I have listed to the 3/19/2020 Metro 2 webinar as well as the 4/2/2020 CDIA webinar. I have also read every piece of guidance I can find, including FAQ 58 and 45 (multiple times), and am not sure exactly what we are REQUIRED to do vs. able to do.

We are offering a six month deferral program for customers affected by COVID-19. There will be nothing due during the deferral period and the maturity date is being extended six months . I understand the interagency regulatory guidance as it relates to delinquency reporting of deferred payments.

What I help with is the Metro 2 formatting requirements. Are REQUIRED use the “D” and/or “AW” (FAQ 58) or if that is an option we may use should we chose to do so?

Thank you for your assistance!

I listened to the CDIA webinar, so did our Loan Operations Manager. She reached out to our Experian contact. From that conversation, we understand, those two codes are not required. Most banks reporting to Experian are using the codes. There is no negative impact on the consumer by using the codes. The codes provide additional info to the user of the report and Experian recommends using the codes. We are using one of the codes, but I can't tell you which one.