The March 2020 Coronavirus Aid, Relief, and Economic Security
Act (CARES Act) contains a number of provisions that help borrowers
with federally backed mortgage loans. Among these are forbearance
protections for borrowers with single-family loans and multifamily
loans. However, only one of the forbearance provisions has a
clearly defined period when the rights are available. As detailed
below, the various federal agencies are taking a piecemeal approach
to forbearances, resulting in differing deadlines for different
types of federally backed mortgages and lots of confusion for the
servicers who have to implement the forbearance programs.
Multifamily Forbearances: Section 4023 of the
CARES Act allows borrowers with federally backed multifamily
mortgage loans to seek forbearance because of a COVID-19 related
financial hardship for 30 days, with the right to extend the
forbearance period for two additional periods of 30 days each.
Section 4023's "covered period" is
