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Potential Tropical Storm Moving Toward Florida

Posted on September 13, 2019September 14, 2019 by Safeguard

Updated 9/14/19: The Orlando Sentinel published a report offering the latest forecast information for Tropical Storm Humberto.

Tropical Storm Humberto forms, path steers away from Florida (full report)

Disaster Alert
September 13, 2019

Source: The Weather Channel

Additional Resource:

Coastal County ZIP Codes:

NOTE: This has not yet been declared a FEMA Major Disaster.

At a Glance

Potential Tropical Cyclone Nine is over the central Bahamas.
It will likely develop into a tropical depression or tropical storm later Friday.
A tropical storm warning has been issued for the northwestern Bahamas.
A tropical storm watch has been posted for portions of the Florida east coast.
The future track of this system is very uncertain.
Interests from the northern Gulf Coast to Florida to the Carolinas should monitor the forecast closely.
The potential tropical cyclone will earn the name Humberto if it attains tropical storm status.

Potential Tropical Cyclone Nine is likely to become a tropical depression or tropical storm by Friday night and will pose a threat to the Bahamas, Florida and possibly other parts of the southern United States, including areas devastated by Hurricane Dorian.

A “potential tropical cyclone” allows the National Hurricane Center (NHC) to issue advisories, watches and warnings on systems that have yet to develop but pose a threat of bringing tropical-storm-force (39-plus mph) or hurricane-force (74-plus mph) winds to land areas within 48 hours.

Potential Tropical Cyclone Nine is moving very slowly toward the northwestern Bahamas and producing clusters of showers and thunderstorms over the islands. These convective clusters have become more persistent over the past day.

This disturbance is expected to resume a northwestward motion later today and an increase in forward speed is anticipated this weekend.

The NHC says environmental conditions are favorable for a tropical depression or tropical storm to form within the next day or so and gives this system a high chance of development as it crawls toward the northwestern Bahamas.

It will earn the name Humberto if it does attain tropical storm status. This system is expected to become a hurricane early next week when it is off the Southeast coast.

For full report, please click the source link above.

Twisters Damage South Dakota Homes

Posted on September 12, 2019September 12, 2019 by Safeguard

Disaster Alert
September 11, 2019

Source: The Weather Channel

Approximate locations experiencing home damage (tornado, straight-line winds):

South Dakota
Sioux Falls (Minnehaha County, 57103, 57104, 57105, 57106, 57107, 57108, 57110)

NOTE: This has NOT yet been declared a FEMA Major Disaster.

At a Glance

Three tornadoes and damaging straight-line winds struck Sioux Falls, South Dakota, Tuesday night.
Southern sections of the city have been hardest hit.
More than three dozen buildings were damaged.
Most of the city’s warning sirens didn’t sound.

As tornadoes and straight-line winds blew off roofs and destroyed buildings Tuesday night in Sioux Falls, South Dakota, most of the city’s warning sirens failed to sound.

Sioux Falls Mayor Paul TenHaken said Wednesday that the problem was caused when an employee in the city’s 911 dispatch center didn’t follow the proper procedure to initiate all 77 of the city’s warning sirens, the Argus Herald reported. Instead, only one quarter of them were activated.

“Quite honestly what happened with the system is we just had a human error issue,” TenHaken said.

In a morning press conference, he had called the incident with the outdoor warning system a “breach of protocol” and said the city was investigating, according to the Associated Press.

Most of the sirens were sounded in the southwest part of the city, which sustained much of the major damage, TenHaken said. But sirens are supposed to sound city-wide.

“We’re doing an internal investigation on why that happened, why the existing protocol was not followed,” TenHaken told the Argus Leader. “The city recognizes that, is owning that, and we’ll be taking the proper steps to rectify that.”

Todd Heitkamp, the meteorologist-in-charge at the Sioux Falls National Weather Service, told the newspaper it’s important to note that outdoor warning sirens aren’t specifically tornado sirens. The system is intended to warn people who are outside that a life-threatening situation is happening.

“I can tell you from my stance last night, I heard the siren only because I stood outside wondering what was going to happen right before the storm hit my house,” Heitkamp said.

A preliminary survey from the National Weather Service confirmed that three EF2 tornadoes had touched down, with estimated winds ranging from 125 mph to 130 mph. The NWS said eight people were injured.

