Ballard Spahr’s Consumer Financial Services, Banking & Financial Institutions, and Mortgage Banking Groups are closely monitoring regulatory developments in connection with the coronavirus (COVID-19) crisis.  To provide one location where members of the banking and consumer financial services industries can access federal regulatory guidance and other information that relates to issues of particular concern to their industries, we have created this COVID-19 Banking and Consumer Financial Services Resource Center.

In addition to the guidance and other information below:

For our clients and others interested in monitoring COVID-19 developments involving debt collection or telemarketing, we have also made a national tracking program available for a monthly flat fee.  For more information, please contact Stefanie Jackman or Lori Sommerfield.

Please note that the guidance below generally appears in reverse chronological order, with the most recent guidance at the top of each category.

FEDERAL RESERVE AND INTERAGENCY

Revised Interagency Statement on Loan Modifications and Reporting For Financial institutions Working with Customers Affected by the Coronavirus (April 7, 2020)

Joint Statement on Supervisory and Enforcement Practices Regarding the Mortgage Servicing Rules in Response to the COVID-19 Crisis and the CARES Act (April 3, 2020)

Agencies announce changes to the community bank leverage ratio (April 6, 2020)

Regulatory Capital Rule: Temporary Exclusion of U.S. Treasury Securities and Deposit at Federal Reserve Banks from the Supplementary Leverage Ratio (April 1, 2020)

Standardized Approach for Calculating the Exposure Amount of Derivative Contracts (March 27, 2020)

Regulatory Capital Rule: Revised Transition of the Expected Credit Losses Methodology for Allowances (March 27, 2020)

Federal agencies encourage banks, savings associations and credit unions to offer responsible small-dollar loans to consumers and small businesses affected by COVID-19 (March 26, 2020)

Federal Reserve offers regulatory reporting relief to small financial institutions affected by the coronavirus (March 26, 2020)

Federal Reserve Statement on Supervisory Activities (March 24, 2020)

Federal Reserve Announces Extensive New Measures to Support the Economy (March 23, 2020)

Federal Reserve Issues FOMC Statement (March 23, 2020) 

Interagency Statement on Loan Modifications and Reporting for Financial Institutions Working with Customers Affected by the Coronavirus (March 22, 2020)

Federal Reserve Board Expands Its Program of Support for Flow of Credit to the Economy by Taking Steps to Enhance Liquidity and Functioning of Crucial State and Municipal Money Markets (March 20, 2020)

Coordinated Central Bank Action to Further Enhance the Provision of U.S. Dollar Liquidity (March 20, 2020)

Joint Statement on CRA Consideration for Activities in Response to the COVID-19 (FIL-19-2020, March 19, 2020)

Federal Reserve Announces the Establishment of Temporary U.S. Dollar Liquidity Arrangements with Other Central Banks (March 19, 2020)

Federal Bank Regulatory Agencies Issue Interim Final Rule for Money Market Liquidity Facility (March 19, 2020)

Federal Reserve Board Broadens Program of Support for the Flow of Credit to Households and Businesses by Establishing a Money Market Mutual Fund Liquidity Facility (MMLF) (March 18, 2020)

Federal Reserve Board Announces Establishment of a Primary Dealer Credit Facility (PDCF) to Support the Credit Needs of Households and Businesses (March 17, 2020)

Federal Banking Agencies Provide Banks Additional Flexibility to Support Households and Businesses (March 17, 2020) 

Federal Banking Agencies Encourage Banks to Use Federal Reserve Discount Window (March 16, 2020)

Federal Reserve Actions to Support the Flow of Credit to Households and Businesses (March 15, 2020)

Federal Reserve Board: Supervisory Practices Regarding Financial Institutions Affected by Coronavirus (SR 20-4/CA 20-3 | March 13, 2020)

Federal and State Banking Agencies Urge Banks to Work with Borrowers Affected by Coronavirus (March 9, 2020)

Updated Interagency Statement on Pandemic Planning (March 7, 2020)

Federal Reserve Board: Supervisory Practices Regarding Banking Organizations and their Borrowers and Other Customers Affected by a Major Disaster or Emergency (SR 13-6/CA 13-3 | March 29, 2013)

FDIC

Joint Statement on the Interaction of the CECL Revised Transition Interim Final Rule with Section 4014 of the Coronavirus Aid, Relief, and Economic Security Act (FIL-32-2020) (March 31, 2020)

Updated Steps to Protect Banks and Consumers and Continue Operations (FIL-29-2020) (March 27, 2020) (Updates
March 16, 2020 statement)

Temporary Alternative Procedures for Sending Supervision-Related Mail and Email to the FDIC (FIL-27-2020) (March 26, 2020)

Identification of Essential Critical Infrastructure Workers During the COVID-19 Response Efforts (FIL-25-2020) (March 26, 2020)

FDIC: Frequently Asked Questions for Financial Institutions and Consumers Affected by the Coronavirus (FIL-18-2020 | March 19, 2020)

FDIC Financial Institutional Letter: Working with Customers Affected by the Coronavirus (FIL-17-2020 | March 13, 2020)

FDIC Statement on Financial Institutions Working with Customers Affected by the Coronavirus and Regulatory and Supervisory Assistance

OCC

OCC COVID-19 (Coronavirus) Information Page

Major Disasters: Interagency Examiner Guidance For Institutions Affected by Major Disasters (OCC Bulletin 2017-61 | December 15, 2017)

Major Disasters: Interagency Examiner Guidance For Institutions Affected by Major Disasters (December 15, 2017)

Responding to a Declaration of a Legal Holiday or a Natural Disaster: Supervisory Guidance on Natural Disasters and Other Emergency Conditions (OCC Bulletin 2012-28 | September 21, 2012)

