COVID-19 Regulatory FAQs

May 29, 2020 - 1 min read

Since the declaration of COVID-19 as a major disaster, the federal regulatory agencies have issued multiple frequently asked questions (FAQs) across various issuances. The FDIC has compiled these FAQs, in addition to specific guidance for FDIC- regulated institutions, into one document as of May 4, 2020. The FAQs were initially released on March 19, to address…

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Protecting Tenants Against Foreclosure

May 25, 2020 - 1 min read

Institutions are reminded that notwithstanding any executive orders regarding foreclosures or evictions regarding shorter time periods, if an institution becomes the successor in interest of a dwelling or residential real property in which a bona fide tenant resides, such tenant must be provided with a notice to vacate at least 90-days prior to the effective…

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Secondary Market

May 22, 2020 - 2 min read

Investors are offering their own relief options. Institutions must refer to the applicable secondary market investor guidelines. Note that under the CARES Act, section 4022 requires that, for Federally-backed mortgage loans (loans insured or guaranteed by certain U.S. government agencies and programs, as well as loans made by the Department of Agriculture and loans sold to…

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Federal Agency Guidance

May 20, 2020 - 1 min read

The federal agencies have published several statements regarding issues and concerns facing financial institutions during this time. The following links lead to FDIC websites, although these are interagency statements. Encouraging Financial Institutions to Meet Financial Needs of Customers and Members Affected by Coronavirus (March 9, 2020) https://www.fdic. gov/news/news/press/2020/ pr20025.html Financial Institutions Working with Customers Affected…

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