We're in a federally-declared disaster area from a storm last month which will have significant impacts to our borrowers and their loans. We're considering granting modifications to consumer and commercial borrowers, to extend them some more time. Underwriting will not occur, although there will be a back-office process to review the extensions granted by the loan officers in the field just to ensure they comply with our internal program (for instance, if we grant 90 days, we will verify that the field didn't grant them 2 years). Do you agree that under FinCEN's FIN-2018-R003 ruling, we are not required to perform any documentation or verification of beneficial ownership?

"Under 31 U.S.C. § 5318(a)(7) and 31 CFR § 1010.970(a), FinCEN has the authority to grant exceptions to the requirements of 31 CFR Chapter X....Accordingly, FinCEN is granting exceptive relief to covered financial institutions from the Beneficial Ownership Rule’s requirement to identify and verify beneficial ownership information on or after May 11, 2018, as a result of the following: (1) CD
rollovers; (2) loan renewals, modifications, and extensions (e.g.,, setting a later payoff date) that do not require underwriting review and approval; (3) commercial line of credit or credit card account renewals, modifications, or extensions (e.g., , setting a later payoff date) that do not require underwriting review and approval...." (https://www.fincen.gov/sites/defaul...pliance%20Date%20CDs_final%20508%202.pdf)

Both exceptions say "do not require underwriting review and approval" and we will have approval back-office, but not underwriting.

P.S. This will be a signed deferral agreement - but, no underwriting.

That is an "and" and not an "or".

(2) loan renewals, modifications, and extensions (e.g.,, setting a later payoff date) that do not require underwriting review and approval;