As we enter the second quarter of 2024, borrowers and lenders alike find themselves mired in a continuing field of uncertainty. Market dynamics influenced by a myriad of known and unknown dynamics, particularly interest rate uncertainty, have caused consternation among borrowers facing looming maturities and diminishing refinancing opportunities. Conversely, lenders managing non-performing and maturing loan portfolios are caught navigating a minefield of competing internal and external pressures and regulatory scrutiny. To wit, the Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board), Federal Deposit Insurance Corporation (FDIC) (amongst other federal regulators and agencies) have "encouraged" financial institutions to "work prudently and constructively with creditworthy borrowers during times of financial stress" in implementing short-term loan accommodations and long-term loan workout arrangements to improve a lender's prospect for repayment while mitigating "long-term adverse effects on borrowers by allowing them to address the issues affecting repayment ability and are often in the best interest of financial institutions and their borrowers." (See June 29, 2023, "Policy Statement on Prudent Commercial Real Estate Loan Accommodations and Workouts"—referred to herein as the Policy Statement.) As stated in the Policy Statement, lenders should "employ prudent risk management practices and appropriate internal controls over such accommodations" while contemporaneously implementing consistent sound banking and accounting practices in accordance with applicable laws and regulations. (Id. at page 20.) At first glance, such a goal seems quite attainable; however, without a crystal ball, no one knows when, how or if borrowers facing such financial stress will return to a position refinancability.