Interagency Statement on Loan Modifications and Reporting: Regulators Issue Statement on Loan Modifications and Reporting for Financial Institutions Working with Customers Affected by COVID-19

Sullivan & Cromwell LLP - March 22, 2020
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On March 22, 2020, federal financial institution regulators and the Conference of State Bank Supervisors published an interagency statement encouraging financial institutions to “work prudently with borrowers who are or may be unable to meet their payment obligations because of the effects” of COVID-19. The Statement notes that (i) the Agencies will not criticize institutions for working with borrowers and (ii) will not direct supervised institutions to automatically categorize all COVID-19 related loan modifications as troubled debt restructurings.