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Financial Services Law Insights and Observations

FDIC updates FAQs for financial institutions affected by Covid-19

Federal Issues Covid-19 FDIC Financial Institutions CRA SBA

Federal Issues

On May 20, the Federal Deposit Insurance Corporation (FDIC) updated its frequently asked questions  issued to financial institutions affected by Covid-19 (previously covered here, here, and here). The updated FAQs provide guidance on Community Reinvestment Act requirements, including, among other things, (i) whether Covid-19-affected states and jurisdictions are considered CRA designated disaster areas, (ii) how activities undertaken in response to Covid-19 that are responsive to community needs will be considered in CRA examinations, and (iii) whether bank loans made under the Paycheck Protection Program or Main Street Lending Program are eligible for CRA consideration.