AGENCY RESPONSE MATRIX

Explanation on how EIP relates to delinquent debts.

Informative answers to frequently asked questions on SBA-guaranteed Paycheck Protection Program loans.

Under the Borrower Protection Program, the CFPB will make complaint information and analytical tools available to FHFA via a secure electronic interface. Meanwhile, the FHFA will make available to the bureau information about forbearances, modifications and other loss-mitigation initiatives undertaken by Fannie Mae and Freddie Mac.

Updated and revised FAQs, intended to aid consumers and lenders.

Nacha has developed updated FAQs based on information it has provided, information it has learned, and inquiries posed to Nacha by industry participants.

Temporarily allows banks to defer appraisals and evaluations for residential or commercial real estate transactions for up to 120 days during the COVID-19 national emergency. The rule will expire on Dec. 31, 2020.

A one-stop shop of federal programs that can be used by rural communities, organizations and individuals affected by the COVID-19 pandemic. The COVID-19 Federal Rural Resource Guide is focused on rural leaders looking for federal funding and partnership opportunities to help address the pandemic.

Formalized steps to make it easier for consumers to use prepaid accounts to receive pandemic-relief payments, including Economic Impact Payments. The CFPB's interpretive rule concludes that, if certain conditions are met, certain pandemic-relief payments are not “government benefits” for purposes of Regulation E.

Formalized steps to make it easier for consumers to use prepaid accounts to receive pandemic-relief payments, including Economic Impact Payments. The CFPB's interpretive rule concludes that, if certain conditions are met, certain pandemic-relief payments are not “government benefits” for purposes of Regulation E.

Informative answers to frequently asked questions on its new liquidity facility for SBA-guaranteed Paycheck Protection Program loans.

Consumer Financial Protection Bureau issued a policy statement extending a community bank exemption to its rule on remittance transfers due to the COVID-19 pandemic. The exception—which allows community banks to provide estimates on required disclosures if certain criteria are met—is set to expire on July 21. Under the new policy statement, the CFPB will neither cite supervisory violations nor initiate enforcement actions against insured institutions for continuing to provide estimates under the temporary exception through the end of the year.

FAQs on COVID-19 pandemic with answers to community banker questions about Economic Impact Payments to taxpayers sent via ACH. The FAQs include information on: what to do when an ACH payment hits a closed account, garnishment exemptions, and more.

Interim final rule encourages lending to small businesses through the SBA's PPP. The rule modifies the agencies' capital rules to neutralize the regulatory capital effects of participating in the Federal Reserve's PPP facility because there is no credit or market risk in association with PPP loans pledged to the facility. The interim final rule also clarifies that a zero percent risk weight applies to loans covered by the PPP for capital purposes.

1. Supplying liquidity to participating financial institutions through term financing backed by PPP loans to small businesses.

2. purchase of up to $600 billion in loans through the Main Street Lending Program.

3. expanding the size and scope of the PMCCF, SMCCF, and TALF, up to $850 billion.

4. establishing a Municipal Liquidity Facility that will offer up to $500 billion in lending to states and municipalities.

Statement incorporates CARES Act provisions, permitting banks to suspend classification of loan modifications as TDRs. The revised statement also provides interpretations on past due and nonaccrual regulatory reporting of loan modification programs. Examiners will exercise judgment in reviewing loan modifications and will not automatically adversely risk rate credits that are affected by COVID-19.

The notice provides certain regulatory relief under the risk-based approach to BSA compliance, including exempting from beneficial ownership requirements new loans extended to existing customers under CARES Act. FinCEN also suspends implementation of the February 6, 2020 ruling (FIN-2020-R001) on CTR filing obligations when reporting transactions involving sole proprietorships and entities operating under a “doing business as” (DBA) name until further notice.

The Federal Reserve will establish a facility to provide term financing backed by PPP loans.

Under the interim final rules, the community bank leverage ratio will be 8 percent beginning in the second quarter and for the remainder of calendar year 2020, 8.5 percent for calendar year 2021, and 9 percent thereafter. The interim final rules also maintain a two-quarter grace period for a qualifying community banking organization whose leverage ratio falls no more than 1 percent below the applicable community bank leverage ratio.

Inform servicers of the agencies’ flexible supervisory and enforcement approach during this emergency regarding certain consumer communications required by the mortgage servicing rules. This Joint Statement is intended to clarify the application of the Regulation X mortgage servicing rules and the agencies’ approach to supervision and enforcement related to the rules during this emergency, including those applicable to short-term options.

The Paycheck Protection Program and loan forgiveness are intended to provide economic relief to small businesses nationwide adversely impacted under COVID-19 Emergency Declaration. This interim final rule outlines the key provisions of SBA’s implementation of sections 1102 and 1106 of the CARES Act in formal guidance.