Sioux Falls Fire Chief Brad Goodroad said 37 buildings collapsed or now have issues with structural integrity.

Some people were trapped under collapsed structures and had to be rescued, according to the Argus Leader. Downed trees and powerlines hindered emergency response in much of south Sioux Falls.

Homes and a hospital were damaged in southern sections of the city.

Avera Behavioral Health Hospital had a portion of its roof torn off by the storms, according to the Argus Leader. Seven patients from the hospital were transported to Avera Heart Hospital, spokeswoman Michelle Pellman told the Argus Leader.

The National Weather Service says the destructive storms hit about 11:45 p.m. CDT Tuesday night.

For full report, please click the source link above.

FHFA: Statement of Director Mark A. Calabria

Posted on September 11, 2019 by Safeguard

Investor Update
September 10, 2019

Source: FHFA

Chairman Crapo, Ranking Member Brown, and distinguished members of the Committee, thank you for the invitation to appear at this morning’s hearing. I can think of few issues in our financial system more in need of our attention.

Our nation’s housing finance system is in urgent need of reform. The status quo poses significant risk to taxpayers, homeowners, renters, and the entire financial system.

I want to thank Secretary Mnuchin and Secretary Carson for their efforts to develop comprehensive housing finance reform plans. They lay out a responsible roadmap to build a more resilient housing finance system that protects taxpayers and mortgage access. I also thank Secretary Mnuchin for the opportunity to have offered commentary on Treasury’s plan during its development.

These plans are broadly consistent with my top priorities, which are to cement FHFA as a world-class regulator and to restore Fannie Mae and Freddie Mac (“the Enterprises”) to safe and sound condition by building capital to match their risk profiles. Building capital would also begin the process to end the Enterprise conservatorships, which have lasted more than 11 years, far longer than any other conservatorship.

A root cause of the 2008 financial crisis was imprudent mortgage credit risk backed by insufficient capital. This fundamental problem remains unresolved today. While borrower average credit scores have modestly improved, the Enterprises’ shares of low-down-payment and high debt-to-income mortgages are back to 2004 levels. Fueling rapidly rising home prices with easy mortgage credit from under-capitalized entities is a mistake. We should not repeat it.

In their current financial condition, the Enterprises are not equipped to withstand a downturn in the housing market. The Enterprises own or guarantee a combined $5.5 trillion in single and multifamily mortgages out of a $12 trillion combined market. Yet with just $6 billion in allowable capital reserves, the Enterprises’ combined leverage ratio is nearly a thousand to one.

In comparison, the nation’s largest financial institutions have an average leverage ratio of roughly ten to one.[1]

The 2019 Dodd-Frank Act Stress Test (DFAST) demonstrated the consequences of inaction. In the last crisis, from the market peak in the summer of 2006 to the bottom in 2012, housing prices declined by 27 percent. The 2019 DFAST modeled a scenario where residential real estate prices decline by 25 percent. Under such conditions, the Enterprises forecasted combined total losses of $43.3 billion during the stress-test period.

Given that housing supply appears to have become more inelastic since the crisis, we should expect greater price volatility going forward.

Our housing finance system also undercuts sustainable homeownership. The Enterprises have expanded with the economy recently yet maintained risk and capital levels that ensure they will fail in a downturn. This pro-cyclical pattern harms low-income borrowers, making it easier to buy homes beyond their means when the economy is strong and harder to keep those homes when the economy is weak.

Our housing finance system is supposed to serve homeowners and renters while protecting taxpayers. Currently, it fails on both counts. The Administration’s plans aim to address these problems.

Only Congress, however, can enact the structural reforms needed to fix today’s broken model.

Compared to the duopoly of the Enterprises, a fair and competitive secondary mortgage market would better serve borrowers and renters and promote long-term stability by ensuring that inefficient firms do not survive and that no institution is “too big to fail.” We have witnessed in one industry after another that the best guarantee for delivering lower prices to consumers is an open, competitive market, not a monopoly or duopoly.

Some argue reform should wait for a crisis. This shortsighted thinking fueled the last housing market collapse. As we learned then, it is impossible to solve complex problems in the middle of a crisis.

To paraphrase President Kennedy, the time to repair the roof is when the sun is shining. Now is the time for bold reforms because our economy and housing market are strong. This will not always be the case.

