Regulatory Relief Measures
Due to the impact of COVID-19, multiple regulatory agencies are issuing relief that may impact the credit union.
Regulatory Relief Measures: Accounting Considerations
- NCUA - Joint Guidance – Loan Modifications and Reporting - Coronavirus
- NCUA - Joint Guidance – REVISED Loan Modification and Reporting
- NCUA Letter 20-CU-08 – Central Liquidity Facility Membership and Borrowing Authority
- NCUA - Temporary Relief (Loan Participation Limit, Eligible Obligations and Disposal of Assets)
Regulatory Relief Measures: Board Meetings
The NCUA issued a letter to credit unions on March 20, 2020 that allows a federal credit union to adopt by a two-thirds vote of its Board of Directors a bylaw amendment to Article IV without going through the formal bylaw approval process with the NCU The bylaw option, which is provided in detail below, allows for the annual meeting to be conducted virtually.
Section 6. Emergency exception to in-person quorum requirement. This credit union may hold its annual meeting of the members, and special member meetings for authorized purposes other than member expulsion under Article XIV of these bylaws, virtually (webcasts, teleconferences, virtual meeting rooms or similar means that permit members to listen, vote as necessary and participate) and without an in-person quorum if all of the following conditions apply and are certified in meeting minutes by a resolution of the majority of a quorum of the board of directors:
- At least one of the following is located in an area where a federal, state, or local authority has declared a state of emergency or major disaster:
- all or part of a community the credit union serves; or
- the credit union’s headquarters.
- The credit union has the technological capacity to facilitate virtual meeting attendance, voting, and participation.
- Members receive at least seven days’ advance notice of the change to a virtual meeting format and appropriate instructions for how to join, participate, and vote during the virtual meeting.
- The NCUA has issued general or specific guidance notifying the credit union that it is appropriate to invoke this bylaw provision.
An additional option for the credit union may be a delayed annual meeting. The credit union has the ability to postpone its annual meeting date, providing notice
Regulatory Relief Measures: General Operations
- CFPB - FAQs Payments and Deposits Rules – COVID-19
- CFPB - Policy Statement on Remittance Transfers – COVID-19
- CFPB - Treatment of COVID-19 Pandemic Relief Payments
- NCUA – COVID-19 Response – Low Income Credit Union Grants/Loans
- NCUA Joint Guidance – Meeting needs of Members Affected by Coronavirus
- NCUA Letter 02-CU-02 – Actions Related to COVID-19
- NCUA Letter - 20-CU-07 – Summary of CARES Act Relief
- NCUA Letter 20-CU-12 – Outreach Related to COVID-19 Impact
- NCUA Outreach Survey Questions
Regulatory Relief Measures: Loan Origination and Mortgage Servicing
- CFPB - Billing Error Resolution Timeframes in Light of COVID-19
- CFPB - FAQs Open-End (not home secured) Rules – COVID-19
- CFPB - Interim Final Rule – Treatment of Related Loss Mitigation Options under RESPA
- CFPB - Interpretive Rule – TRID Right of Rescission – COVID-19
- CFPB Credit Reporting Guidance (CARES Act)
- ECOA Valuations Rule Flexibility – COVID-19
- Mortgage Servicing FAQs related to COVID-19
- Payment Deferral Repayment Option – COVID-19
- Foreclosure and Eviction Moratorium Extended
- Refinance and Home Purchase Eligibility for Borrowers in Forbearance
- NCUA - Joint Guidance on Mortgage Servicing Rules in Response to COVID-19 and the CARES Act
- NCUA - Joint Guidance - Interagency Statement on Appraisals and Evaluations for Real Estate Related Financial Transactions Affected by the Coronavirus
- NCUA - Joint Statement on Additional Loan Accommodations Related to COVID-19 (8/4/2020)
- NCUA Letter 20-CU-10 – Residential Appraisals Threshold Increase and Other COVID-19 Related Relief Measures
- NCUA Regulatory Alert 20-RA-06 – Treatment of Certain COVID-19 Related Loss Mitigation Options under RESPA (Updated 7/29/2020)
Regulatory Relief Measures: Model Policies
The following policy from CU PolicyPro can be used to help you craft your own policy on this topic:
- Model Policy 7362: Temporary Policy for Loan Modifications and Reporting (COVID-19) Updated 6/30/2020
We recommend reviewing your own policies to see if this policy or similar policies have already been customized and are in use by your credit union. If you're not sure if your credit union subscribes to CU PolicyPro, contact email@example.com for assistance.