Summary of Action: Interim final rule that allows community banks with fewer than $10 billion in assets as of December 31, 2019, to avoid various extra regulations associated with an increase in asset size until 2022; banks would have until 2022 to get under the relevant asset size threshold, or to comply with the increased regulations.

 

https://www.federalreserve.gov/newsevents/pressreleases/bcreg20201120a.htm

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Type of Policy: Interim final rule

 

Expires: January 1, 2022; comments on interim final rule due 60 days after publication in the federal register.

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Summary of Action:  OCC bulletin addressing the potential preemption concerns of state COVID-19 relief actions that “address foreclosure and repossession moratoriums, loan forbearance, and limitations on the interest and fees banks may charge,” indicating that such measures may impermissibly conflict with federal regulation of banks.

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https://www.occ.treas.gov/news-issuances/bulletins/2020/bulletin-2020-62.html

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Type of Policy:  Bulletin

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Expires:  No expiration

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Additional Information: Conference of State Bank Supervisors has pushed back on the OCC’s assertion of preemption concerns.

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https://www.csbs.org/why-occ-preemption-bulletins-do-not-impact-state-covid-19-relief-measures

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Democratic Senators have sent a letter to the OCC indicating it exceeded its authority by issuing the bulletin.

Summary of Action: Relief allowing banking organizations (i.e. banks and bank holding companies) subject to the supplementary leverage ratio requirement to exclude U.S. Treasury securities and deposits at Federal Reserve Banks from supplementary leverage ratio denominator.  Depository institutions electing to take this relief must seek permission from their primary federal regulator before making certain capital distributions.

 

https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200515a.htm

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Type of Policy: Interim final rule

 

Expires: March 31, 2021

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Additional Information:  Law360 explains this could result in up to $55 billion reduction in capital.

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Summary of Action:  Proposed rule that would neutralize the effect of participating in Paycheck Protection Program (PPP) on banks’ assessment rates and assessment base, by excluding PPP loans from banks’ loan portfolios and asset base, and also by excluding loans taken through the Paycheck Protection Program Liquidity Facility or Money Market Mutual Fund Facility from calculation of banks’ liabilities.

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https://www.fdic.gov/news/news/press/2020/pr20059.html

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Type of Policy:  Proposed Rule

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Expires:  No expiration

Summary of Action: Extension of deadline for Barclays, Credit Suisse, Deutsche Bank, and UBS to submit resolution plans addressing previously identified weaknesses to September 29, 2020; extension of deadline for Category II and Category III banks to submit targeted resolution plans to September 29, 2020.

 

https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200506a.htm

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Type of Policy: Interim final rule

 

Expires: New deadline for submission is September 29, 2020

Summary of Action:  Excludes loans made to banks through the Money Market Mutual Fund Liquidity Facility or Paycheck Protection Program Liquidity Facility, and the assets securing such loans, from the calculation of the banks’ “total net cash outflow” amount for purposes of the liquidity coverage ratio, to neutralize the effect of taking such loans.

 

https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200505a.htm

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Type of Policy:  Interim Final Rule

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Expires:  No Expiration Date

Summary of Action: Deletes provision of the Regulation D definition of “savings deposit” that prevented bank customers from making more than six (6) transfers per month from savings accounts.

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https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200424a.htm

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Type of Policy: Interim final rule

 

Expires: No expiration; comments on interim final rule due 60 days from date of publication in the Federal Register

Summary of Action:  Relief temporarily eliminating caps on uncollateralized intraday credit, and overdraft fees, for those institions eligible for primary credit from the discount window (i.e., those “in generally sound financial condition”).  The relief also provides a “streamlined procedure” for secondary credit institutions to request collateralized intraday credit.

 

https://www.federalreserve.gov/newsevents/pressreleases/other20200423a.htm

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Type of Policy:  Policy statement

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Expires:  September 30, 2020

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Summary of Action: Agency statement that Office of Foreign Assets Control will consider the need to temporarily reallocate compliance resources as part of a risk-based approach to compliance, in assessing possible administrative responses to OFAC sanctions violations.

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https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20200420.aspx

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Type of Policy: Agency statement

 

Expires: No expiration date

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Summary of Action:  Relief exempting Paycheck Protection Program loans from restrictions on loans to bank insiders. 

 

https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200417a.htm

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Type of Policy:  Interim final rule.

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Expires:  No expiration date; comments on interim final rule due June 8, 2020

Summary of Action:  Relief allowing financial institutions engaging in certain residential or commercial real estate transaction to defer obtaining appraisal or evaluation for up to 120 days after closing (excluding transactions for acquisition, development, and construction of real estate).

 

https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20200414a1.pdf

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Type of Policy:  Interim final rule.

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Expires:  December 31, 2020 (comments due 45 June 1, 2020).

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Summary of Action:  Establishment of zero percent risk weight for PPP loans, to neutralize the regulatory capital effects of participating in FRB’s PPP facility. 

