COVID-19 Federal and State Banking Guidance

March 23, 2020

Last night the federal banking regulators, the FRB, FDIC, NCUA, OCC, and CFPB, along with state regulators (CSBS) issued formal guidance to financial institutions acknowledging the temporary business disruptions and challenges presented by COVID-19 and its broad impact throughout the economy.

The agencies have encouraged financial institutions to work prudently with commercial and retail borrowers who may have difficulty in meeting contractual payment obligations.  As such, fee waivers and payment delays by banks, credit unions and other entities will not be criticized by regulators and examiners where an institution is working with its borrowers in seeking to mitigate risk.  Guidance is attached here on:

  • Accounting for Loan Modifications;
  •  Past Due Reporting;
  • Nonaccrual Status and Charge-Offs; and
  • Discount Window Eligibility

Given the above, our banking and borrower clients impacted by the coronavirus have the ability to proactively seek loan modifications and intervention.  Such assistance will not be treated as troubled debt restructurings.  It is therefore critical for financial institutions to work with borrowers at this time so as to help mitigate the adverse economic effects of COVID-19.   

If you have questions about this alert or need assistance with respect to this guidance, please contact Victoria Reider.

Print to PDFPDFEmail PageEmailPrint HTMLPrint
Search Tips

Our Web site's search function employs a variety of techniques to help you make the most of your queries. In this tips section we use square brackets [ ] to signal queries, so [antitrust and litigation] is one query, while [antitrust] and [litigation] are two.

  • Exact phrases: Eliminate unnecessary search results by surrounding your search phrase with quotation marks. Placing ["project finance"] in quotes will return specific results and discard additional results that simply have the words "project" and "finance" peppered on a page.
  • Wildcard symbol: If you're not exactly sure how a piece of information you want is phrased, use the following symbol (*) as a word root expander. A search for [child*] will find not only "child," but also results with words like "children" and "childhood."

Related Lawyers

Related Industries

Related Practices

Related Offices

Media Contact