The NCUA, along with the Office of the Comptroller of the Currency, Federal Reserve, Federal Deposit Insurance Corporation, and state regulators recognize the severe impact of California wildfires on customers and the operations of many financial institutions. and provide appropriate regulatory assistance to the relevant institutions subject to their supervision. Agencies encourage institutions operating in affected areas to meet the financial service needs of their communities.
A full list of affected disaster areas is available at https://www.fema.gov/disasters.
Ready: Agencies encourage financial institutions to work constructively with borrowers in communities affected by California wildfires. Cautious efforts to adjust or change the terms of existing loans in affected areas should not be subject to reviewer criticism. Institutions should individually assess changes to existing loans to determine whether they represent distressed debt restructurings under US generally accepted accounting principles. Institutions must consider the facts and circumstances of each borrower and loan, and exercise judgment, as not all changes will result in a restructuring of troubled debt. In overseeing institutions affected by the California wildfires, agencies will take into account the unusual circumstances that these institutions face. Agencies recognize that efforts to work with borrowers in stressful communities may be compatible with safe and healthy practices as well as in the public interest.
Temporary installations: The agencies understand that many financial institutions face challenges with personnel, electricity, telecommunications and others in reopening their facilities after the wildfires. In cases where operational issues persist, the primary federal and / or state regulator will expedite, where appropriate, any request to operate temporary facilities in order to provide more convenient availability of services to those affected by the fires. forest in California. In most cases, a telephone notification to the primary federal and / or state regulator will initially suffice to initiate the approval process, with the necessary written notification submitted shortly thereafter.
Publication requirements: The agencies understand that damage from California wildfires may affect compliance with publishing and other requirements for branch closings, relocations, and temporary installations under various laws and regulations. Institutions experiencing disaster-related difficulties in complying with any publication or other requirements should contact their primary federal and / or state regulator.
Regulatory reporting requirements: Institutions affected by the California wildfires that expect to experience difficulty meeting agency reporting requirements should contact their primary federal and / or state regulator to discuss their situation. Agencies do not plan to impose sanctions or take other supervisory action against institutions that take reasonable and prudent steps to comply with regulatory agency reporting requirements if those institutions are unable to fully meet these requirements due to the California wildfires.
Agency staff are ready to work with relevant institutions that may encounter problems in fulfilling their reporting responsibilities, taking into account the particular circumstances of each institution, including the state of its reporting systems and record keeping and the state of its underlying financial records.
For more information, see Interagency Supervisory Reviewer’s Guide for Institutions Affected by a Major Disaster, which is available here.