Eligibility of Pledged Loan Collateral FAQs

posted on Tuesday, April 14, 2020 in Member Services

Federal Home Loan Bank of Des Moines (FHLB Des Moines or the Bank) has published general guidelines for members providing relief to their borrowers in relation to the coronavirus (COVID-19) pandemic. Please see COVID-19 Updates and Resources. This Frequently Asked Questions (FAQ) provides additional information regarding that guidance.  Members are reminded that all forbearance and modification agreements must comply with all applicable laws, regulations and regulatory guidance to which the member may be subject. 

The Bank is actively monitoring actions by all regulators, including the Federal Housing Finance Agency, Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve, the Office of the Comptroller of the Currency, the National Credit Union Administration and the Consumer Financial Protection Bureau. We are also monitoring efforts at Fannie Mae (FNMA) and Freddie Mac (FHLMC).  In the event these agencies provide additional relief initiatives or other guidance, we will assess our own guidance and make any adjustments as necessary. 

General Guidelines on Acceptable Collateral Modifications

New Loan Originations

  • Are electronic signatures acceptable for new loan originations?

    Temporarily. An electronic or fax signature is permitted for new originations. However, the Bank will require a wet signature replacement when safe to do so. 

    For newly originated loans made in accordance with the SBA Paycheck Protection Program (PPP) requirements and guidelines, the Bank will accept electronically signed, newly originated loans. PPP loans will remain eligible as collateral even if a wet-inked signed copy is not obtained.

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Collateral Reporting

Past Due Assessment

  • In reporting eligible collateral based on past due status, is FHLB Des Moines changing its limitations on past due loans?

    No. Currently, we expect members to report past due loans based on the member’s determination of past due status. Reporting past due status for impacted loans should be completed in accordance with the requirements of the member’s primary regulator and applicable law.

    For members providing detailed loan listing data, the past due status as determined by the member should be reflected in the Delinquency Code field.  A loan’s paid through date, however, should continue to reflect payments made under the contractual terms of the note, including any executed modification or forbearance agreements.    

    Loans that have not been modified or paid current following the forbearance period, and have no borrower signature, may be subject to additional discounting in the Member Collateral Verification (MCV) and collateral valuation processes.

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Regulatory Relief Initiatives


  1. COVID-19