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Financial Services Law Insights and Observations

FDIC rescinds Covid-19 filing extension for Part 363 annual reports

Bank Regulatory Federal Issues FDIC Covid-19

On March 15, the FDIC rescinded its Statement on Part 363 Annual Reports in Response to the Coronavirus, which had provided certain insured depository institutions (IDIs) with total assets of $500 million or more an additional 45 days to file their Part 363 Annual Reports and Other Reports and Notices. FIL-10-2022 rescinds FIL-30-2020 and is effective for fiscal years beginning after December 31, 2021. Going forward, the deadline for IDIs to file their annual reports “reverts to either 90 or 120 days after the end of the IDI’s fiscal year, depending on the IDI’s status as a public filer.” The FDIC reminded IDIs that if they are unable to meet their filing deadline, they “must submit a written Notice of Late Filing to the FDIC, the appropriate federal banking agency, and any appropriate state bank supervisor by the 90- or 120-day report filing deadline.”