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Interagency Examiner Guidance for Assessing Safety and Soundness Considering the Effect of the COVID-19 Pandemic on Financial Institutions

Disaster Relief
June 23, 2020

Summary:

The FDIC, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the National Credit Union Administration (federal financial regulatory agencies) in conjunction with the state bank and credit union regulators are jointly issuing examiner guidance (interagency examiner guidance) to outline the supervisory principles for assessing the safety and soundness of institutions given the ongoing impact of the COVID-19 pandemic. This is guidance for examiners, and no action on the part of supervised institutions is required.

Statement of Applicability to Institutions with Total Assets under $1 Billion: This Financial Institution Letter (FIL) is relevant for all FDIC-supervised depository institutions, but the subject is examiner guidance.

Highlights:

  • The interagency examiner guidance acknowledges that stresses caused by COVID-19 can adversely impact an institution’s financial condition and operational capabilities, even when institution management has appropriate governance and risk management systems in place to identify, monitor, and control risk.
  • The interagency examiner guidance instructs agency examiners to consider the unique, evolving, and potentially long-term nature of the issues confronting institutions and to exercise appropriate flexibility in their supervisory response.
  • Examiners will continue to assess institutions in accordance with existing policies and procedures and may provide supervisory feedback, or downgrade an institution’s composite or component ratings, when conditions have deteriorated.
  • Examiners will consider whether institution management has managed risk appropriately, including taking appropriate actions in response to stresses caused by COVID-19 impacts.
  • Examiners will give consideration to the challenges involved in assessing the risk that the response presents to the institution in real time given the level of information available and the stage of local economic recovery.
  • In assessing an institution under the principles in the interagency examiner guidance, examiners will consider the institution’s asset size, complexity, and risk profile, as well as the industry and business focus of its customers.

Distribution:

All FDIC-Supervised Depository Institutions

Suggested Routing:

Board of Directors
Chief Executive Officer
Chief Credit Officer
Chief Risk Officer

Attachment(s)
FIL 36-2020 Revised Interagency Statement on Loan Modifications by Financial Institutions Working with Customers Affected by the Coronavirus (April 7, 2020)
FIL 17-2020 Regulatory Relief - Working with Customers Affected by the Coronavirus (March 13, 2020)
FIL 62-2017 Interagency Supervisory Guidance for Institutions Affected by a Major Disaster (December 15, 2017)

Last Updated: June 23, 2020