InfoBytes Blog
Maryland banking regulator outlines expectation for working with borrowers
On March 27, Maryland’s Commissioner of Financial Regulation issued an industry advisory with guidance regarding consumer credit for borrowers impacted by Covid-19. The guidance warns licensees against using the health crisis as an opportunity to increase fees or interest rates and instructs them to keep applicants and clients informed of disruptions or delays in credit decisions or changes to times and methods of communication. The advisory also “strongly urges” licensees to takes steps to mitigate the health crisis by, among other things: waiving late fees and online and telephone payment fees; foregoing credit reporting or reporting payment information in a manner that minimizes negative impact on credit histories; offering modification, forbearance or other options to allow borrowers to reduce or defer payments; ensuring that borrowers are able to timely make inquiries and manage their accounts; reaching out to borrowers proactively to provide information on available assistance; and ensuring that all borrower-facing staff are fully informed regarding available assistance and proactive in informing borrowers. Licensees are reminded to comply with applicable Maryland law, including all fair lending requirements, and to retain appropriate documentation to support decisions regarding mitigation offers.