March 27, 2020
Statement on Part 363 Annual Reports in Response to the Coronavirus
The FDIC issued the Statement on Part 363 Annual Reports in Response to the Coronavirus to provide additional information and guidance to insured depository institutions (IDIs) subject to Part 363 of the FDIC’s regulations that have been affected by the Coronavirus Disease 2019 (referred to as COVID-19).
Statement of Applicability to Institutions with Total Assets under $1 Billion: This Financial Institution Letter (FIL) applies to all insured depository institutions with $500 million or more in total assets.
As noted in the statement, the FDIC:
- Recognizes that an IDI subject to Part 363 of the FDIC’s regulations may not be able to file its Part 363 Annual Report in a timely manner due to the effects of COVID-19.
- Provides that the FDIC will not take supervisory action against any IDI for submitting its Part 363 Annual Report or its written notification of late filing as long as the annual report or notification of late filing is submitted within 45 days of the 90- or 120-day report filing deadline.
- Encourages IDIs to contact the FDIC in advance of the official filing date if the IDI anticipates a delayed submission.
- Affirms that the staff of the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the state banking regulators have confirmed the FDIC’s treatment of the annual report required by Part 363.