk by limiting the amount of direct credit exposure to any one borrower to $15,000. Borrowers with direct credit needs of more than $15,000 may be serviced through the use of loan participations with other commercial banks. Commercial and agricultural real estate loans commonly require loan-to-value limits of 80% or less. Depending upon the type of loan, past credit history, and current operating results, we may require the borrower to pledge accounts receivable, inventory, property, or equipment. Personal guarantees are generally required from the owners of closely held corporations, partnerships, and sole proprietorships. In addition, we may require annual financial statements, prepare cash flow analyses, and review credit reports.
We entered into a mortgage purchase program in 2016 with a financial institution where we participate in advances to mortgage brokers (“advances”). The mortgage brokers originate residential mortgage loans with the intent to sell them on the secondary market. We participate in the advance to the mortgage broker, which is secured by the underlying mortgage loan, until it is ultimately sold on the secondary market. As such, the average life of each participated advance is approximately 20-30 days. Funds from the sale of the loan are used to pay off our participation in the advance to the mortgage broker. We classify these advances as commercial loans and include the outstanding balance in commercial loans on our consolidated balance sheets. Under the participation agreement, we committed to a maximum outstanding aggregate amount of $80,000 as of December 31, 2020. During the first quarter of 2021, the maximum outstanding aggregate amount was reduced to $40,000. The difference between our outstanding balance and the maximum outstanding aggregate amount is classified as “Unfunded commitments under lines of credit” in the “Contractual Obligations and Loan Commitments” section of the Management's Discussion and Analysis of Financial Condition and Results of Operations of this report.
We offer adjustable rate mortgages, construction loans, and fixed rate residential real estate loans which have amortization periods up to a maximum of 30 years. We consider the anticipated direction of interest rates, balance sheet duration, the sensitivity of our balance sheet to changes in interest rates, our liquidity needs, and overall loan demand to determine whether or not to sell fixed rate loans to Freddie Mac.
Our lending policies generally limit the maximum loan-to-value ratio on residential real estate loans to 100% of the lower of the appraised value of the property or the purchase price. Private mortgage insurance is typically required on loans with loan-to-value ratios in excess of 80% unless the loan qualifies for government guarantees.
Underwriting criteria for residential real estate loans generally include:
Evaluation of the borrower’s ability to make monthly payments.
Evaluation of the value of the property securing the loan.
Ensuring the payment of principal, interest, taxes, and hazard insurance does not exceed 28% of a borrower’s gross income.
Ensuring all debt servicing does not exceed 40% of income.
Verification of acceptable credit reports.
Verification of employment, income, and financial information.
Appraisals are performed by independent appraisers and are reviewed for appropriateness. Generally, mortgage loan requests are reviewed by our mortgage loan committee or through a secondary market underwriting system; loans in excess of $1,000 require the approval of our Internal Loan Committee, the Executive Loan Committee, the Board of Directors’ Loan Committee, or the Board of Directors.
Consumer loans include secured and unsecured personal loans. Loans are amortized for a period of up to 15 years based on the age and value of the underlying collateral. The underwriting emphasis is on a borrower’s perceived intent and ability to pay rather than collateral value. No consumer loans are sold to the secondary market.
The ALLL is established as losses are estimated to have occurred through a provision for loan losses charged to earnings. Loan losses are charged against the ALLL when we believe the uncollectability of the loan balance is probable. Subsequent recoveries, if any, are credited to the ALLL.
The ALLL is evaluated on a regular basis for appropriateness. Our periodic review of the collectability of a loan considers historical experience, the nature and volume of the loan portfolio, adverse situations that may affect the borrower’s ability to repay, estimated value of any underlying collateral, and prevailing economic conditions. This evaluation is inherently subjective as it requires estimates that are susceptible to significant revision as more information becomes available.
