As with other US and non-US regulators, the US federal banking regulators (Federal Reserve Board, Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation, collectively, the “US federal banking regulators”) have been issuing statements and providing guidance on the impact of the coronavirus on banking services. This blog posts covers some of their recent issuances on banks handling the consequences of the coronavirus for themselves and their customers.

• On March 6, 2020, the Federal Financial Institutions Examination Council (“FFIEC”), an interagency group of state and federal regulators that develops principles, standards and reporting systems to promote uniformity in the supervision of US financial institutions, issued updated guidance on how financial institutions could take steps to minimize the potential adverse impacts of a pandemic. Its Interagency Statement on Pandemic Planning updated guidance from 2007 that was issued regarding influenza pandemic planning.
• On March 9, 2020, the federal and state banking regulators issued a press release encouraging financial institutions to work with their customers who may be impacted by the coronavirus. The regulators also stated that they would work with banks should they need variances from regulatory requirements to be better able to serve the banking needs of their customers.
• On March 13, 2020, the Office of the Comptroller of the Currency issued a separate bulletin on national banks working with customers affected by the coronavirus and the regulatory relief that it could provide banks should there be a need.
• On March 15, 2020, the Federal Reserve Board issued a statement that, among other things, encouraged banks to use the Federal Reserve Banks’ discount windows to obtain short term loans to help meet the credit needs of their customers dealing with the impact of the coronavirus.
• The next day, the US federal banking regulators released a press release endorsing the Federal Reserve Board’s statement encouraging the use of the discount window.
• The Conference of State Bank Supervisors, the trade association for state banking regulators, has developed a website that provides information on what states are doing with respect to COVID-19, including state emergency declarations and executive orders.

Norton Rose Fulbright counsel Glen Barrentine also has posted an article to the blog regarding FINRA’s guidance to broker dealers on pandemic preparedness.

For further information, please visit Norton Rose Fulbright’s webpage dedicated to the coronavirus pandemic.