Has anyone seen any guidance regarding credit bureau reporting as a result of the recent hurricanes? We're seeing other FIs are saying that they are suppressing credit bureau reporting for 90 days. Can't find anything that specifically speaks to whether the bank can decide not to report credit bureau status for a period of 90 days as the result of a disaster like these hurricanes. Would appreciate anyone's feedback or direction.

Thank you.

Who is your regulator? This is from the FDIC FIL regarding Harvey:

Prudent efforts by depository institutions to meet customers’ cash and financial needs generally will not be subject to examiner criticism. When consistent with safe and-sound banking practices, these efforts may include:

Waiving ATM fees for customers and non-customers
Increasing ATM daily cash withdrawal limits
Waiving overdraft fees
Waiving early withdrawal penalties on time deposits
Waiving availability restrictions on insurance checks
Easing restrictions on cashing out-of-state and non-customer checks
Easing credit card limits and credit terms for new loans
Allowing loan customers to defer or skip some payments
Waiving late fees for credit card and other loan balances
Delaying the submission of delinquency notices to the credit bureaus

The CDIA is hosting a live Metro 2 webinar today that covers how to report accounts for consumers who were affected by natural disasters.

https://cdia.cdiaonline.org/impak/member...mp;catalog=TELE

http://s3.amazonaws.com/rdcms-cdia/files/production/public/Metro2/2017%20CRRG%20FAQ58_updated.pdf

The FDIC FIL that bigfish mentioned was a joint issuance by the Federal Reserve, OCC, FDIC, and the Conference of State Bank Supervisors. These regulators are encouraging institutions serving the affected areas to proactively meet the financial services needs of their communities.

https://www.federalreserve.gov/newsevents/pressreleases/bcreg20170906a.htm

https://www.occ.treas.gov/news-issuances/news-releases/2017/nr-ia-2017-97.html

Among other things:

Lending: Bankers should work constructively with borrowers in communities affected by Hurricane Irma. The agencies realize that the effects of natural disasters on local businesses and individuals are often transitory, and prudent efforts to adjust or alter terms on existing loans in affected areas should not be subject to examiner criticism. In supervising institutions affected by the hurricane, the agencies will consider the unusual circumstances they face. The agencies recognize that efforts to work with borrowers in communities under stress can be consistent with safe-and-sound banking practices as well as in the public interest.

Community Reinvestment Act (CRA): Financial institutions may receive CRA consideration for community development loans, investments, or services that revitalize or stabilize federally designated disaster areas in their assessment areas or in the states or regions that include their assessment areas. For additional information, institutions should review the Interagency Questions and Answers Regarding Community Reinvestment at https://www.ffiec.gov/cra/qnadoc.htm.

Investments: Bankers should monitor municipal securities and loans affected by the hurricane. The agencies realize local government projects may be negatively affected. Appropriate monitoring and prudent efforts to stabilize such investments are encouraged.

Information on disaster areas can be found at https://www.fema.gov/disasters. Don't forget you may have affected customers even if you don't operate in the disaster areas.