As the status of the pandemic changes, banking agencies are continuing to release guidance and resources to help financial institutions meet the needs of consumers while operating in a safe and sound manner. We will do our best to keep you informed as information is released. In a previous post, we provided you with guidance from the OCC and FDIC encouraging banks to work with customers affected by COVID-19. Below are additional resources that were recently released.
FRB, OCC, FDICFederal Banking Agencies Encourage Banks to Use Federal Reserve Discount Window. A statement encouraging banks to use the Fed’s “discount window”, which provides short-term loans to banks and, therefore, supports the liquidity/stability of the banking system, so that they can continue supporting households and businesses. By providing access to funding, the discount window helps institutions manage their liquidity risks efficiently and avoid actions that have negative consequences for their customers.
CFPBProtect Yourself Financially from the Impact of the Coronavirus. This information can help inform your consumers about options available if they experience a loss in income, can not make loan payments, or if they may have been targeted by a scammer. It can also prompt financial institutions to consider a consumer’s circumstances and ways they can help.
FRB, OCC, FDICStatement on the Use of Capital and Liquidity Buffers. The Agencies, are taking two specific actions to allow banks to continue lending to households and businesses, including:

  • Encouraging banks to use their capital and liquidity buffers as they respond to the challenges presented by the effects of the coronavirus.
  • A technical change to phase in, as intended, the automatic distribution restrictions gradually if a firm’s capital levels decline.

FinCENThe Financial Crimes Enforcement Network (FinCEN) Encourages Financial Institutions to Communicate Concerns Related to the Coronavirus Disease 2019 (COVID-19) and to Remain Alert to Related Illicit Financial Activity. FinCEN advises institutions to: 1) Contact FinCEN and their regulator if there is the potential for delays in its ability to file BSA reports due to the pandemic; 2) Remain alert about malicious or fraudulent transactions; 3) See FinCEN’s advisory, FIN-2017-A007 “Advisory to Financial Institutions Regarding Disaster-Related Fraud” (October 31, 2017) for descriptions of other relevant typologies, such as benefits fraud, charities fraud, and cyber-related fraud; and 4) Enter “COVID19” in Field 2 of the SAR-template, along with checking the appropriate suspicious activity report-template (SAR-template) box(es) for certain typologies, for suspected suspicious transactions linked to COVID-19.
FTCChecks from The Government. Information that checks from the government have not yet been finalized or released. The government will not call to ask for your Social Security number, bank account, or credit card number and the government will not ask you to pay anything up front to get this money. Financial institutions should consider sharing this information with their customers.
Continue to watch our blog for additional information. Also, the OCC, FDIC, FRB, NCUA, and CFPB have COVID-19 resource pages available.
Compliance Resource has a one-hour Pandemic Planning webinar scheduled for March 23. For more information visit our registration page.