Guidance to Help Financial Institutions and Facilitate Recovery in Areas of Texas Affected by Severe Storms and Flooding
The
Statement of Applicability to Institutions with Total Assets under
Highlights:
* Severe storms and flooding caused significant property damage in areas of
* A federal disaster for selected areas in
* The
* Extending repayment terms, restructuring existing loans, or easing terms for new loans, if done in a manner consistent with sound banking practices, can contribute to the health of the local community and serve the long-term interests of the lending institution.
* Banks may receive favorable Community Reinvestment Act (CRA) consideration for community development loans, investments, and services in support of disaster recovery.
* The
Continuation of FIL-37-2018 (https://www.fdic.gov/news/news/financial/2018/fil18037.html#continuation)
Suggested Distribution:
* FDIC-Supervised Banks (Commercial and Savings) in
Suggested Routing:
* Chief Executive Officer
* Compliance Officer
*
Related Topics:
* Lending
* Investments
* Publishing Requirements
* Consumer Laws
* Community Reinvestment Act
Contact:
*
Note:
FDIC Financial Institution Letters (FILs) may be accessed from the
To receive FILs electronically, please visit www.fdic.gov/about/subscriptions/fil.html.
Paper copies may be obtained through the
Financial Institution Letters
FIL-37-2018
Supervisory Practices Regarding Depository Institutions and Borrowers Affected by Severe Storms and Flooding in Areas of
The
The affected areas in
Lending: Bankers should work constructively with borrowers in communities affected by the severe weather. The
Community Reinvestment Act (CRA): Financial institutions may receive CRA consideration for community development loans, investments, or services that revitalize or stabilize federally designated disaster areas in their assessment areas or in the states or regions that include their assessment areas. For additional information, institutions should review the Interagency Questions and Answers Regarding Community Reinvestment at https://www.ffiec.gov/cra/pdf/2010-4903.pdf at Section 12(g)(4)(ii). For help in identifying community development activities to revitalize or stabilize a disaster area, financial institutions can contact their regional Community Affairs Officer (see www.fdic.gov/consumers/community/offices.html).
Investments: Bankers should monitor municipal securities and loans affected by the severe weather. The
Reporting Requirements:
Publishing Requirements: The
Consumer Laws: Regarding consumer loans, Regulation Z provides consumers an option to waive or modify the three-day rescission period when a "bona fide personal financial emergency" exists. To exercise this option, the consumer must provide the lender with a statement describing the emergency in accordance with the regulation.
Temporary Banking Facilities: The
Footnotes:
1 Modifications of existing loans should be evaluated individually to determine whether they represent troubled debt restructurings (TDRs). This evaluation should be based on the facts and circumstances of each borrower and loan, which requires judgment, as not all modifications are TDRs.
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