I am not forecasting a downturn. Rather, as a prudential regulator, I believe my job is to hope for the best and prepare for the worst.

Therefore, I intend, fulfilling my statutory duties, to strengthen FHFA, enable the Enterprises to build capital to match their risk profiles, and end the Enterprise conservatorships.

These reforms are critical to building a resilient mortgage finance system that protects taxpayers and delivers a diverse range of housing options at market-affordable prices. In the interim, modest reforms can improve FHFA’s ability to do its job.

For example, in June, I asked Congress for the authority, similar to other financial regulators, to develop capital standards for the Enterprises and to charter new enterprises. This common-sense proposal need not wait for broader reform.

In far too many areas of our Nation, we face a housing affordability crisis. Too often this has been the result of misguided local land-use and building regulations. In other areas, housing supply remains limited due to a lack of construction labor. For the Enterprises to play an important role in addressing this crisis, they themselves must be fixed. Adding more weight to an already cracked foundation is to invite collapse.

Thank you again for the opportunity to testify today. I look forward to answering your questions.

Contacts:

Fannie Mae: SVC-2019-06: Servicing Guide Updates

Posted on September 11, 2019September 11, 2019 by Ashley Shepherd

Investor Update
September 11, 2019

Source: Fannie Mae

The Servicing Guide has been updated to include changes or clarifications related to the following:

• Foreclosure and Bankruptcy Allowable Attorney Fees*
• Miscellaneous Revisions
o Guide Updates for Maximum Servicing Fee for UMBS Loans**
o Reporting Bankruptcy Notifications to Fannie Mae**
o Document Custodian Timing Requirements for Post-Delivery Servicing Transfers

*Policy change applies only to HomeKeeper® loans and is not applicable to Home Equity Conversion Mortgage (HECM) loans.
**Policy change not applicable to reverse mortgage loans.

Foreclosure and Bankruptcy Allowable Attorney Fees
We are updating the maximum allowable foreclosure attorney fees in all jurisdictions except Maine, New Hampshire, Washington (foreclosures for e-Notes only), Hawaii, Iowa (non-judicial foreclosures), and South Dakota. We determined that fees do not need to be adjusted at this time for those states. Additionally, we are updating the following maximum allowable bankruptcy attorney fees for legal services provided on mortgage loans we own or securitize:

▪ Motion for Relief for Chapter 7, 11, 12, and 13 cases;
▪ Proof of Claim Preparation and Plan Review for Chapter 11, 12, and 13 cases;
▪ Objection to Plan for Chapter 12 and 13 cases; and
▪ Response to Final Cure Payment Notice for Chapter 13 cases.

Updated Servicing Guide Exhibits
▪ Allowable Foreclosure Attorney Fees
▪ Allowable Bankruptcy Attorney Fees

Effective Date
The allowable fee updates are effective as follows:

▪ The new allowable foreclosure fees apply to all matters referred to counsel for initiation of foreclosure proceedings, regardless of referral date, if the matter is still active as of September 11, 2019. Servicers are encouraged to implement the new fees for the impacted states immediately, but must do so no later than December 1, 2019.
▪ The new allowable bankruptcy fees apply to all legal services performed on or after December 1, 2019.

Servicers may exercise reasonable discretion in determining how to implement the changes, including working as needed with the law firm or an applicable invoicing technology provider.

Miscellaneous Revisions
Guide Updates for Maximum Servicing Fee for UMBS Loans. To support the Uniform Mortgage-Backed Securities (UMBS), we previously announced new maximum servicing fees for fixed-rate mortgage loans delivered on or after June 1, 2019 in Lender Letter LL-2019-03. We are now incorporating these changes into the following topics of the Servicing Guide:
▪ F-2-09, Servicing Fees for MBS Mortgage Loans
▪ F-2-10, Servicing Fees for Portfolio Mortgage Loans

Reporting Bankruptcy Notifications to Fannie Mae. Currently, servicers must notify us when they learn after the foreclosure sale date that a borrower has filed for bankruptcy. In response to servicers’ feedback and to resolve confusion, we have created the Bankruptcy Notification Template to clarify the information that servicers must provide to us in connection with bankruptcy filings identified after the foreclosure sale date.

