RESPONSE TO CORONAVIRUS DISEASE 2019 (COVID-19) 11 

2020

 

RESPONSE TO CORONAVIRUS DISEASE 2019 

(COVID-19)

In January 2020, a novel coronavirus, SARS-CoV-2, was 

identified as the cause of an outbreak of viral pneumonia 

in Wuhan, China. The disease, later named coronavirus 

disease 2019 (COVID-19), subsequently spread globally. 

The rapid spread of the virus disrupted the economy and 

increased volatility in global financial markets. 

By March 11, 2020, the World Health Organization 

(WHO) declared COVID-19 a global pandemic. The FDIC 

implemented strategies to address challenges related 

to COVID-19 to maintain stability and public confidence 

in the nation's financial system. These actions have 

focused on providing necessary flexibility to both banks 

and their customers —particularly the most heavily 

afected individuals and businesses — while maintaining 

the overall safety and soundness of the banking system. 

In February 2020, the FDIC established a Coronavirus 

Working Group and named a Pandemic Coordinator, 

shortly afer credible information and reports from the 

Centers for Disease Control and Prevention and the 

WHO revealed the seriousness and widespread impact 

of COVID-19. The FDIC’s pre-planning eforts and early 

decisions proved to be extremely helpful in positioning 

the agency to communicate information and guidance 

to the workforce, implement proactive measures, 

provide recommendations to senior leadership, and 

marshal resources where needed. Among several key 

actions, the FDIC: 

♦ Restricted non-mission-essential travel;

♦ Created a Health and Safety Working Group;

♦ Created a COVID-19 webpage;

♦ Issued a mandatory telework policy for employees;

♦ Approved flexible telework arrangements;

♦ Provided global messaging, call-ins, and videos

for employees;

♦ Approved the ability for employees to conduct

examinations and supervisory functions of-site;

♦ Re-negotiated contracts for reduced services

and prices;

♦ Hired a contractor specializing in preparedness,

response, and recovery for public health

emergencies to assist with health and safety

issues and questions;

♦ Enhanced the use of Microsof® Teams for

collaboration;

♦ Instituted virtual hiring and onboarding;

♦ Developed a new approach to bank closings; and

♦ Created a Return to the Ofice Plan.

♦ Provided virtual training for bank examiners;

♦ Modified on-site contracts to accommodate

remote work;

In March 2020, the FDIC created a page on our public 

website (www.fdic.gov) to help consumers and bankers 

to stay abreast of current events related to COVID-19 and 

to remind Americans that FDIC-insured banks remain the 

safest place to keep their money. The FDIC also warned 

consumers of scams involving imposters pretending 

to be agency representatives to perpetrate fraudulent 

schemes. 

RULEMAKING AND 

GUIDANCE ISSUED 

As it became clear that the public health emergency 

caused by COVID-19 would lead to a significant economic 

disruption, the FDIC worked to (1) encourage banks to 

work with afected customers and communities, (2) 

increase flexibility for banks to meet the needs of their 

customers, (3) foster small business lending, (4) protect 

consumers and increase financial options, and (5) 

actively monitor the financial system. 

On March 9, 2020, the FDIC, Board of Governors of the 

Federal Reserve System (FRB), Ofice of the Comptroller 

of the Currency (OCC), Consumer Financial Protection 

Bureau (CFPB), National Credit Union Administration 

(NCUA), and the Conference of State Bank Supervisors 

(CSBS) issued a press release encouraging financial 

on the customers, members, and operations of many 

institutions to meet the financial needs of customers 

and members afected by the coronavirus. The agencies 

recognized the potential impact of the coronavirus 
12 RESPONSE TO CORONAVIRUS DISEASE 2019 (COVID-19)

ANNUAL 

REPORT

financial institutions and stated they would provide 

appropriate regulatory assistance to afected institutions 

subject to their supervision. The agencies noted that 

financial institutions should work constructively with 

borrowers and other customers in afected communities 

and prudent eforts that are consistent with safe and 

sound lending practices would not be subject to 

examiner criticism. The agencies further stated that 

they understand that many financial institutions may 

face stafing and other challenges. In cases in which 

operational challenges persisted, regulators would 

expedite, as appropriate, any request to provide 

more convenient availability of services in afected 

communities. The regulators also stated that they would 

work with afected financial institutions in scheduling 

examinations or inspections to minimize disruption and 

burden. 