The Bureau reiterates its prior guidance encouraging financial institutions to work constructively with borrowers and other customers affected by COVID-19 to meet their financial needs. The Bureau expects furnishers to comply with the CARES Act and will work with furnishers as needed to help them do so.

To ease strains in the Treasury market resulting from the coronavirus and increase banking organizations' ability to provide credit to households and businesses, the Federal Reserve Board on Wednesday announced a temporary change to its supplementary leverage ratio rule. The change would exclude U.S. Treasury securities and deposits at Federal Reserve Banks from the calculation of the rule for holding companies, and will be in effect until March 31, 2021.

Borrowers with a financial hardship that makes them unable to pay their mortgage due to the COVID-19 National Emergency, mortgage servicers must extend deferred or reduced mortgage payment options - called forbearance - for up to six months, and must provide an additional six months of forbearance if requested by the borrower.

The flexibilities announced by the Enterprises include:

-Allowing desktop appraisals on new construction loans;

- Allowing flexibility on demonstrating construction has been completed (alternative to the Completion Report);

-Allowing flexibility for borrowers to provide documentation (rather than requiring an inspection) to allow renovation disbursements (draws); and

Expanding the use of power of attorney and remote online notarizations.

Banks are free to suspend enforcement of the “six convenient transfer” monthly limit for any account that they do not plan to report as a “savings deposit” on their FR 2900 deposit reports.  Depository institutions may immediately allow an unlimited number of transfers from accounts that they have been reporting as “savings deposits” and then work with their local Reserve Bank deposit reporting teams to develop a plan for reporting those accounts as “transaction accounts.” 

FIMA Repo Facility establishes a temporary repurchase agreement facility for foreign and international monetary authorities.

Allows FIMA account holders (central banks and other international monetary authorities with accounts at the NY Fed) to temporarily exchange their U.S. Treasury securities held with the Federal Reserve for U.S. dollars, which can then be made available to institutions in their jurisdictions.

Originally to be effective April 1, the Board finalized a revised framework that simplifies and increases the transparency of its rules for determining when one company controls another company for purposes of the Bank Holding Company Act and Home Owners' Loan Act.

The joint statement clarifies the interaction between the interim final rule that provides a five-year transition period for the impact of the current expected credit loss methodology (CECL) on regulatory capital and the temporary CECL relief provided by CARES Act.

The agencies are adjusting their calculation for credit concentration ratios used in the supervisory process. The adjustment is in response to changes in the capital information available after the implementation of the Community Bank Leverage Ratio (CBLR) rule. Effective March 31, 2020, for supervisory purposes, examiners will calculate credit concentration ratios using tier 1 capital plus the appropriate allowance for loan and lease losses or the allowance for credit losses attributed to loans and leases (as applicable) for the denominator.

The interim final rule provides banking organizations that implement CECL before the end of 2020 the option to delay for two years an estimate of CECL’s effect on regulatory capital, relative to the incurred loss methodology’s effect on regulatory capital, followed by a three-year transition period

Supervisory and other FDIC activities at financial institutions will be conducted off-site for an additional two weeks through April 12, and staff has individually contacted institutions with ongoing or upcoming examination activities about their communication preferences during this period.

The agencies will not take action against any institution for submitting its March 31, 2020, Consolidated Reports of Condition and Income (Call Report) after the official filing deadline, provided the report is submitted within 30 days of the official filing deadline.

FDIC is encouraging financial institutions and other parties to use alternative procedures to send the agency official mail related to supervisory matters and to use secure email to send official supervisory correspondence.

The agencies encourage financial institutions to continue to offer small-dollar loans in a manner that is consistent with safe-and-sound banking practices, provides fair treatment of consumers, and complies with applicable statutes and regulations, including consumer protection laws.

The financial services sector is identified as a Critical Infrastructure Sector by the Department of Homeland Security. A letter from company leadership explaining that the identified worker carrying the letter is a critical infrastructure worker who needs to be allowed access to their place of work, and the attached documents may assist essential critical infrastructure workers needing to travel inside restricted areas in order to support critical infrastructure.

The Federal Reserve will not take action against a financial institution with $5 billion or less in total assets for submitting its March 31, 2020, Consolidated Financial Statements for Bank Holding Companies (FR Y-9C) or Financial Statements of U.S. Nonbank Subsidiaries of U.S. Bank Holding Companies (FR Y-11) after the official filing deadline, as long as the applicable report is submitted within 30 days of the official filing due date.

1) Temprorary cessation of quarterly HMDA reporting on DFA 1071

2) No expectation to report under CARD Act

3) Postponed data collection

4) Postponed survey of PACE loans

The Department will not bring enforcement actions against any public or private employer for violations of the Act occurring within 30 days of the enactment of the FFCRA, i.e. March 18 through April 17, 2020, provided that the employer has made reasonable, good faith efforts to comply with the Act.

