PORT OF SPAIN, Trinidad – The Central Bank of Trinidad and Tobago (CBTT) has announced a new moratorium on the regulatory treatment of payment deferrals or restructured loans due to the measures put in place by the authorities here to curb the spread of the coronavirus (COVID-19) pandemic.
In a letter sent to all institutions licensed under the Financial Institutions Act and copied to the Bankers Association of Trinidad and Tobago and the Institute of Chartered Accounts of Trinidad and Tobago (ICATT), the CBTT said that it notes “with concern the difficulties currently being faced by our national community as we face the effects of the ongoing pandemic and the potential hardship that it presents to customers of financial institutions.”
The CBTT said that it had previously extended an initial moratorium on deferred loans in March last year, which was subsequently extended twice within 2020 and came to an end on December 31, 2020.
“However, having regard to the new circumstances, the Central Bank considers it appropriate to reintroduce a moratorium on the regulatory treatment for rescheduled loans due to “skipped payments” or rate reductions and past due facilities for the period May 1, 2021, to September 30, 2021.”
Financial institutions should note that payment deferrals or rate reductions shall apply only to those performing loans and loans past due up to 89 days as of May 1, 2021.
“Non-performing loans, that is, loans in the 90 days and over category and classified as sub-standard, doubtful loss as of May 1, 2021, will not qualify for this treatment.”
The CBTT said that the deferral of loan payments is to be extended on an ‘opt in’ basis only. All deferrals offered to customers during this period must expire on September 30, 2021, regardless of the actual date of commencement of the deferral.
In addition, credit facilities that have been afforded skipped payments or rate reductions should not be reported as “Restructuring or Rescheduled” or as “Past Due” based on several measures.
It said that borrowers who were current before the new moratorium period commencing May 1, 2021, and who subsequently accepted the “skipped payment” provision due to the effects of COVID-19 generally should not be reported as past due.
“Similarly, borrowers who accept a rate reduction should not be reported as “Restructuring or Rescheduled,” the CBTT said, adding that financial institutions have the option on a “case by case” basis for applying payment deferrals to past due exposures in the 1 – 89 days categories by their credit management policies.
“Past due reporting status should be maintained as the status reflected as at May 1, 2021, for the duration of the deferral period granted,” the CBTT said, adding “ all financial institutions will be required to submit the special DPC-19 Report to the Central Bank every month and within 30 business days of the end of the relevant reporting month for the period May to September 2021.”
The CBTT said that financial institutions would be allowed to restructure loans that have a high probability of fulfilling revised payment terms and conditions beyond the current restrictions set out in the Bank’s Guideline for the Measurement, Monitoring, and Control of Impaired Assets.
It said loans that have been restructured should be reported by established reporting requirements. Financial institutions are required to provide borrowers with accurate disclosures when offering payment deferrals and rate reductions, which will alleviate any misunderstandings relative to the changes in the terms and conditions of the loan contract.
“The financial institution must provide customers with adequate information to understand the implications of a “skipped payment” or payment deferral, including the consequences (if any) for the total amount payable under the loan contract, the term of the loan, and the amount of contractual monthly installments. The customer should also have no liability to pay any charge or fee associated with the granting of the “skipped payment” or deferral arrangement.”
The Central Bank said that it would be meeting with the commercial banks in the coming weeks to discuss the detailed plans being put in place for monitoring and managing credit and liquidity risks and capital both during and after the moratorium period.
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