Updated Servicing Guide Topics
▪ E-2.3-07, Responding to Bankruptcies Identified After Foreclosure Sale
▪ F-4-01, References to Fannie Mae’s Website
▪ F-4-03, List of Contacts

Effective Date
Servicers are encouraged to use the template immediately, but must do so by December 1, 2019.

Document Custodian Timing Requirements for Post-Delivery Servicing Transfers. To enable timely and accurate recertification of custodial documents, we have updated A2-7-03, Post-Delivery Servicing Transfers to require that when a post-delivery servicing transfer occurs, the transferor servicer must advise the transferor document custodian maintaining possession of the custodial documents within 30 days of the transfer effective date.

Effective Date
Servicers are encouraged to implement this change immediately, but must do so for post-delivery servicing transfers that occur on or after January 1, 2020.

Contact your Fannie Mae account team, Portfolio Manager, or Fannie Mae’s Single-Family Servicer Support Center at 1-800-2FANNIE (1-800-232-6643) with any questions regarding this Announcement.

Malloy Evans
Senior Vice President and
Chief Credit Officer for Single-Family

OCC Bulletin 2016-20: Flood Disaster Protection Act

Posted on September 11, 2019September 11, 2019 by Safeguard

Investor Update
August 27, 2019

Source: OCC

Summary

The Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council¹ (FFIEC) adopted revised interagency examination procedures for the Flood Disaster Protection Act (FDPA). The revised procedures reflect the amendments to the regulations regarding loans in areas having special flood hazards to implement the private flood insurance provisions of the Biggert-Waters Flood Insurance Reform Act of 2012 (Biggert-Waters Act). The amendments to the regulations were issued by the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Farm Credit Administration, and the National Credit Union Administration and published in the Federal Register on February 20, 2019.²

This bulletin makes available on the OCC website the revised interagency FDPA examination procedures that reflect the private flood insurance requirements, which are effective July 1, 2019.

Rescission

The “Flood Disaster Protection Act” booklet of the Comptroller’s Handbook is rescinded with the issuance of the interagency examination procedures. OCC examiners will rely on the interagency procedures. This bulletin also rescinds OCC Bulletin 2017-35, “Flood Disaster Protection Act: Revised Comptroller’s Handbook Booklet.”

Note for Community Banks

The interagency examination procedures apply to examinations of all national banks, federal savings associations, and federal branches and agencies of foreign banking organizations.

Highlights

The FFIEC members developed these examination procedures to promote consistency in the examination process and communication of supervisory expectations. The new regulatory requirements are effective on July 1, 2019. The interagency procedures reflect regulatory provisions that

◾ require a regulated lending institution to accept private flood insurance policies that meet the definition of “private flood insurance” in satisfaction of the flood insurance purchase requirement.

◾ include a compliance aid to facilitate a regulated lending institution’s determination that a policy meets the definition of “private flood insurance.”

◾ permit a regulated lending institution to exercise its discretion to accept a flood insurance policy issued by a private insurer that does not meet the definition of “private flood insurance,” subject to certain restrictions.

◾ permit a regulated lending institution to exercise its discretion to accept flood coverage provided by a mutual aid society, subject to certain restrictions.

Further Information

Please contact Paul R. Reymann, Director for Consumer Compliance Policy, at (202) 649-5470.

Grovetta N. Gardineer
Senior Deputy Comptroller for Bank Supervision Policy

¹ The FFIEC comprises the following six voting members: a member of the Board of Governors of the Federal Reserve System; the Chairman of the Federal Deposit Insurance Corporation; the Director of the Consumer Financial Protection Bureau; the Comptroller of the Currency; the Chairman of the National Credit Union Administration; and the Chairman of the State Liaison Committee.

² Refer to 84 Fed. Reg. 4953.

VA: VALERI Servicer Newsflash

Posted on September 10, 2019 by Safeguard

Investor Update
September 9, 2019

Source: VA

IMPORTANT INFORMATION

Transfer of Custody (TOC) – Some TOC events reported via servicing system nightly files are not being generated in VALERI. In these instances, the event should be reported manually on the Events Bulk Upload Template. The template and the VALERI Servicer User Guide are available at https://www.benefits.va.gov/HOMELOANS/servicers_valeri_guides.asp. If the TOC event is rejected and the only business rule that fails is for late event reporting (15 days), the appeal link will be enabled.

