InitiateYourOwnCreditForbearanceandModificationPrograms There is no need to be constrained by government action or to wait for regulators to provide detailed guidance. In the US, banks have already received guidance from the OCCthat“prudenteffortstomodifythetermsonexistingloansforaffectedcustomers should not be subject to examiner criticism.” So, banks should proactively notify customers that they will do “the right thing” and adopt a highly flexible approach to paymentschedules. While payment holidays for mortgages are helpful, outside of North America and the UKrentingyourhouseisfarmoreprevalent.Therefore,banksmayalsoneed topay special attention to supporting the rental sector in two ways: short-term loans to pay rent, and an extension of payment holidays to “buy-to-let” mortgage holders. This will also ensure that economic support is not inadvertently skewed towards homeowners andthosewhoarerelativelywelloff. Manybanksandotherlendershavealreadystartedtocommunicatethesebroad-based forbearance programs, typically suspending payments for a period of 90 to 120 days. Some of the leaders in this wave have been crowdlending platforms like October (with apresenceinhard-hitmarketslikeSpain,theNetherlands,ItalyandFrance)whichwere aheadofthebanksinaskingtheirinvestorstoapproveablanketthree-monthpayment holiday. Butmanylendersalsohavetheabilitytointerveneinmoretargetedways.Ideally,banks shouldbedata-drivenintheirapproachtothisrapidlyevolvingcreditcrisis. Clients – commercial as well as individual consumers – will not be equally impacted by this pandemic. It follows that lenders should be doing not only sectoral modelling but also individual customer cashflow modelling (particularly where they have transaction account information). These analyses can then be used to proactively reach out to customers with tailored, relevant solution proposals. For example, it will quicklybecomeapparentwhichrestaurantscanmovetoapick-up/deliverybusiness 8 COVID-19: Open letter to retail and commercial banking CEOs