[Brent V]

No one knows if the fallout from the COVID-19 Pandemic will last for two or three weeks, or two or three years. Many experts expect the current surge in cases to last until summer, then drop off somewhat for the summer, with another surge in cases in the fall. Also uncertain is how long it will take the economy to rebound from the crisis. The historic recovery time for a pandemic is nine months.

When planning a response to customer and community needs:
• Develop a Pandemic Relief Task Force (senior management, loan staff, loan operations, deposit staff, deposit operations, compliance, risk, legal, audit, IT, operations, security, PR/marketing, etc.);
• Determine and document potential institution, customer and community needs;
• Determine and document assistance financial institution can offer, timeframes available, and exit strategies;
• Evaluate assistance programs/offerings for compliance and risk (UDAP/UDAAP, fair lending, violations of regulations, disclosures, system capabilities, etc.);
• Document all efforts;
• Inform and train applicable staff
• Inform customers/consumers of relief assistance options.

Other items to consider:

• Involve legal counsel
• Cash/Vault management
• Equitable treatment
• Criteria and documentation for assistance
• Interest rate risk and asset liability committee
• Negative rates
• Growing the loan portfolio

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