On March 13, 2020, the FDIC issued an FDIC-only 

statement encouraging institutions to take prudent 

steps to assist customers and communities afected 

by COVID-19. The FDIC acknowledged that this unique 

and evolving situation could pose significant temporary 

business disruptions and challenges, and encouraged 

financial institutions to work with all borrowers, 

especially borrowers from industry sectors particularly 

vulnerable to the volatility in the current economic 

environment and small businesses and independent 

contractors that are reliant on afected industries. 

The FDIC advised that a financial institution’s prudent 

eforts to modify the terms on existing loans for afected 

customers will not be subject to examiner criticism, and 

committed to work with afected financial institutions to 

reduce burden when scheduling examinations, including 

making greater use of of-site reviews, consistent with 

applicable legal and regulatory requirements. The 

FDIC further stated it stood ready to work with financial 

institutions that may experience challenges fulfilling 

their regulatory reporting responsibilities and would 

act expeditiously if institutions needed to temporarily 

close facilities. The FDIC also announced that it had 

launched a COVID-19 webpage on its public website to 

provide useful information to bankers, consumers, and 

others. The website is located at https://www.fdic.gov/ 

coronavirus/index.html. 

On March 16, 2020, the FDIC, FRB, and OCC released 

a statement encouraging banks to use the Federal 

Reserve’s “discount window” so that they can continue 

supporting households and businesses. By providing 

ready access to funding, the discount window helps 

banks manage their liquidity risks eficiently and avoid 

actions that have negative consequences for their 

customers. Thus, the discount window supports the 

smooth flow of credit to households and businesses. 

On March 17, 2020, the FDIC, FRB, and OCC announced 

two actions to support the U.S. economy and 

allow banks to continue lending to households and 

businesses. The actions included: 

♦ A statement encouraging banks to use their capital

and liquidity bufers to support households and

businesses; and

♦ An interim final rule that facilitates the use of a

bank’s capital bufers to promote lending activity to

households and businesses.

The statement noted that banks have more than 

doubled their capital and liquidity levels over the past 

decade and are now substantially safer and stronger 

than they were previously. As a result, the agencies 

encouraged banks to use that strength to support 

households and businesses. The interim final rule 

was a technical change to the definition of eligible 

retained income in the capital conservation bufer. The 

revised definition of eligible retained income made any 

automatic limitations on capital distributions that could 

apply under the agencies’ capital rules more gradual. 

On March 20, 2020, this interim final rule was published 

in the Federal Register. On October 8, 2020, a final rule 

was published that adopted the interim final rule without 

changes to the definition of eligible retained income, 

with an efective date of January 1, 2021. 

On March 19, 2020, the FDIC, FRB, and OCC announced 

an interim final rule to ensure banks could efectively use 

the Money Market Mutual Fund Liquidity Facility (MMLF). 

The interim final rule modified the agencies’ capital rules 

by permitting a bank to exclude exposures acquired 

as part of the MMLF from the bank’s total leverage 

exposure, average total consolidated assets, advanced 

approaches total risk-weighted assets, and standardized 

total risk-weighted assets, as applicable. On March 23, 

2020, this interim final rule was published in the Federal 

Register. On October 28, 2020, a final rule was published 

that adopted the interim rule with no changes, with an 

efective date of December 28, 2020. 
RESPONSE TO CORONAVIRUS DISEASE 2019 (COVID-19) 13 

2020

On March 19, 2020, Chairman McWilliams wrote a letter 

to the Financial Accounting Standards Board (FASB) 

advocating several actions in light of the unprecedented 

business conditions related to COVID-19. Specifically, 

Chairman McWilliams urged FASB to (1) exclude COVID-19 

related modifications from being categorized as troubled 

debt restructurings (TDRs), (2) allow banks that are 

currently subject to current expected credit losses (CECL) 

the option to postpone implementation of CECL, and (3) 

impose a moratorium on the efective date for CECL for 

institutions not yet subject to CECL. Such actions would 

allow financial institutions to work with their borrowers, 

support lending in their communities, and focus on the 

immediate business challenges related to the pandemic. 

