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What products may be offered and what type of documentation should financial institutions maintain relative to providing an accommodation to a borrower affected by COVID-19?

Credit unions play an important role in helping members weather through difficult times.   While the Office of Credit Unions does not make lending decisions for any credit union, all credit union activities are subject to examination and the documentation and rationale for any material decisions is subject to such review for its safety and soundness. There is an endless array of possible products/terms an institution could offer to help their members (skip pays, deferrals, extensions, refinances, customized loan products, reduced or waived fees, etal.).  That being said, it is the credit union board and management’s purview to determine what loan products/terms are appropriate for their institution and their members.  The board and management are likewise responsible to manage the risks appropriately.  Credit unions are encouraged to aid their members with reasonable lending decisions, prudent and appropriate for your institution.  Be sure you evaluate the individual risks, the aggregate risks, and any impact on the short- and long-term health of your credit union to ensure its ongoing safety and soundness. Rationale for credit decisions should be clearly documented, and effective systems in place to monitor and control the risks being assumed.