[mandy]

Typically we charge a fee for rate modifications, but it doesn’t seem entirely prudent to do so now. Regarding a simple rate change modification, (not a TDR or deferrals to assist those in need), and given the boom of customers wishing to modify their rates to take advantage of the market, what is everyone doing fee wise? And so I know we are doing it correctly, are there restrictions to charging a fee or specific disclosures that must be given? Thanks!

[rcooper]

We anticipate you have criteria for those who have been affected by the pandemic and need assistance. For those customers, I would not advise charging a fee. Whether formalized or not, you probably have a team of individuals in your institution, which I’m guessing you are likley a part of, that is working on determine what kind of assistance to offer and how to determine to whom the assistance is extended. There should be a process for qualifying and documentation who qualifies. Perhaps this is as simple as a questionnaire. For those not negatively affected by the pandemic, I do not see an issue with charging your normal fee.

The regulators are encouraging banks to communicate with them. That might be something you want to do as you work through the details of your assistance program so there are no surprises at the next exam.

[Author]

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