When do the 15 days for issuing a notice of adverse credit decisions on restructuring applications start?
An adverse credit decision on a restructuring request must be provided within 15 days of the conclusion of negotiations. Negotiations in this context are meant to be a cooperative effort between the qualified lender and the borrower to develop the best restructuring plan possible. The 15-day period does not begin when the lender receives a signed application for restructuring and a proposed restructuring plan from the borrower. Rather, it begins when (1) the qualified lender has obtained information sufficient to make a safe and sound credit restructuring decision and (2) the qualified lender has attempted to address any deficiency in the information provided by the borrower.