Claim and Incentive Payments (Update from 8/15/19 Newsflash) – Issue with payments not generating on some incentives has been resolved. The claim payment generation issue is still pending.

Analytics Reports (Update from 8/15/19 Newsflash) – The system issue affecting reported events not reflecting in reports as of July 12, 2019, and June 15 through June 21, 2019, has been resolved.

Supplemental Claims – A system issue was identified where servicers are receiving an error message when attempting to submit a supplemental claim. Additional information will be provided at a later date.

Appeals – Servicers must upload documents and select the ‘Submit’ button to complete the appeal submission.
Loan Technician Contact Information – Loan Technician contact information is now located as an article in ‘Knowledge’ in VALERI. It is also still available at https://www.benefits.va.gov/homeloans/servicers_valeri.asp.

REMINDERS

Accessing VALERI – The new VALERI application must be accessed with the Google Chrome browser.

VALERI Assistance – The assigned loan technician should continue to be the first point of contact (VA Servicer Handbook M26-4, Chapter 1). VALERI system related inquiries for loans that are unassigned must be directed to valeri.vbaco@va.gov. Loan Management policy inquiries should still be directed to the VALERI Helpdesk at valerihelpdesk.vbaco@va.gov. When submitting inquiries related to upload issues, servicers must provide the uploaded spreadsheet and the auto-generated error message received.

HUD: FHA INFO #19-47: Training Opportunities

Posted on September 10, 2019September 10, 2019 by Safeguard

Investor Update
September 4, 2019

Source: HUD

Webinar Title: NEW Mortgagee Letter (ML) 2019-14: Updates to FHA’s Loss Mitigation Options for Borrowers in Presidentially-Declared Major Disaster Areas (PDMDA)

Date/Time: This webinar will be offered twice. Select the date and time of your choice:

• Thursday, September 12, 2019 2:00 PM to 3:00 PM (Eastern) or
• Thursday, September 26, 2019 2:00 PM to 3:00 PM (Eastern)

Event Location: On-line Webinar – No Fee

Jurisdictional Host: National Servicing Center

Registration Link: https://attendee.gotowebinar.com/register/2291915896603259907

Description:

This free, on-line webinar will provide attendees with a detailed overview of the loss mitigation policies announced in ML 2019-14. Additionally, it will highlight the amended loss mitigation procedures referenced in Section III.A.3.c. iv. of FHA’s Single Family Housing Policy Handbook 4000.1 for disaster-affected borrowers whose FHA-insured property or place of employment is in a PDMDA.

Audience:

This webinar is targeted primarily to FHA servicing industry participants; however, other stakeholders may also benefit from attending.

Special Instructions: For additional information, contact Stacey Brown at: stacey.a.brown@hud.gov.

Resources
Contact the FHA Resource Center:
• Visit our online knowledge base to obtain answers to frequently asked questions 24/7 at: www.hud.gov/answers.
• E-mail the FHA Resource Center at: answers@hud.gov. Emails and phone messages will be responded to during normal hours of operation, 8:00 AM to 8:00 PM (Eastern), Monday through Friday on all non-Federal holidays.
• Call 1-800-CALLFHA (1-800-225-5342). Persons with hearing or speech impairments may reach this number by calling the Federal Relay Service at 1-800-877-8339.

USDA: Post-Closing Lender Self Report

Posted on September 10, 2019September 10, 2019 by Safeguard

Investor Update
September 4, 2019

Source: USDA

Revisions to HB 3555-1, Chapter 4, “Lender Responsibilities,” were published on June 28, 2019. Paragraph 4.12 provides guidance on submitting post-closing lender self-reports and refers lenders and loan servicers to Attachment 16-C of Chapter 16 of the handbook for additional information. Attachment 16-C provides the following:

A self‐report must include:

• Borrower ID/GUS Application ID and last name to select the correct file
• Description of the issue
• Provide supporting documentation, if applicable
• Lender/Servicer Contact information

Submit this information via email SFHGLD.Compliance@usda.gov. Response time is dependent on the issue and number of submissions received by USDA. It is the responsibility of the lender to ensure their investor will accept responses from USDA for investor delivery.

The revised Chapter 16 will be published at a later date. However, an advance copy of Chapter 16 with the new Attachment 16-C is available in the USDA LINC Training and Resource Library.