The primary factors behind the determination of the level of the ALLL are specific allocations for impaired loans, historical loss percentages, as well as unallocated components. Specific allocations for impaired loans are primarily determined based on the difference between the loan’s outstanding balance and the present value of expected future cash flows discounted at the loan’s effective interest rate, or the fair value of the collateral, less costs to sell, if the loan is collateral dependent. Historical loss allocations are calculated at the loan class and segment levels based on a migration analysis of the loan portfolio, with the exception of advances to mortgage brokers, over the preceding five years. With no historical losses on advances to mortgage brokers, there is no allocation in the commercial segment displayed in the following tables. The unallocated component of the allowance reflects the margin of imprecision inherent in the underlying assumptions used in the methodologies for estimating specific and general losses in the portfolio.
A summary of changes in the ALLL and the recorded investment in loans by segments follows:
Allowance for Loan Losses
Year Ended December 31, 2020
CommercialAgriculturalResidential Real EstateConsumerUnallocatedTotal
January 1, 2020$1,914 $634 $2,047 $922 $2,422 $7,939 
Charge-offs(7)(24)(28)(322)— (381)
Recoveries149 39 136 197 — 521 
Provision for loan losses106 (338)(792)2,688 1,665 
December 31, 2020$2,162 $311 $1,363 $798 $5,110 $9,744 
 Allowance for Loan Losses
Year Ended December 31, 2019
CommercialAgriculturalResidential Real EstateConsumerUnallocatedTotal
January 1, 2019$2,563 $775 $1,992 $857 $2,188 $8,375 
Charge-offs(143)(240)(99)(466)— (948)
Recoveries123 189 167 — 482 
Provision for loan losses(629)96 (35)364 234 30 
December 31, 2019$1,914 $634 $2,047 $922 $2,422 $7,939 
Allowance for Loan Losses and Recorded Investment in Loans
As of December 31, 2020
CommercialAgriculturalResidential Real EstateConsumerUnallocatedTotal
ALLL
Individually evaluated for impairment$84 $56 $771 $— $— $911 
Collectively evaluated for impairment2,078 255 592 798 5,110 8,833 
Total$2,162 $311 $1,363 $798 $5,110 $9,744 
Loans
Individually evaluated for impairment$9,821 $13,796 $4,319 $— $27,936 
Collectively evaluated for impairment746,865 86,665 303,224 73,621 1,210,375 
Total$756,686 $100,461 $307,543 $73,621 $1,238,311 
Allowance for Loan Losses and Recorded Investment in Loans
As of December 31, 2019
CommercialAgriculturalResidential Real EstateConsumerUnallocatedTotal
ALLL
Individually evaluated for impairment$15 $26 $1,073 $— $— $1,114 
Collectively evaluated for impairment1,899 608 974 922 2,422 6,825 
Total$1,914 $634 $2,047 $922 $2,422 $7,939 
Loans
Individually evaluated for impairment$7,865 $14,840 $5,486 $— $28,191 
Collectively evaluated for impairment693,076 102,080 293,083 70,140 1,158,379 
Total$700,941 $116,920 $298,569 $70,140 $1,186,570 
The following tables display the credit quality indicators for commercial and agricultural credit exposures based on internally assigned credit risk ratings as of December 31:
 2020
 CommercialAgricultural
Real EstateOtherAdvances to Mortgage BrokersTotalReal EstateOtherTotalTotal
Rating
1 - Excellent$— $— $— $— $— $— $— $— 
2 - High quality2,308 13,406 — 15,714 541 11 552 16,266 
3 - High satisfactory69,327 51,093 50,258 170,678 14,411 5,312 19,723 190,401 
4 - Low satisfactory403,733 122,025 — 525,758 34,464 17,600 52,064 577,822 
5 - Special mention15,049 6,174 — 21,223 13,137 3,240 16,377 37,600 
6 - Substandard15,854 6,130 — 21,984 5,267 2,693 7,960 29,944 
7 - Vulnerable26 1,303 — 1,329 3,208 387 3,595 4,924 
8 - Doubtful— — — — 190 — 190 190 
9 - Loss— — — — — — — — 
Total$506,297 $200,131 $50,258 $756,686 $71,218 $29,243 $100,461 $857,147 
 2019
 CommercialAgricultural
Real EstateOtherAdvances to Mortgage BrokersTotalReal EstateOtherTotalTotal
Rating
1 - Excellent$— $390 $— $390 $— $— $— $390 
2 - High quality2,582 8,844 — 11,426 1,452 99 1,551 12,977 
