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Guidance on Loan Modifications During COVID-19

William G. Spaniel, Senior Vice President and Lending Officer
Supervision, Regulation, and Credit March 23, 2020 — The Federal Reserve continues to evaluate actions to assist during these unique and challenging times.

Last evening, the federal regulatory and state banking agencies issued an interagency statement to encourage financial institutions to work with borrowers affected by COVID-19. Loan modifications as a result of COVID-19 are considered positive actions, and the agencies will not criticize institutions for working with borrowers or direct any COVID-19-related loan modifications automatically categorized as troubled debt restructurings. Further, loans with deferrals due to COVID-19 will not be considered past due during the period of deferral or reported as nonaccrual. Finally, loans restructured in accordance with the interagency statement will be eligible as collateral at the discount window based on the usual criteria. You can read the complete joint press release and interagency statement here.

Should you have any questions relating to these or any other supervisory matters, please reach out to us here. Please note the direct contacts for supervisory matters below.

  • Bill Wisser (215-219-8819), Joanne Branigan (267-761-1913), and Jim Corkery (215-219-9924) for community and regional banking supervision;
  • Robin Myers (215-360-7311) and Anjanette Kichline (215-518-1090) for consumer compliance supervision and matters;
  • Lorraine Lopez (215-764-0678) for large bank supervision;
  • For credit and discount window matters, please call 1-800-372-2011 or visit the FRB Philadelphia Discount Window site here; if needed, you can also contact Gail Todd (215-704-6489).
Sincerely,

William G. Spaniel
Senior Vice President & Lending Officer
Federal Reserve Bank of Philadelphia

  • Last update: March 23, 2020

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