On March 22, 2020, the FDIC, FRB, OCC, CFPB, NCUA, 

and the CSBS issued the Interagency Statement on Loan 

Modifications and Reporting for Financial Institutions 

Working with Customers Afected by the Coronavirus. The 

statement encouraged financial institutions to work 

constructively with borrowers afected by COVID-19 

and provided additional information regarding loan 

modifications. The statement emphasized that not 

all modifications of loan terms result in a TDR. The 

agencies noted that they confirmed with FASB that 

short-term modifications made on a good faith basis in 

response to COVID-19 to borrowers who were current 

prior to any relief are not TDRs. This includes shortterm (e.g., six months) modifications such as payment 

deferrals, fee waivers, extensions of repayment terms, 

or other delays in payment that are insignificant. The 

statement indicates that the agencies’ examiners will 

exercise judgment in reviewing loan modifications, 

including TDRs, and will not automatically adversely 

risk rate credits that are afected, including those 

considered TDRs. Regardless of whether modifications 

are considered TDRs or are adversely classified, the 

statement makes clear that agency examiners will not 

criticize prudent eforts to modify terms on existing loans 

for afected customers. 

On March 26, 2020, the FDIC, FRB, OCC, CFPB, and NCUA 

issued the Joint Statement Encouraging Responsible 

Small-Dollar Lending in Response to COVID-19. The 

statement recognizes that responsible small-dollar loans 

can play an important role in meeting customers’ credit 

needs because of temporary cash-flow imbalances, 

unexpected expenses, or income disruptions during 

periods of economic stress or disaster recoveries. Such 

loans can be ofered through a variety of structures 

including open-end lines of credit, closed-end 

installment loans, or appropriately structured single 

payment loans. The agencies stated that loans should 

be ofered in a manner that provides fair treatment 

of consumers, complies with applicable laws and 

regulations, and is consistent with safe and sound 

practices. For borrowers who experience unexpected 

circumstances and cannot repay a loan as structured, 

financial institutions are further encouraged to consider 

workout strategies designed to help borrowers to repay 

the principal of the loan while mitigating the need to 

re-borrow. In May, the FDIC, FRB, OCC, and NCUA issued 

further guidance related to small-dollar lending, as 

described later in this report. 

On March 27, 2020, the FDIC, FRB, and OCC announced 

two actions to support the U.S economy and allow 

banking organizations to continue lending to households 

and businesses. The actions included: 

♦ Early adoption of the “standardized approach 

for measuring counterparty credit risk” rule, also 

known as SA-CCR. 

♦ An interim final rule that allows banks to mitigate 

the efects of the “current expected credit loss,” 

or CECL, accounting standard on their regulatory 

capital. 

SA-CCR, was finalized by the agencies in November 

2019, with an efective date of April 1, 2020. It reflects 

improvements made to the derivatives market since the 

2007-2008 financial crisis, such as central clearing and 

margin requirements. To help improve current market 

liquidity and smooth disruptions, the agencies permitted 

banks to early adopt SA-CCR for the reporting period 

ending March 31, 2020. 

The interim final rule allowed banks that are required 

under U.S. accounting standards to adopt CECL in 2020 

to mitigate the estimated cumulative regulatory capital 

efects for up to two years. This is in addition to the 

three-year transition period already in place. On March 

31, 2020, this interim final rule was published in the 

Federal Register. On September 30, 2020, the agencies 

adopted the final rule consistent with the interim final 

rule with some clarifications and adjustments related 

to the calculation of the transitions and the eligibility 

criteria for using the 2020 CECL transition provision. 
14 RESPONSE TO CORONAVIRUS DISEASE 2019 (COVID-19)

ANNUAL 

REPORT

On April 3, 2020, the FDIC, FRB, OCC, CFPB, NCUA, 

and CSBS issued the Joint Statement on Supervisory 

and Enforcement Practices Regarding the Mortgage 

Servicing Rules in Response to the COVID-19 Emergency 

and the CARES Act. The statement informed servicers 

of the agencies’ flexible supervisory and enforcement 

approach during the COVID-19 pandemic regarding 

certain communications to consumers required by the 

mortgage servicing rules. The statement facilitated 

mortgage servicers’ ability to place consumers in shortterm payment forbearance programs such as the one 

established by the Coronavirus Aid, Relief, and Economic 

Security Act (CARES Act). The statement clarified 

that the agencies do not intend to take supervisory 

or enforcement action against mortgage servicers for 

delays in sending certain early intervention and loss 

mitigation notices and taking certain actions relating to 

loss mitigation set out in the mortgage servicing rules, 

provided that servicers are making good faith eforts to 

provide these notices and take these actions within a 

reasonable time. To further enable short-term payment 

forbearance programs or short-term repayment plans, 

mortgage servicers ofering these programs or plans 

will not have to provide an acknowledgement notice 

within 5 days of receipt of an incomplete application, 

provided the servicer sends the acknowledgment 

notice before the end of the forbearance or repayment 

period. The guidance also reminds servicers that there 

is existing flexibility in the rules with respect to the 

content of certain notices. Finally, to assist servicers 

experiencing high call volumes from consumers seeking 

help, the statement also confirms that the agencies do 

not intend to take supervisory or enforcement action 

against mortgage servicers for delays in sending annual 

escrow statements, provided that servicers are making 

good faith eforts to provide these statements within a 

reasonable time. 