3 - High satisfactory109,737 42,858 35,523 188,118 16,765 6,769 23,534 211,652 
4 - Low satisfactory377,198 94,847 — 472,045 42,798 20,861 63,659 535,704 
5 - Special mention15,372 3,470 — 18,842 7,165 3,754 10,919 29,761 
6 - Substandard4,874 3,625 — 8,499 9,136 3,836 12,972 21,471 
7 - Vulnerable390 1,231 — 1,621 2,711 1,574 4,285 5,906 
8 - Doubtful— — — — — — — — 
9 - Loss— — — — — — — — 
Total$510,153 $155,265 $35,523 $700,941 $80,027 $36,893 $116,920 $817,861 
Internally assigned credit risk ratings are reviewed, at a minimum, when loans are renewed or when management has knowledge of improvements or deterioration of the credit quality of individual credits. Descriptions of the internally assigned credit risk ratings for commercial and agricultural loans are as follows:
1. EXCELLENT – Substantially Risk Free
Credit has strong financial condition and solid earnings history, characterized by:
High liquidity, strong cash flow, low leverage.
Unquestioned ability to meet all obligations when due.
Experienced management, with management succession in place.
Secured by cash.
2. HIGH QUALITY – Limited Risk
Credit with sound financial condition and a positive trend in earnings supplemented by:
Favorable liquidity and leverage ratios.
Ability to meet all obligations when due.
Management with successful track record.
Steady and satisfactory earnings history.
If loan is secured, collateral is of high quality and readily marketable.
Access to alternative financing.
Well defined primary and secondary source of repayment.
If supported by guaranty, the financial strength and liquidity of the guarantor(s) are clearly evident.
3. HIGH SATISFACTORY – Reasonable Risk
Credit with satisfactory financial condition and further characterized by:
Working capital adequate to support operations.
Cash flow sufficient to pay debts as scheduled.
Management experience and depth appear favorable.
Loan performing according to terms.
If loan is secured, collateral is acceptable and loan is fully protected.
4. LOW SATISFACTORY – Acceptable Risk
Credit with bankable risks, although some signs of weaknesses are shown:
Would include most start-up businesses.
Occasional instances of trade slowness or repayment delinquency – may have been 10-30 days slow within the past year.
Management’s abilities are apparent yet unproven.
Weakness in primary source of repayment with adequate secondary source of repayment.
Loan structure generally in accordance with policy.
If secured, loan collateral coverage is marginal.
To be classified as less than satisfactory, only one of the following criteria must be met.
5. SPECIAL MENTION – Criticized
Credit constitutes an undue and unwarranted credit risk but not to the point of justifying a classification of substandard. The credit risk may be relatively minor yet constitutes an unwarranted risk in light of the circumstances surrounding a specific loan:
Downward trend in sales, profit levels, and margins.
Impaired working capital position.
Cash flow is strained in order to meet debt repayment.
Loan delinquency (30-60 days) and overdrafts may occur.
Shrinking equity cushion.
Diminishing primary source of repayment and questionable secondary source.
Management abilities are questionable.
Weak industry conditions.
Litigation pending against the borrower.
Loan may need to be restructured to improve collateral position or reduce payments.
Collateral or guaranty offers limited protection.
Negative debt service coverage, however the credit is well collateralized and payments are current.
6. SUBSTANDARD – Classified
Credit is inadequately protected by the current net worth and paying capacity of the borrower or of the collateral pledged. There is a distinct possibility we will implement collection procedures if the loan deficiencies are not corrected. Any commercial loan placed in nonaccrual status will be rated “7” or worse. In addition, the following characteristics may apply:
Sustained losses have severely eroded the equity and cash flow.
