Since our March 2020 blog post, the
Federal banking and credit union regulators (FRB, FDIC, NCUA, OCC
and CFPB) (collectively, the "Agencies") published
revised guidance clarifying the relationship between the March 22,
2020 Interagency Statement on Loan Modifications and Reporting for
Financial Institutions Working with Customers Affected by the
Coronavirus ("March Guidance") and Section 4013 (here) of the Coronavirus Aid,
Relief, and Economic Security Act (the "CARES Act"),
which was signed into law on March 27, 2020.
As was the case with the March Guidance, the Interagency
Statement on Loan Modifications and Reporting for Financial
Institutions Working with Customers Affected by the Coronavirus
(Revised) (here) ("Revised
Guidance") states that the Agencies continue to
"encourage financial institutions to work prudently with
borrowers who are or may be unable to meet their contractual
payment obligations because of the effects of COVID-19."
According to the
