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What type of documentation should financial institutions maintain relative to providing an accommodation to a borrower affected by COVID-19?
Banks should maintain appropriate documentation that considers borrowers’ payment status prior to being affected by COVID-19, and borrowers’ payment performance according to the changes in terms provided by the accommodation. Documentation could also include the borrowers’ recovery plans, sources of repayment, additional advances on existing or new loans, and value of collateral. Loan modifications made due to the impact of COVID-19 should be identified as such in the institution’s loan reporting system(s).