Due to the COVID-19 pandemic, the Bank is considering the following with respect to its loan customers:
Deferring scheduled monthly payments for a period of time
Allowing payments of interest only
Allowing interest or payment reductions on a case-by-case basis
How should deferrals or modifications be documented? Can deferred principal and interest payments be capitalized or added to the back-end of the loan?
Is the Bank’s Funds Availability Disclosure prepared for compliance with the new changes to Regulation CC going into effect on July 1, 2020? What changes are to be expected?