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Financial Services Law Insights and Observations

FDIC announces Pennsylvania disaster relief

Federal Issues FDIC Disaster Relief Pennsylvania Mortgages Regulation Z Bank Regulatory

Federal Issues

On September 16, the FDIC issued FIL-67-2021 to provide regulatory relief to financial institutions and help facilitate recovery in areas of Pennsylvania affected by Hurricane Ida. The FDIC acknowledged the unusual circumstances faced by institutions in affected areas, and suggested institutions take certain steps to meet the needs of their communities and keep the FDIC informed of business impacts. These steps include (i) working with borrowers to adjust or alter loan terms in a safe and sound manner; (ii) identifying potential community development activities to revitalize or stabilize the disaster area (which the FDIC noted may receive favorable CRA consideration); (iii) monitoring potentially impacted municipal securities and loans; (iv) notifying the FDIC of delays in meeting filing and publishing requirements, or in the event temporary banking facilities are needed; and (v) processing consumer requests under Regulation Z for a waiver or modification of the three-day rescission period for dwelling-secured loans in the event of a “bona fide personal financial emergency.”

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