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Financial Services Law Insights and Observations

Vermont Department of Financial Regulation issues guidance to Vermont chartered banks and credit unions

State Issues Covid-19 Vermont Bank Charter Credit Union Bank Compliance Consumer Finance

State Issues

On March 16, the Vermont Department of Financial Regulation issued guidance to Vermont chartered banks and credit unions regarding working with affected customers. Financial institutions are encouraged to, among other things, waive certain fees (e.g., ATM, overdraft, late payment fees), ease restrictions on cashing out-of-state and non-member checks, increase credit card limits for credit worthy borrowers, and offer payment accommodations. Prudent efforts to modify the terms on existing loans for affected customers will not be subject to examiner criticism and, generally, the department supports and will not criticize efforts to accommodate customers in a safe and sound manner. The guidance also addresses: (i) financial condition review, supervisory response, and regulatory relief; (ii) regulatory reporting requirements; and (iii) alternative service options.