[rcooper]

Expediting New Lending:
Consider that your customers and others in your community will have increased borrowing needs as the crisis evolves. Evaluate
• Current products;
• Product additions, including government relief programs; and
• Methods of eliminating or minimizing delays.

Suggestions for needed products include: Small dollar, unsecured hardship loans (ex: $2,500 to $5,000 for a term of 1 to 5 years). Consider waiving credit score and DTI requirements; Develop a targeted program for low-income and small businesses borrowers adversely affected by the Coronavirus; Build new lending products based on new emergency government loan programs, such as small business loans.

To expedite the process your customer might be able to use a waiver under certain rules such as ECOA appraisal, rescission, TRID (be sure to check the specific requirements for each waiver). Also, consider property inspections and appraisals and how your bank and providers will complete these tasks.

Existing Customers:
Regulators are asking banks to work with customers affected by covid-19. This should be done in a prudent and safe and sound manner, and in compliance with laws/regs. Consider required disclosures (modification v. refinance), will it be a MIRE event that trigger flood requiremetns, HELOC Change in Terms Noticiation might be required, what do you need to consider for accounting (TDRs, past dues, non-accrual, etc.). See the interagency guidance on working with borrowers: https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200322a.htm.

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