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NCUA issues FAQs regarding Covid-19 and credit union operations
On March 25, the National Credit Union Administration (NCUA) issued FAQs regarding the impact of Covid-19 on the NCUA and credit union operations. The FAQs answer questions regarding, among other things, flexibility for federal credit unions in planning annual meetings and monthly board of director meetings, restrictions on access to or closure of facilities, the impact of Covid-19 on the NCUA’s examination and supervision program, and deadlines for submission of certain filings (e.g., Call Reports, annual capital plan and/or stress testing, Bank Secrecy Act reports).
Montana urges credit unions to work with affected members
On March 20, the Montana Division of Banking and Financial Services issued guidance urging credit unions to work with members and communities affected by Covid-19. Efforts include, among other things, waiving fees, increasing ATM cash withdrawal limits, easing restrictions on cashing checks, easing credit terms for new loans, offering or expanding payday alternative loan programs, increasing credit card limits, and offering payment accommodations to assist members having payment difficulty. The guidance also noted: (i) that “prudent efforts” to modify loan terms would not be subject to examiner criticism, as long as the efforts are documented; (ii) that the Division would work with credit unions to reduce burden when scheduling examinations and inspections, and utilize off-site reviews; (iii) that credit unions should inform the Division of branch or office closures; and (iv) that attendance via electronic communications would constitute in-person attendance at board, committee, and annual meetings.
Michigan Department of Insurance and Financial Services issues FAQs for credit unions
On March 24, the Michigan Department of Insurance and Financial Services issued FAQs for credit unions. The FAQs provide responses to questions regarding continuation of examinations, credit union operations and annual meetings, working with credit union members experiencing hardship due to Covid-19, and reporting requirements.
Indiana Department of Financial Institutions issues statement on essential businesses
On March 23, Indiana Department of Financial Institutions (DFI) issued a statement reiterating that Indiana’s Executive Order 20-08 deems the following financial institutions as essential businesses that are encouraged to stay open and adhere to social distancing guidelines: banks, currency exchanges, consumer lenders, including, but not limited to, credit unions, pawnbrokers, consumer installment lenders and sales finance lenders, title companies, appraisers, financial markets, trading and futures exchanges, payday lenders, affiliates of financial institutions, entities that issue bonds, related financial institutions, and institutions selling financial products.
Kansas Department of Credit Unions releases list of Covid-19 resources
On March 23, the Kansas Department of Credit Unions issued a statement to Kansas chartered credit unions including a list of Covid-19 resources that may be helpful. The list includes resources from both the federal government and the state of Kansas.
NCUA provides urgent needs grants to credit unions during Covid-19 emergency
On March 23, the National Credit Union Administration (NCUA) announced that “[f]ederally insured, low-income designated credit unions” that have been adversely impacted by costs related to Covid-19 may apply for urgent needs grants. The NCUA can provide grants for such things as (i) “[h]ardware, software, or other equipment to help them provide financial products and services from remote locations”; (ii) “[c]onsulting services to develop programs…to assist those affected by COVID-19”; and (iii) “marketing materials to assure members their insured deposits are safe.” Applications for the grants may be found here.
Oregon releases guidance for credit unions during Covid-19
Oregon’s Division of Financial Regulation communicated with credit union CEOs regarding operational adjustments due to Covid-19. Among other things, the state requests notice if credit unions temporarily close branches, decide to offer special programs, or make public statements about their response to Covid-19. The letter also notes that examinations will continue to be conducted offsite.
Montana regulator issues guidance to state banks and credit unions on operating during outbreak
On March 19, the Montana Division of Banking and Financial Institutions issued a supervisory memorandum discussing operations of state-chartered banks and credit unions during the Covid-19 outbreak. The guidance instructs regulated institutions to communicate with the Division using email and electronic file transfer services instead of mail. The guidance also clarifies that the Division considers accepting deposits, providing access to cash and existing customer accounts, and drawing on existing loans to be “essential” services that should be continued during the outbreak, and contains frequently-asked questions about operations and regulatory notifications.
North Carolina issues guidance for credit unions during Covid-19
The North Carolina Credit Union Division notified state-chartered credit unions of certain accommodations for Covid-19. These include (i) conducting examinations offsite; (ii) granting extensions of the deadline to submit quarterly call reports; (iii) conducting meetings electronically, (iv) discouraging in-person board meetings; and (v) permitting the postponement or cancellation of required annual meetings.
New Mexico authorizes credit unions to postpone in-person meetings
On March 18, the New Mexico Regulation and Licensing Department, Financial Institutions Division provided guidance to state-chartered credit unions allowing for postponement or virtual attendance at certain meetings that must normally be conducted in-person. This guidance applies to board meetings, committee meetings, and annual meetings for the duration of the Covid-19 national emergency. Credit unions that comply with the guidance will not be cited during examinations provided that they notify members in advance and arrange for virtual attendance to the extent feasible.