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Financial Services Law Insights and Observations

Agencies announce guidance regarding institutions affected by Hawaiian wildfires.

Federal Issues Bank Regulatory Consumer Finance NCUA OCC Federal Reserve FDIC Disaster Relief

Federal Issues

On August 17, the Federal Reserve Board, the FDIC, the Hawaii Department of Commerce and Consumer Affairs’ Division of Financial Institutions, the NCUA, and the OCC issued a joint interagency statement covering supervisory practices for financial institutions affected by the Hawaiian wildfires. The agencies announced that, among other things, the regulators would expedite requests made by institutions for temporary operating facilities. The regulators noted that in most cases, “telephone notice to the primary federal and/or state regulator will suffice” for such requests. The agencies also encouraged financial institutions to work with borrowers in affected communities, explaining that “prudent efforts” to adjust terms on existing loans should not be subject to examiner criticism, in light of the unusual circumstances faced by the financial institutions.

Further, the agencies announced that they understood that damage caused by the wildfires may affect the ability of institutions to comply with publishing requirements for branch closings, relocations, or temporary locations, and instructed institutions experiencing such difficulties to contact their primary federal and/or state regulator. The agencies additionally instructed institutions that face difficulty meeting reporting requirements due to the wildfires to contact their primary federal and/or state regulator, explaining that the agencies “do not expect to assess penalties or take other supervisory action” against institutions that take reasonable steps to comply with reporting requirements. The agencies also announced that financial institutions may receive CRA consideration for loans, investments, or services that revitalize or stabilize federally designated disaster areas. Finally, the agencies encouraged financial institutions to monitor any municipal securities and loans affected by the Hawaii wildfires.