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We have been offering payment deferral through a change in terms agreement on consumer mortgage loans due to COVID-19. We are a large servicer under the Reg Z periodic statement rule for consumer mortgage loans. In order to defer the payments, and not show the customer as past due, a statement will not be produced by our core. There has been a lot of communication about the FDIC stressing to banks to work with borrowers. I realize there is a requirement for the statements monthly, but in this scenario if no statements were sent during the 3 or 6 month deferral period, would this be an issue?
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