On Friday, March 13, 2020, the OCC issued OCC Bulletin 2020-15 and the FDIC issued FIL-17-2020 encouraging banks to take steps to meet the financial services needs of  customers affected by Coronavirus (COVID-19) related issues. Both agencies provide information on steps banks can take to assist customers and communities, way the Agencies will help reduce burden on banks, and note all efforts must be consistent with safe and sound banking practices and applicable laws.
Notable items addressed in the OCC Bulletin include:

  • Ways to work with customers, in accordance with prudent banking standards, such as waiving fees and penalties, increasing ATM withdrawal or credit card limits, easing restrictions on cashing checks, offering payment accommodations, ease terms for new loans, etc. The Bulletin notes that prudent efforts to modify the terms on existing loans for affected customers should not be subject to examiner criticism.
  • Providing regulatory relief by: 1) considering the unusual circumstances when reviewing a bank’s financial condition and determining any supervisory response; 2) reducing the burden of exams/inspections, 3) working with banks on reporting requirements; and 4) working with banks on temporary closures or reduction in services.

Notable items addressed in the FDIC FIL include:

  • Working with all borrowers affected by COVID-19, especially those in industries vulnerable to the economic environment and small businesses and contractors that are reliant on affected industries in a prudent manner. A financial institution’s prudent efforts to modify the terms on existing loans for affected customers will not be subject to examiner criticism.
  • The FDIC will work with affected financial institutions to reduce burden when scheduling examinations, including making greater use of off-site reviews, consistent with applicable legal and regulatory requirements.
  • The FDIC has launched a COVID-19 webpage on its public website to provide useful information to bankers, consumers, and others. Financial institutions that have questions about guidance in the statement are encouraged to contact their FDIC Regional Office.
  • Depository institutions can advise customers to contact the FDIC toll free at 1-800-ASK-FDIC or 1-877-275-3342 with questions about deposit insurance or accessing bank accounts.

Compliance Resource has a one-hour Pandemic Planning webinar scheduled for March 23. For more information visit the registration page.