NCUA, along with the Federal Reserve, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and state financial regulators recognize the serious impact of Hurricanes Fiona and Ian on the customers and operations of many financial institutions and will provide appropriate regulatory assistance to affected institutions subject to their supervision.
The agencies encourage institutions operating in the affected areas to meet the financial services needs of their communities.
A complete list of the affected disaster areas can be found at fema.gov/disasters.
The agencies encourage financial institutions to work constructively with borrowers in communities affected by Hurricanes Fiona and Ian. Prudent efforts to adjust or alter terms on existing loans in affected areas are supported by the agencies and should not be subject to examiner criticism. In accordance with U.S. generally accepted accounting principles, institutions should individually evaluate modifications of existing loans to determine whether they represent troubled debt restructurings or modifications to borrowers experiencing financial difficulty, as applicable.
In making this evaluation, institutions should consider the facts and circumstances of each borrower and modification. In supervising institutions affected by Hurricanes Fiona and Ian, the agencies will consider the unusual circumstances these institutions face. The agencies recognize that efforts to work with borrowers in communities under stress can be consistent with safe-and-sound practices as well as in the public interest.
The agencies understand that many financial institutions face staffing, power, telecommunications, and other challenges in re-opening facilities after Hurricanes Fiona and Ian. In cases in which operational challenges persist, the primary federal and/or state regulator will expedite, as appropriate, any request to operate temporary facilities to provide more convenient availability of services to those affected by Hurricanes Fiona and Ian.
In most cases, a telephone notice to the primary federal and/or state regulator will suffice initially to start the approval process, with necessary written notification being submitted shortly thereafter.
The agencies understand that the damage caused by Hurricanes Fiona and Ian may affect compliance with publishing and other requirements for branch closings, relocations, and temporary facilities under various laws and regulations. Institutions experiencing disaster-related difficulties in complying with any publishing or other requirements should contact their primary federal and/or state regulator.
Regulatory Reporting Requirements
Institutions affected by Hurricanes Fiona and Ian that expect to encounter difficulty meeting the agencies’ reporting requirements should contact their primary federal and/or state regulator to discuss their situation. The agencies do not expect to assess penalties or take other supervisory action against institutions that take reasonable and prudent steps to comply with the agencies’ regulatory reporting requirements if those institutions are unable to fully satisfy those requirements because of Hurricanes Fiona and Ian.
The agencies’ staffs stand ready to work with affected institutions that may be experiencing problems fulfilling their reporting responsibilities, taking into account each institution’s particular circumstances, including the status of its reporting and recordkeeping systems and the condition of its underlying financial records.
Institutions are encouraged to monitor municipal securities and loans affected by Hurricanes Fiona and Ian. The agencies realize local government projects may be negatively affected by the disaster and encourage institutions to engage in appropriate monitoring and take prudent efforts to stabilize such investments.
For more information, refer to the Interagency Supervisory Examiner Guidance for Institutions Affected by a Major Disaster.