Agencies Finalize Three Rules Issued as Part of Pandemic Response

The federal banking agencies today finalized several rules originally issued as interim final rules during the spring weeks of the emergency coronavirus response. The final rules:

In its comment letter on the latter rule, the American Bankers Association warned of potential unintended consequences that could arise from the 25% add-back applied across the board without regard to lending product, as CECL credit loss provisions are likely to adversely impact consumer lending significantly more than commercial lending. The agencies noted the comments but did not change the final rule in response.