See also and associated commentary.

One unfortunate, but inescapable, fact illustrated by the letter is that forbearance requirements are not cost-free. If borrowers do not have to pay their loans, then servicers will in turn need government assistance or they may fail. In the housing and real estate market, the long-term economic cost of those failures could be significant.

What does the virus do to New York City property values? It may be the case that all property values are somewhat speculative at this point, or maybe also in the intermediate future. It will take time before we know the extent, if any, to which the ordinary routines of life, such as riding the subway, are impacted.

The decision to redo the various forms intended to collect systemic risk data is completely sensible and seemingly overdue. (As , Form PF and its various spin-offs are worthless.) That said, now is not the time for the redo. Rather than adopt a rule change during a period when no one in the industry is likely to have an ability to focus on the details, which are important, this should be put on hold. Better to spend another year collecting useless data than to make revisions that don't…