A Procedure Notice (PN) will be issued at least 30 days prior to publication of HB 1-3555, Chapter 16.

Questions regarding this announcement may be directed to the National Office Division at
(202) 720-1452 or via email to SFHGLD.Compliance@usda.gov.

Thank you for your support of the Single-Family Housing Guaranteed Loan Program!

Help Resources

Policy Questions
Customer Service Center
Phone: 866-550-5887
Single Family Housing Guaranteed Loan Division
Phone: 202-720-1452

USDA ITS Service Desk Support Center
For e-Authentication assistance
Email: eAuthHelpDesk@ftc.usda.gov
Phone: 800-457-3642, option 1 (USDA e-Authentication Issues)

Rural Development Help Desk
For GUS system, outage or functionality assistance
Email: RD.HD@STL.USDA.GOV
Phone: 800-457-3642, option 2 (USDA Applications); then option 2 (Rural Development)

HUD: FHA INFO #19-46: FHA Strengthens Permanent Disaster Loss Mitigation Options

Posted on August 30, 2019 by Safeguard

Investor Update
August 29, 2019

Source: HUD

Today, the Federal Housing Administration (FHA) published Mortgagee Letter (ML) 2019-14, Updates to FHA’s Loss Mitigation Options for Borrowers in Presidentially-Declared Major Disaster Areas (PDMDA). This ML strengthens and expands FHA’s loss mitigation options to homeowners located in all PDMDAs by adding new options and improving several existing options that were originally put in place in 2018 as temporary provisions for specific PDMDAs. Read today’s Press Release, issued by the Department of Housing and Urban Development (HUD), for more on the topic.

Effective immediately, FHA will now make permanent:

– The Disaster Standalone Partial Claim option to help eligible borrowers on a forbearance plan resume their pre-disaster mortgage payments and avoid payment shock;

– Streamlined income documentation and revised loss mitigation procedures for a Disaster Loan Modification option and Disaster Standalone Partial Claim option; and

– A Trial Payment Plan as an alternative to providing income documentation for these disaster loss mitigation options.

This ML is designed to provide immediate loss mitigation and other relief options to FHA borrowers in all PDMDAs and help them stay in their homes while mitigating losses to FHA’s Mutual Mortgage Insurance Fund (MMIF). Further, the addition of these provisions to the Single Family Housing Policy Handbook 4000.1 creates clear and consistent policy applicable to borrowers whose FHA-insured property or place of employment is in a PDMDA.

Servicers may begin implementing these new policies immediately; however, they must begin implementing them no later than November 30, 2019.

Quick Links
– View today’s Press Release and other archived Press Releases at: https://www.hud.gov/press
– View Mortgagee Letter 2019-14 and all other archived Mortgagee Letters at:
http://portal.hud.gov/hudportal/HUD?src=/program_offices/administration/hudclips/letters/mortgagee

Resources
Contact the FHA Resource Center:

– Visit our online knowledge base to obtain answers to frequently asked questions 24/7 at: www.hud.gov/answers.
– E-mail the FHA Resource Center at: answers@hud.gov. Emails and phone messages will be responded to during normal hours of operation, 8:00 AM to 8:00 PM (Eastern), Monday through Friday on all non-Federal holidays.
– Call 1-800-CALLFHA (1-800-225-5342). Persons with hearing or speech impairments may reach this number by calling the Federal Relay Service at 1-800-877-8339.

OCC Allows National Banks and Federal Savings Associations Affected by Hurricane Dorian in Southeast United States to Close

Posted on August 30, 2019August 30, 2019 by Safeguard

Investor Update
August 30, 2019

Source: OCC

WASHINGTON—The Office of the Comptroller of the Currency (OCC) today issued a proclamation allowing national banks, federal savings associations, and federal branches and agencies of foreign banks affected by severe weather conditions associated with Hurricane Dorian in the Southeast region of the United States to close.

In issuing the proclamation, the OCC expects that only those bank offices directly affected by potentially unsafe conditions will close. Those offices should make every effort to reopen as quickly as possible to address the banking needs of their customers.

OCC Bulletin 2012-28, “Supervisory Guidance on Natural Disasters and Other Emergency Conditions” (September 21, 2012), provides guidance on actions bankers could consider implementing when their bank or savings association operates or has customers in areas affected by a natural disaster or other emergency.