Payment accommodations. The FDIC encourages financial institutions to provide payment accommodations to those affected by COVID-19. For example, financial institutions may want to consider addressing any deferred or skipped payments by either extending the original maturity date or by making those payments due in a balloon payment at the maturity date of the loan. Borrowers should be provided with accurate disclosures that are consistent with federal and state consumer protection laws to ensure customers are clear on the terms of any accommodations.

Reporting delinquent loans. Borrowers who were current before becoming affected by COVID-19 and then receive payment accommodations as a result of COVID-19 generally would not be reported as past due.

Documentation. Financial institutions should maintain appropriate documentations that considers the borrowers' payment status prior to being affected by COVID-19 as well as the borrowers' payment performance according to any changes in terms provided by a payment accommodation. Documentation could also include the borrowers’ recovery plans, sources of repayment, additional advances on existing or new loans, and value of the collateral.

Troubled debt restructurings. Financial institutions should determine whether loans that receive payment accommodations as a result of COVID-19 should separately be reported as troubled debt restructurings in separate memoranda items for such loans in regulatory reports. However, deferred, extended, or renewed loans at a stated interest rate equal to the current interest rate for new debt with similar risk is not reported as a troubled debt restructuring.

Nonaccrual status, allowance for credit losses, allowance for loan and lease losses, and charge-offs. Financial institutions should refer to the applicable regulatory reporting instructions, as well as its internal accounting policies, in determining whether to report loans with COVID-19 accommodations as nonaccrual assets in regulatory reports. Institutions should also maintain an appropriate allowance for loan and lease losses for such loans, maintain appropriate accrual status on affected credits, and appropriately recognize credit losses according to their charge-off policies as soon as a loss can be estimated.

Alternative service options. Financial institutions can limit access to branch offices and require customers to use a drive-up window to protect employees and customers.

Filing applications. The FDIC does not require financial institutions impacted by COVID-19 to file applications for temporary office closures. However, financial institutions should check with their state regulator to determine whether state law and regulations require applications to be filed. They should also notify their primary federal and state regulator and their customers of temporary closure of an institution’s facilities and the availability of any alternative service options as soon as practical.

Difficulties filing reports. The FDIC encourages institutions affected by COVID-19 to take reasonable and prudent steps to comply with regulatory reporting requirements to the extent possible, and to contact their Regional Office if they are unable to do so. The FDIC will take into account each financial institution's particular challenges when considering whether to give forbearance in meeting regulatory reporting requirements.

Security. The FDIC encourages financial institutions to provide appropriate training to staff and to take appropriate measures to maintain the security of their staff and customers.

Cash management. Financial institutions may consider reminding customers about the safety of their money at an FDIC-insured bank.

Community bank leverage ratio election. It is up to the individual financial institution to decide whether to elect the community bank leverage ratio (CBLR). The decision to elect CBLR for the March Call Report is not binding, and may be reversed in a subsequent quarter.

Real property inspections. Financial institutions should consult with appraisers and real estate inspectors about alternative arrangements if the property owner does not want to permit access to the property's interior due to COVID-19 concerns.

Real property appraisals. Financial institutions should consult with appraisers about short-term, temporary reductions in income as a result of COVID-19.

The Bank Secrecy Act. Financial institutions should contact their regional office to discuss issues with filing Bank Secrecy Act reports.