 

https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200409a.htm

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Type of Policy:  Interim final rule.

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Expires:  No expiration date; comments on interim final rule May 13, 2020

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Summary of Action:  Establishment of Main Street Business Lending Program to provide funds for purchasing loan participations, to facilitate lending to small- and medium-sized businesses by banks.

 

https://www.federalreserve.gov/newsevents/pressreleases/files/monetary20200409a7.pdf

 

https://www.federalreserve.gov/newsevents/pressreleases/files/monetary20200409a4.pdf

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Type of Policy:  Section13(3) authority.

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Expires:  September 30, 2020.

Summary of Action:  Temporary relief for Wells Fargo from growth restrictions imposed “because of widespread compliance and operational breakdowns that resulted in harm to consumers” and insufficient oversight by Wells Fargo’s board; loans made pursuant to Paycheck Protection Program and FRB’s Main Street Business Lending Program do not count towards cap.

 

https://www.federalreserve.gov/newsevents/pressreleases/enforcement20200408a.htm

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Type of Policy:  Amendment to consent order. 

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Expires:  Loans excluded from cap must be made pursuant to PPP (expires June 30, 2020) or Main Street Business Lending Program (expires September 30, 2020)

Summary of Action:  Establishment of facility to provide term financing backed by Payback Protection Program loans.

 

https://www.federalreserve.gov/newsevents/pressreleases/files/monetary20200409a6.pdf

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Type of Policy:  Section 13(3) authority.

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Expires:  September 30, 2020

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> Additional Information:  The Project on Government Oversight has released an analysis of the shortcomings of the Office of Management and Budget’s oversight guidance for CARES Act programs. Read the analysis here. 

Summary of Action:  Temporary reduction of the threshold for qualifying community banking organizations, i.e. those with less than $10 billion in assets and who meet certain other criteria, to meet capital and leverage requirements using the “community bank leverage” ratio, from 9% to 8%, for 2020 and to allow a two-quarter grace period for banks that fall below the 8% ratio so long as they stay above 7% community bank leverage ratio, a reduction from 8%, the previous threshold to be entitled to the grace period

 

https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200406a.htm

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Type of Policy:  Interim final rule.

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Expires:  The community banking leverage ratio goes to 8.5% for 2021, and to the previous level of 9% in 2022. Comments on the final rule are due 45 days.

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Summary of Action:  Establishment of FIMA repurchase authority to allow central banks and other international monetary authorities to exchange U.S. Treasury Securities held with FRB for U.S. dollars.

 

https://www.federalreserve.gov/newsevents/pressreleases/monetary20200331a.htm 

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Type of Policy:  FOMC action. 

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Expires:  Until at least October 6, 2020 (6 months after program begins on April 6)

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Summary of Action:  Delay of implementation, from April 1, 2020 to September 30, 2020, of revised framework for determining when one company controls another for determining whether a company is a bank holding company under the BHCA.

 

https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20200331a1.pdf

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Type of Policy:  Final rule delaying effective date.

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Expires:  Delays effective date until September 30, 2020.

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Summary of Action:  Allows banking organizations that adopt CECL during 2020 the option to delay, for two years, the estimated impact of CECL on regulatory capital, followed by a three year transition to phase out aggregate capital benefit provided by the two-year phase in. 

 

https://www.federalregister.gov/documents/2020/03/31/2020-06770/regulatory-capital-rule-revised-transition-of-the-current-expected-credit-losses-methodology-for 

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Type of Policy:  Interim final rule. 

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Expires:  Banks have until the end of 2020 to adopt CECL to take advantage of the extended phase-in (Comments on the IFR are due May 15, 2020)

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Summary of Action:  FRB will not take action against small financial institutions, i.e. banks with less than $5 billion in assets, for submitting March 31, 2020 financial statements (FR Y-9C or FR Y-11, as applicable) after the deadline, so long as reports are filed by 30 days after the deadline.

 

https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200326b.htm

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Type of Policy:  Agency statement.

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Expires:  Until further notice.

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Summary of Action:  FFIEC agencies will not take action against banks that fail to submit March 31, 2020 call reports by the filing deadline, as long as reports are filed by 30 days after the deadline.

 

https://www.ffiec.gov/press/pr032520.htm

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Type of Policy:  Agency statement. 

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Expires:  Banks have 30 additional days to submit call report.

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Summary of Action:  FRB explanation of supervisory approach during crisis, including the following: (1) FRB will not criticize FIs that work with borrowers (consistent with interagency statement issued on 3/22/20), (2) FRB will increase focus on monitoring, and decrease focus on examinations (including ceasing exams for banks under $100 billion in assets), and (3) FRB will provide additional time to remediate supervisory findings.  Banks still expected to submit CCAR plans by April 6, 2020.

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https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200324a.htm

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Type of Policy:  Agency statement.

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Expires:  No expiration.

