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Financial Institution Letter

Interagency Interim Final Rule Provides Regulatory Relief to Institutions Experiencing Temporary Asset Growth in Connection with COVID-19-Related Programs


On November 20, 2020, the FDIC Board of Directors adopted an interim final rule (IFR) to provide temporary regulatory burden relief to certain insured depository institutions (IDIs) that exceeded, or may exceed, certain regulatory asset thresholds due, in large part, to their participation in government programs established in response to the COVID-19 pandemic (e.g., the Paycheck Protection Program (PPP), among others). The IFR, issued with the Board of Governors of the Federal Reserve and the Office of the Comptroller of the Currency, amends certain rules to provide temporary relief to IDIs with $10 billion or less in total consolidated assets as of December 31, 2019. The IFR is effective immediately; comments will be accepted for 60 days after publication in the Federal Register .

A copy of the IFR is available on the FDIC’s website.

Statement of Applicability: This Financial Institution Letter (FIL) applies to institutions with $10 billion or less in total consolidated assets.


  • Some IDIs have experienced large cash inflows resulting from participation in the PPP, the Paycheck Protection Program Liquidity Facility, the Money Market Mutual Liquidity Fund, or other factors, such as the effects of other government stimulus efforts.
  • The IFR generally provides relief to IDIs with under $10 billion in total assets as of December 31, 2019, by allowing the IDI to calculate its asset size for applicable thresholds during calendar years 2020 and 2021 based on the lower of either total assets as of December 31, 2019 or total assets as of the normal measurement date; the temporary relief expires on December 31, 2021.
  • For FDIC-supervised institutions, the temporary relief applies to:
    • Eligibility for the community bank leverage ratio (CBLR) framework ($10 billion, 12 CFR 324.12(a));
    • Thresholds in the FDIC’s rule regarding management official interlocks ($10 billion, 12 CFR 348.3(c); $100 million, 12 CFR 348.2(k)(1); and $50 million, 12 CFR 348.3(b));
    • Eligibility for reduced reporting on the FFIEC 051 Call Report ($5 billion,12 CFR 304.12); and
    • Thresholds concerning the frequency of examinations ($3 billion) for domestic banks (12 CFR 337.12) and insured branches of foreign banks (12 CFR 347.211).

  • The agencies reserve the authority, with respect to the CBLR and management interlocks rules, to determine, in limited circumstances, that the regulatory relief would not be appropriate based on an institution’s risk profile. The agencies will rely on existing reservations of authority in the Call Report and examination frequency rules.
  • The agencies will be making conforming changes to regulatory reports, in coordination with the Federal Financial Institutions Examination Council, through a separate Federal Register notice.
  • Comments on the IFR will be accepted for 60 days after publication in the Federal Register .
  • FDIC-supervised institutions with questions about the IFR or the reservations of authority should contact their regional office.


FDIC-Supervised Institutions

Suggested Routing:

Chief Executive Officer
Chief Financial Officer
Chief Risk Officer

Last Updated: November 20, 2020