Deteriorating liquidity.
Serious management problems or internal fraud.
Original repayment terms liberalized.
Likelihood of bankruptcy.
Inability to access other funding sources.
Reliance on secondary source of repayment.
Litigation filed against borrower.
Interest non-accrual may be warranted.
Collateral provides little or no value.
Requires excessive attention of the loan officer.
Borrower is uncooperative with loan officer.
7. VULNERABLE – Classified
Credit is considered “Substandard” and warrants placing in nonaccrual status. Risk of loss is being evaluated and exit strategy options are under review. Other characteristics that may apply:
Insufficient cash flow to service debt.
Minimal or no payments being received.
Limited options available to avoid the collection process.
Transition status, expect action will take place to collect loan without immediate progress being made.
8. DOUBTFUL – Workout
Credit has all the weaknesses inherent in a “Substandard” loan with the added characteristic that collection and/or liquidation is pending. The possibility of a loss is extremely high, but its classification as a loss is deferred until liquidation procedures are completed, or reasonably estimable. Other characteristics that may apply:
Normal operations are severely diminished or have ceased.
Seriously impaired cash flow.
Original repayment terms materially altered.
Secondary source of repayment is inadequate.
Survivability as a “going concern” is impossible.
Collection process has begun.
Bankruptcy petition has been filed.
Judgments have been filed.
Portion of the loan balance has been charged-off.
9. LOSS – Charge-off
Credit is considered uncollectible and of such little value that their continuance as bankable assets is not warranted. This classification is for charged-off loans but does not mean that the asset has absolutely no recovery or salvage value. These loans are further characterized by:
Liquidation or reorganization under Bankruptcy, with poor prospects of collection.
Fraudulently overstated assets and/or earnings.
Collateral has marginal or no value.
Debtor cannot be located.
Over 120 days delinquent.
Our primary credit quality indicator for residential real estate and consumer loans is the individual loan’s past due aging. The following tables summarize the past due and current loans for the entire loan portfolio as of December 31:
 2020
 Accruing Interest
and Past Due:
 Total Past Due and Nonaccrual  
30-59
Days
60-89
Days
90 Days
or More
NonaccrualCurrentTotal
Commercial
Commercial real estate$333 $— $— $26 $359 $505,938 $506,297 
Commercial other486 — — 1,303 1,789 198,342 200,131 
Advances to mortgage brokers— — — — — 50,258 50,258 
Total commercial819 — — 1,329 2,148 754,538 756,686 
Agricultural
Agricultural real estate— — — 3,398 3,398 67,820 71,218 
Agricultural other— — 387 388 28,855 29,243 
Total agricultural— — 3,785 3,786 96,675 100,461 
Residential real estate
Senior liens3,203 145 — 199 3,547 269,425 272,972 
Junior liens25 — — — 25 3,791 3,816 
Home equity lines of credit— — — 30,747 30,755 
Total residential real estate3,236 145 — 199 3,580 303,963 307,543 
Consumer
Secured93 — — — 93 70,349 70,442 
Unsecured— — — 3,176 3,179 
Total consumer96 — — — 96 73,525 73,621 
Total$4,152 $145 $ $5,313 $9,610 $1,228,701 $1,238,311 
 2019
 Accruing Interest
and Past Due:
 Total Past Due and Nonaccrual  
30-59
Days
60-89
Days
90 Days
or More
NonaccrualCurrentTotal
Commercial
Commercial real estate$139 $30 $— $390 $559 $509,594 $510,153 
Commercial other531 156 — 1,231 1,918 153,347 155,265 
Advances to mortgage brokers— — — — — 35,523 35,523 
Total commercial670 186 — 1,621 2,477 698,464 700,941 
Agricultural
Agricultural real estate— — — 2,711 2,711 77,316 80,027 
Agricultural other— — — 1,574 1,574 35,319 36,893 
Total agricultural— — — 4,285 4,285 112,635 116,920 
Residential real estate
Senior liens3,463 258 — 557 4,278 253,894 258,172 
Junior liens65 — — — 65 5,766 5,831 
Home equity lines of credit157 — — 72 229 34,337 34,566 
Total residential real estate3,685 258 — 629 4,572 293,997 298,569 
Consumer
Secured68 — — — 68 66,547 66,615 
Unsecured— — — 3,522 3,525 
Total consumer71 — — — 71 70,069 70,140 
Total$4,426 $444 $ $6,535 $11,405 $1,175,165 $1,186,570 
Impaired Loans
Loans may be classified as impaired if they meet one or more of the following criteria:
1.There has been a charge-off of its principal balance (in whole or in part);
2.The loan has been classified as a TDR; or
3.The loan is in nonaccrual status.