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Summary of Action:  Delay in implementation of changes to Payment Systems Risk Policy, governing the provision of intraday credit to U.S. branches of foreign banks, from April 1 to October 1, in order to allow banks to focus on heightened priorities (COVID-19) instead of establishing new arrangements for intraday credit.

 

https://www.federalreserve.gov/newsevents/pressreleases/other20200324a.htm

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Type of Policy:  Notice of delay. 

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Expires: Delays implementation of PSRP changes to October 1, 2020.

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Summary of Action:  Re-establishment of Term Asset-Backed Securities Loan Facility, a crisis-era bailout program, to serve as a funding backstop to facilitate issuance of asset-backed securities.

 

https://www.federalreserve.gov/monetarypolicy/talf.htm

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Type of Policy:  Section 13(3) authority.

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Expires:  September 30, 2020

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Summary of Action:  Establishment of Primary Market Corporate Credit Facility and Secondary Market Corporate Credit Facility to provide liquidity for new and outstanding corporate bonds.

 

https://www.federalreserve.gov/monetarypolicy/pmccf.htm

 

https://www.federalreserve.gov/monetarypolicy/smccf.htm 

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Type of Policy:  Section 13(3) authority. 

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Expires:  September 30, 2020

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Summary of Action:  Relaxes the definition of “eligible retained income,” which serves as a cap on the amount of capital distributions a bank can make.  This will make the onset of capital distribution restrictions more gradual, which according to FRB will prevent banks from limiting lending, by incentivizing use of TLAC buffers for lending, in response to economic shocks (such as that caused by COVID-19).

 

https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200323a.htm

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Type of Policy:  Interim final rule.

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Expires:  No expiration (deadline for comments on the interim final rule is May 11, 2020)

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Summary of Action:  Allows Short-Term Investment Funds operated by national banks to have longer dollar-weighted average portfolio maturity (must be 60 days or less under the rule, can be 120 days or less under the relief) and dollar-weighted average portfolio life maturity (must be less than 120 days under the rule, can be 180 days or less under the relief).

 

https://www.occ.gov/news-issuances/news-releases/2020/nr-occ-2020-38.html

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Type of Policy:  Exemptive Order. 

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Expires:  July 20, 2020

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Summary of Action:  Establishment of Money Market Mutual Fund Liquidity Facility to provide loans to financial institutions secured by assets purchased from money market mutual funds.

 

https://www.federalreserve.gov/newsevents/pressreleases/monetary20200318a.htm

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Type of Policy:  Section 13(3) authority.

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Expires:  September 30, 2020

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> Additional Information:  This facility is another taxpayer bailout for Money Market Funds.  If the SEC doesn’t finally regulate them adequately, we’ll continue to see the same outrageous cycle:  MMFs will reap their profits when times are good while taxpayers pay for their losses when crisis hits. Read more in our Comment Letter.

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Summary of Action:  Re-establishment of financial crisis bailout programs, including the Commercial Paper Funding Facility, to provide a backstop for commercial paper, and the Primary Dealer Credit Facility, to provide a liquidity backstop to primary dealers of FRBNY.

 

https://www.federalreserve.gov/newsevents/pressreleases/monetary20200317a.htm

 

https://www.federalreserve.gov/newsevents/pressreleases/monetary20200317b.htm

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Type of Policy:  Section 13(3) authority.

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Expires:  CPFF terminates on March 17, 2021; PDCF will operate for at least 6 months.

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Summary of Action:  Relaxes the definition of “eligible retained income,” which serves as a cap on the amount of capital distributions banks with insufficient regulatory capital buffers can make.  This will make the onset of capital distribution restrictions more gradual, which according to the agencies will prevent banks from limiting lending, by incentivizing use of capital buffers for lending, in response to economic shocks (such as that caused by COVID-19). 

 

https://www.govinfo.gov/content/pkg/FR-2020-03-20/pdf/2020-06051.pdf

 

Type of Policy:  Interim final rule.

 

Expires: No expiration

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> Additional Information: See Better Markets' comment letter submitted on
May 4, 2020.

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Summary of Action: Effective March 26, 2020, reserve requirements, i.e. the amount banks have to hold as a percentage of deposits, are reduced to zero.  Increases the potential liquidity for banks, allowing greater ability to lend.

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https://www.federalreserve.gov/monetarypolicy/reservereq.htm

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Type of Policy: Monetary policy authority under Section 9 of Federal Reserve Act

 

Expires: No expiration date given. According to FRB: “Currently, the Board has no plans to re-impose reserve requirements.”

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Summary of Action:  Explanation of supervisory expectations during COVID-19 crisis, including that banks will work with customers impacted by the crisis, and explaining that actions such as loan modifications to support customers are viewed as positive action and will not lead to negative supervisory actions.

 

https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200322a.htm; https://www.federalreserve.gov/supervisionreg/srletters/SR2004.htm

 

Type of Policy:  Interagency statement; Supervisory letter

 

Expires: No expiration date

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