Topic: Pandemic Preparedness and Response
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We are considering a COVID-19 loan modification program for existing clients that would allow for skipped payments, no credit reporting for past due amounts, extended pay periods, etc. Will we still be required to obtain flood determinations due to the modifications? We are aware of the interagency guidance stating that such modifications will not automatically be categorized as troubled debt restructurings.
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Whether such a modification would require you to a obtain a flood determination depends on the nature of the modification and whether you are able reuse a previous flood determination. This is the case regardless of whether the modification is categorized as a troubled debt restructuring. However, under recent FDIC guidance, you may be able…
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With respect to Illinois law, please offer any insights into granting borrowers’ requests to skip monthly payments on adjustable rate mortgages (ARMs) with thirty-year terms or monthly interest payments on home equity lines of credit (HELOCs). For the ARMs, the skipped payments would be added to the end of the scheduled loan payments, and for the HELOCs, the skipped interest-only payments would be spread over a few months to avoid the borrower being hit with one large interest payment.
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Illinois law does not expressly address mutually agreed-upon skipped payments — whether offered by the bank as a “skip-a-payment” program or when requested by the borrower. However, such arrangements are permissible in Illinois. It is important that your “skip-a-payment” agreement does not have the effect of canceling the original loan and substituting it for a…
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We are an Indiana savings bank. We also have branches in Illinois, and we are still open for business but have closed our branch lobbies to foot traffic. We have notified the FDIC and the Indiana Department of Financial Institutions of this modification of our services, and we are planning to send a courtesy notice to the Illinois Department of Financial and Professional Regulation (IDFPR). Where should such notices be directed, and has the IDFPR issued any FAQs for banks or hosted any calls related to the COVID-19 pandemic?
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The IDFPR is accepting notices of modifications in branch services at [email protected]. The IDFPR issued written guidance on lobby closure issues related to the COVID-19 pandemic on March 16, 2020. The IDFPR guidance, copied below, states that banks may close their lobbies in response to the COVID-19 pandemic without obtaining an official proclamation from the…
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Are we allowed to close our branch lobbies during the Coronavirus (COVID-19) pandemic while keeping our drive-through, night drop and electronic banking services available and allowing customers to call for an appointment at a branch? We have a branch with a lobby, night drop and ATM, but no drive-through — would we be allowed to close this lobby? We would put information about the closures on our doors and on our website. Is anything else needed, and should we contact our regulators?
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We recently were advised by the Illinois Department of Financial and Professional Regulation (IDFPR) Division of Banking that banks are permitted to close their lobbies in response to the Coronavirus (COVID-19) pandemic without obtaining an official proclamation from the IDFPR — provided the branches remain open in some matter (for example, by providing drive-through teller…
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We are a state bank and are creating a pandemic disaster recovery guide for our retail department. Is it mandatory for us to make safe deposit box entry available, and must we provide mailed ten-day certificate of deposit (CD) renewal notices? Are there any guidelines for reducing our typical services to a minimum?
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Generally, your obligations to your safe deposit box customers will be dictated by the terms of your safe deposit box rental agreements, and Regulation DD dictates the disclosures you must provide to consumers with CD accounts. However, in the event of a viral pandemic, your bank’s ability to provide certain services or to comply with…