Federal Reserve will temporarily reduce its examination activities, with the greatest reduction in activities occurring at the smallest banks.

Federal Reserve institutes six-month delay in the planned implementation of policy changes to procedures governing the provision of intraday credit to U.S. branches

Establishing Exchange Stabilization Fund (ESF) to channel equity to new programs that will provide up to $300 billion in new financing to employers, consumers, and businesses.

Fed maintains the federal funds rate in a target range of 0 to 1/4 percent; increases holdings of Treasury securities and agency mortgage-backed securities (MBS); includes purchases of agency commercial mortgage-backed securities in its agency mortgage-backed security purchases; continue conducting term and overnight repurchase agreement operations; conduct overnight reverse repurchase operations at an offering rate of 0.00 percent.

Federal Housing Finance Agency (FHFA) is announcing that the Enterprises will offer multifamily property owners mortgage forbearance with the condition that they suspend all evictions for renters unable to pay rent due to the impact of coronavirus.

FHFA directed Fannie Mae and Freddie Mac (the Enterprises) to provide alternative flexibilities to satisfy appraisal requirements and employment verification requirements.

FHFA has authorized Fannie Mae and Freddie Mac (the Enterprises) to enter into additional dollar roll transactions (dollar roll transactions provide mortgage-backed securities investors with short-term financing of their positions, providing liquidity to these investors).

Disaster relief loan deferments through December 31, 2020, will be automatic. Borrowers of home and business disaster loans do not have to contact SBA to request deferment.

Will not criticize institutions for prudent loan modifications and will not direct supervised institutions to automatically categorize COVID-19-related loan modifications as troubled debt restructurings (TDRs); Confirmed with staff of the Financial Accounting Standards Board (FASB) that short-term modifications made on a good faith basis in response to COVID-19 to borrowers who were current prior to any relief are not TDRs; Views that modification efforts described in the interagency statement for borrowers of one-to-four family residential mortgages where loans are prudently underwritten and not past due or carried in nonaccrual status do not result in loans being considered restructured or modified for the purpose of respective risk-based capital rules;

Extending the comment period on its Supplemental Notice of Proposed Rulemaking (SNPRM) implementing the Fair Debt Collection Practices Act (FDCPA). The SNPRM, which proposed to require debt collectors to make certain disclosures when collecting time-barred debts

The interim final rule revises the definition of eligible retained income to the greater of (1) a banking organization's net income for the four preceding calendar quarters, net of any distributions and associated tax effects not already reflected in net income, and (2) the average of a banking organization's net income over the preceding four quarters. The revised definition of eligible retained income is intended to strengthen the incentives for banking organizations to use their capital buffers as intended in adverse conditions and serve as a financial intermediary and source of credit to the economy.

The agencies encourage financial institutions to work with affected customers and communities, particularly those that are low- and moderate-income. Pursuant to the Community Reinvestment Act (CRA), the agencies will provide favorable consideration of certain retail banking services, retail lending activities, and community development activities.

FDIC is providing FAQs to financial institutions and consumers affected by COVID-19 that address some of the questions received to-date, and will continue to update these FAQs, as needed.

MMLF will make loans available to eligible financial institutions secured by high-quality assets purchased by the financial institution from money market mutual funds.

Federal Housing Finance Agency (FHFA) has directed Fannie Mae and Freddie Mac (the Enterprises) to suspend foreclosures and evictions for at least 60 days due to the coronavirus national emergency. The foreclosure and eviction suspension applies to homeowners with an Enterprise-backed single-family mortgage.

Authorized the Federal Housing Administration (FHA) to implement an immediate foreclosure and eviction moratorium for single family homeowners with FHA-insured mortgages for the next 60 days. Halt all new foreclosure actions and suspend all foreclosure actions currently in process; and Cease all evictions of persons from FHA-insured single-family properties.

The PDCF will offer overnight and term funding with maturities up to 90 days. Credit extended to primary dealers under this facility may be collateralized by a broad range of investment grade debt securities, including commercial paper and municipal bonds, and a broad range of equity securities.

CPFF will provide a liquidity backstop to U.S. issuers of commercial paper through a special purpose vehicle (SPV) that will purchase unsecured and asset-backed commercial paper rated A1/P1.

Encouragement for financial institutions to work with customers and communities affected by COVID-19 in a prudent manner; to work with all borrowers; prudent efforts to modify the terms on existing loans for affected customers will not be subject to examiner criticism

Economic Injury Disaster Loan assistance declaration issued by the SBA makes loans of up to $2 million available to small businesses and private, non-profit organizations in designated areas of a state or territory to help alleviate economic injury caused by the Coronavirus (COVID-19).