Updated March 25, 2020
As we now face unparalleled challenges in our world, the Bluegrass Community Bankers Association stands with you. This is our chance to demonstrate the value of COMMUNITY banking.The dynamic, hour-by-hour changes in this fast moving response to the pandemic is leaving us all somewhat anxious and stressed. That is to be expected. However, our communities will look to us to lead by example, to put our words into action and to stand strong on behalf of our neighbors. As an organization, the BCBA has been active in seeking clarity and direction from our governmental and regulatory leaders. Below is some information that we are aware of:
1) ISSUED March 25: Statement from Commissioner Vice on Loan Modifications and Regulatory Relief
The Kentucky Department of Financial Institutions (DFI) will support Kentucky chartered banks that implement reasonable actions to help customers while Kentucky is operating under a State of Emergency related to COVID19. The DFI will take no actions or criticize a Kentucky chartered bank for modifying loan terms without obtaining a new or updated appraisal to help customers during the COVID 19 State of Emergency. Furthermore, the DFI encourages Kentucky chartered banks to work with federal bank regulators to implement appropriate regulatory relief relating to other federal statutes, such as right of rescission and flood insurance.
2) ISSUED March 23: Interagency Statement on Loan Modifications by Financial Institutions Working with Customers Affected by the Coronavirus
The FDIC, the Board of Governors of the Federal Reserve System (FRB), the Office of the Comptroller of the Currency, the National Credit Union Administration, the state banking regulators, and the Consumer Financial Protection Bureau issued the Interagency Statement on Loan Modifications and Reporting by Financial Institutions Working with Customers Affected by the Coronavirus to encourage financial institutions to work constructively with borrowers impacted by the Coronavirus Disease 2019 (referred to as COVID-19) and provide additional information regarding loan modifications.
Statement of Applicability to Institutions under $1 Billion in Total Assets: Read the FIL
3) ISSUED March 16: FDIC Statement on Financial Institutions Working with Customers Affected by the Coronavirus and Regulatory and Supervisory Assistance.
The FDIC issued FIL 20017a, addressing the potential for the Coronavirus Disease 2019 (referred to as COVID-19) to adversely affect the customers and operations of financial institutions. To read the complete FIL, click here.
Community banks in Kentucky are strong, well prepared and equipped to help lead our communities and Commonwealth during this uncertain time. We all need to make sure we consistently communicate that message to our customers and our communities. The BCBA stands ready to help our member banks in any way we can as we navigate these uncharted waters.