Impairment is measured on a loan-by-loan basis for commercial and agricultural loans by comparing the loan’s outstanding balance to the present value of expected future cash flows discounted at the loan’s effective interest rate, or the fair value of the collateral, less costs to sell, if the loan is collateral dependent. Large groups of smaller-balance, homogeneous residential real estate and consumer loans are collectively evaluated for impairment by comparing the loan’s unpaid principal balance to the present value of expected future cash flows discounted at the loan’s effective interest rate.
We do not recognize interest income on impaired loans in nonaccrual status. For impaired loans not classified as nonaccrual, interest income is recognized daily, as earned, according to the terms of the loan agreement and the principal amount outstanding. The following summarizes information pertaining to impaired loans as of, and for the years ended, December 31:
2020
Recorded BalanceUnpaid Principal BalanceValuation AllowanceAverage Recorded BalanceInterest Income Recognized
Impaired loans with a valuation allowance
Commercial real estate$2,048 $2,290 $79 $1,384 $121 
Commercial other107 107 464 20 
Agricultural real estate1,994 1,994 54 2,099 103 
Agricultural other1,355 1,355 1,355 78 
Residential real estate senior liens4,319 4,661 771 4,836 197 
Residential real estate junior liens— — — — — 
Total impaired loans with a valuation allowance9,823 10,407 911 10,138 519 
Impaired loans without a valuation allowance
Commercial real estate3,006 3,080 3,679 210 
Commercial other4,660 4,660 3,730 150 
Agricultural real estate8,681 8,731 7,704 302 
Agricultural other1,766 1,766 2,361 105 
Home equity lines of credit— — 61 
Consumer secured— — — 
Total impaired loans without a valuation allowance18,113 18,237 17,536 772 
Impaired loans
Commercial9,821 10,137 84 9,257 501 
Agricultural13,796 13,846 56 13,519 588 
Residential real estate4,319 4,661 771 4,897 202 
Consumer— — — — 
Total impaired loans$27,936 $28,644 $911 $27,674 $1,291 
2019
Recorded BalanceUnpaid Principal BalanceValuation AllowanceAverage Recorded BalanceInterest Income Recognized
Impaired loans with a valuation allowance
Commercial real estate$517 $635 $15 $2,044 $61 
Commercial other— — — 10 — 
Agricultural real estate1,509 1,509 12 1,091 100 
Agricultural other1,355 1,355 14 832 55 
Residential real estate senior liens5,401 5,830 1,073 6,210 114 
Residential real estate junior liens— — — 11 — 
Total impaired loans with a valuation allowance8,782 9,329 1,114 10,198 330 
Impaired loans without a valuation allowance
Commercial real estate4,961 5,224 4,247 91 
Commercial other2,387 2,387 2,697 46 
Agricultural real estate8,372 8,422 7,404 171 
Agricultural other3,604 3,604 4,623 258 
Home equity lines of credit85 385 58 
Consumer secured— — — 
Total impaired loans without a valuation allowance19,409 20,022 19,034 572 
Impaired loans
Commercial7,865 8,246 15 8,998 198 
Agricultural14,840 14,890 26 13,950 584 
Residential real estate5,486 6,215 1,073 6,279 120 
Consumer— — — — 
Total impaired loans$28,191 $29,351 $1,114 $29,232 $902 
We had committed to advance $98 and $175 in additional funds to be disbursed in connection with impaired loans, which includes TDRs, as of December 31, 2020 and 2019, respectively.