CFPB

Statement on Supervisory and Enforcement Practices Regarding Quarterly Reporting Under the Home Mortgage Disclosure Act (March 26, 2020)

Statement on Supervisory and Enforcement Practices Regarding Bureau Information Collections for Credit Card and Prepaid Account Issuers (March 26, 2020)

Statement on Bureau Supervisory and Enforcement Response to COVID-19 Pandemic  (March 26, 2020)

CFPB Director Kraninger Statement on Joint HUD-FHFA Announcement on Foreclosure and Eviction Moratorium (March 18, 2020)

CFPB Guidance for Consumers: “Protect Yourself Financially from the Impact of the Coronavirus” (March 16, 2020)d

DEPT. OF EDUCATION

Coronavirus and Forbearance Info for Students, Borrowers, and Parents

COVID-19 (“Coronavirus”) Information and Resources for Schools and School Personnel

NACHA

NACHA Issues Reminder Regarding ACH Responsibilities to Financial Institutions Potentially Impacted by Coronavirus (ACH Operations Bulletin 2-2020 | March 9, 2020) 

FFIEC

FFIEC IT Examination Handbook – Business Continuity Management Booklet (2019)

FFIEC IT Examination Handbook – Business Continuity Management Booklet: Appendix D – Pandemic Planning 

Department of Veterans Affairs

Origination and Appraisal Guidance Based on COVID-19 (Circular 26-20-10, Circular 26-20-11) (March 27, 2020)

HUD

General Coronavirus (COVID-19) Information and Resources

Implementation of Project Catalyst (Mortgagee Letter 2020-07) (April 6, 2020)

FHA’s Loss Mitigation Options for Single Family Borrowers (Mortgagee Letter 2020-06) (April 1, 2020)

HUD Mortgagee Letter 2020-05 (March 27, 2020)  (FHA Guidance on Re-Verification of Employment and Exterior-Only or Desktop Appraisals)

HUD Press Release Announcing Foreclosure and Eviction Moratorium  (HUD No. 20-042 | March 18, 2020)

HUD Mortgagee Letter 2020-04  (March 18, 2020)


Single-Family Housing:

Single-Family Housing Announcement: Continuation of FHA Single Family Business Operations Related to COVID-19 and Temporary Partial Waiver of Servicing Requirements Regarding Face-to-Face Contact with Borrowers (FHA INFO 20-20 | March 13, 2020)

FHA-Approved Mortgagees’ Loss Mitigation Home Retention Options for Assisting Borrowers (FHA INFO 20-18 | March 9, 2020)

Single-Family Housing Guidance for Stakeholders (FHA INFO 20-16 | March 3, 2020)

Questions & Answers for Single-Family Housing Stakeholders (COVID-19)

Multi-Family Housing:

Message from Office of Multi-Family Housing (March 3, 2020)

Questions & Answers for Multi-Family Housing Stakeholders

FHFA

Contingency Plan for Final Delivery Packages (March 13, 2020)

Statement from FHFA Director Mark Calabria on Coronavirus (March 10, 2020)

FREDDIE MAC

Temporary Servicing Guidance Related to COVID-19 (Bulletin 2020-10) (April 8, 2020)

Selling Guidance Related to COVID-19 (Bulletin 2020-8) (March 31, 2020)

Servicing Requirements and Relief Related to COVID-19 (Bulletin 2020-7) (March 25, 2020)

Servicing Update on Payment Deferral and Attachment (Bulletin 2020-6) (March 25, 2020)

Selling Guidance Related to COVID-19 (Bulletin 2020-5) (March 23, 2020)

Temporary Servicing Guidance Related to COVID-19 (Bulletin 2020-4) (March 18, 2020)

Important Seller-Servicer Information on Potential Impacts of COVID-19 (March 10, 2020)

FANNIE MAE

Lender Letter to Single-Family Servicers on Impact of COVID-19 on Servicing (LL-2020-02) (Updated April 8, 2020)

Lender Letter to Single-Family Sellers on Impact of COVID-19 on Originations (LL-2020-03) (Updated March 31, 2020)

Lender Letter to Single-Family Servicers on Impact of COVID-19 on Servicing (LL-2020-02) (Updated March 25, 2020)

Lender Letter to Single-Family Servicers on Payment Deferral  (LL-2020-05) (March 25, 2020))

Lender Letter to Singe-Family Sellers on Impact of COVID-19 on Appraisals (LL-2020-04) (March 23, 2020)

Lender Letter to Single-Family Sellers on Impact of COVID-19 on Originations (LL-2020-03) (March 23, 2020)

FCC

Declaratory Ruling on TCPA “Emergency Purposes” Exception (March 20, 2020)

Lender Letter to Single-Family Sellers on Impact of COVID-19 on Originations (LL-2020-03) (March 23, 2020)

FinCEN

Information for Financial Institutions in Response to the Coronavirus Disease 2019 (COVID-19) Pandemic (April 3, 2020)

OTHER (Note: Please consult state regulator websites for state-specific guidance.)

Conference of State Bank Supervisors: Information on Coronavirus

Joint Statement on Supervisory and Enforcement Practices Regarding the Mortgage Servicing Rules in Response to the COVID-19 Crisis and the CARES Act (April 3, 2020)

NMLS – State Agency Communication/Guidance on Coronavirus (COVID-19)

Consumer Data Industry Association:

Helping Consumer Avoid Credit Problems if They Have Been Impacted by Coronavirus (COVID-19) (March 15, 2020)

Reporting Information on Consumers for Accounts Affected by Natural and Declared Disasters or Accounts in Forbearance (March 9, 2020)