FFIEC Guidance Notes Critical Nature of Financial Services and Announces No-Action Position for Missing Certain Deadlines

As part of their combined response to the COVID-19 crisis, the Federal Financial Institutions Examination Council issued guidance on March 25, 2020, noting that:

• The financial services sector provides critical service “by ensuring the continued availability of financial resources to consumers and businesses.”  The notice also states that the FFIEC members will provide guidance to financial institutions and work with state and local officials to identify essential workers; and
• “The federal banking agencies will not take action against any institution for submitting its March 31, 2020, Reports of Condition and Income (Call Reports) after the respective filing deadline, as long as the report is submitted within 30 days of the official filing date.”

The guidance encourages financial institutions to work with their regulator in advance of the deadline if they anticipate a late filing.

The guidance is available here.