Troubled Debt Restructurings
A loan modification is considered to be a TDR when the modification includes terms outside of normal lending practices to a borrower who is experiencing financial difficulties.
Typical concessions granted include, but are not limited to:
1.Agreeing to interest rates below prevailing market rates for debt with similar risk characteristics.
2.Extending the amortization period beyond typical lending guidelines for loans with similar risk characteristics.
3.Agreeing to an interest only payment structure and delaying principal payments.
4.Forgiving principal.
5.Forgiving accrued interest.
To determine if a borrower is experiencing financial difficulties, factors we consider include:
1.The borrower is currently in default on any of their debt.
2.The borrower would likely default on any of their debt if the concession is not granted.
3.The borrower’s cash flow is insufficient to service all of their debt if the concession is not granted.
4.The borrower has declared, or is in the process of declaring, bankruptcy.
5.The borrower is unlikely to continue as a going concern (if the entity is a business).
The following is a summary of information pertaining to TDRs granted in the years ended December 31:
20202019
Number of LoansPre-Modification Recorded InvestmentPost-Modification Recorded InvestmentNumber of LoansPre-Modification Recorded InvestmentPost-Modification Recorded Investment
Commercial other10 $5,224 $5,224 $1,188 $1,188 
Agricultural other3,194 3,194 3,286 3,286 
Residential real estate136 136 17 17 
Total18 $8,554 $8,554 11 $4,491 $4,491 
The following table summarizes the nature of the concessions we granted to borrowers in financial difficulty in the years ended December 31:
20202019
Below Market Interest RateBelow Market Interest Rate and Extension of Amortization PeriodBelow Market Interest RateBelow Market Interest Rate and Extension of Amortization Period
 Number of LoansPre-Modification Recorded InvestmentNumber of LoansPre-Modification Recorded InvestmentNumber of LoansPre-Modification Recorded InvestmentNumber of LoansPre-Modification Recorded Investment
Commercial other$987 $4,237 — $— $1,188 
Agricultural other— — 3,194 1,189 2,097 
Residential real estate— — 136 — — 17 
Total2 $987 16 $7,567 2 $1,189 9 $3,302 
We did not restructure any loans by forgiving principal or accrued interest during 2020 or 2019.
Based on our historical loss experience, losses associated with TDRs are not significantly different than other impaired loans within the same loan segment. As such, TDRs, including TDRs that have been modified in the past 12 months that subsequently defaulted, are analyzed in the same manner as other impaired loans within their respective loan segment.
We had no loans that defaulted in the years ended December 31, 2020 and 2019, which were modified within 12 months prior to the default date.
The following is a summary of TDR loan balances as of December 31:
20202019
TDRs$24,930 $24,737 
Measures we have taken to assist our customers include loan programs that provide short-term payment relief.  Under these programs, borrowers whose loans were in good standing as of March 1, 2020 could elect to defer full or partial payments for a period not to exceed 180 days.  Loan payment deferrals totaled $306,103, or 23.8% of gross loans, as of June 30, 2020. As of September 30, 2020, active loan payment deferrals declined to $103,858, or 8.0% of gross loans, as the majority of borrowers granted loan payment deferrals had reverted back to contractual payments. As of December 31, 2020, active loan payment deferrals declined even further and totaled $6,048, or 0.5% of gross loans.
Bank regulators issued a statement on March 22, 2020, and a revised statement on April 7, 2020, which provided confirmation that short-term loan modifications made on a good faith basis in response to COVID-19 to borrowers with a current payment status are not categorized as TDRs. Pursuant to this guidance, borrowers granted a short-term loan modification meeting this criteria were not categorized as TDR as of December 31, 2020.