On April 6, 2020, the FDIC, FRB, and OCC announced 

two interim final rules to provide temporary relief to 

community banking organizations. The two rules 

modified the community bank leverage ratio framework 

so that: 

♦ Beginning in the second quarter 2020 and until 

the end of the year, a banking organization that 

has a leverage ratio of 8 percent or greater and 

meets certain other criteria may elect to use the 

community bank leverage ratio framework; and 

♦ Community banking organizations will have until 

January 1, 2022, before the community bank 

leverage ratio requirement is re-established at 

greater than 9 percent. 

Under these interim final rules, the community bank 

leverage ratio is 8 percent beginning in the second 

quarter and for the remainder of calendar year 2020, 8.5 

percent for calendar year 2021, and 9 percent thereafer. 

These interim final rules also maintained a two-quarter 

grace period for a qualifying community banks whose 

leverage ratio falls no more than 1 percent below 

the applicable community bank leverage ratio. The 

agencies provided community banks with a clear and 

gradual transition back to the 9 percent leverage ratio 

requirement previously established by the agencies. 

This transition allowed community banks to focus on 

supporting lending to creditworthy households and 

businesses given strains on the U.S. economy caused 

by the coronavirus. On April 23, 2020, these interim final 

rules were published in the Federal Register. On October 

9, 2020, a final rule was published in the Federal Register 

that adopted these interim rules with no changes, with 

an efective date of November 9, 2020. 

On April 7, 2020, the FDIC, FRB, CFPB, NCUA, and OCC, 

in consultation with state financial regulators, issued 

the Interagency Statement on Loan Modifications and 

Reporting for Financial Institutions with Customers 

Afected by the Coronavirus (Revised). The revised 

statement clarified the interaction between the 

interagency statement issued on March 22, 2020 and 

the temporary relief provided by Section 4013 of the 

CARES Act, which was signed into law on March 27, 2020. 

Section 4013 allowed financial institutions to suspend 

the requirements to classify loan modifications as TDRs 

if the loan modification is (1) related to COVID-19; (2) 

executed on a loan that was not more than 30 days past 

due as of December 31, 2019; and (3) executed between 

March 1, 2020, and the earlier of (A) 60 days afer the 

date of termination of the National Emergency or (B) 

December 31, 2020. The revised statement also provided 

supervisory interpretations on past due and nonaccrual 

regulatory reporting of loan modification programs and 

regulatory capital. 

On April 9, 2020 the FDIC, FRB, and OCC announced 

an interim final rule to neutralize the regulatory capital 

efect of participation in the Paycheck Protection 

Program Liquidity Facility (PPPLF). The interim final 
RESPONSE TO CORONAVIRUS DISEASE 2019 (COVID-19) 15 

2020

rule permitted a bank to exclude exposures pledged as 

collateral to the PPPLF from the bank’s total leverage 

exposure, average total consolidated assets, advanced 

approaches total risk-weighted assets, and standardized 

total risk-weighted assets, as applicable. Additionally, 

the interim final rule provided that a bank must apply 

a zero percent risk weight to PPP covered loans, as 

required by Section 1102 of the CARES Act. A bank must 

apply a zero percent risk weight to PPP covered loans 

regardless of whether they are pledged under the PPPLF. 

On April 13, 2020, this interim final rule was published 

in the Federal Register. On October 28, 2020, a final rule 

was published in the Federal Register that adopted the 

interim rule with no changes, with an efective date of 

December 28, 2020. 

On April 14, 2020, the FDIC, FRB, OCC, NCUA, and 

CFPB announced an interim final rule to temporarily 

defer real estate-related appraisals and evaluations 

under the agencies’ interagency appraisal regulations. 

The agencies provided this temporary relief to 

allow regulated institutions to extend financing to 

creditworthy households and businesses quickly 

in the wake of the national emergency declared in 

connection with COVID-19. The agencies deferred 

certain appraisals and evaluations for up to 120 days 

afer closing of residential or commercial real estate 

loan transactions. Transactions involving acquisition, 

development, and construction of real estate were 

excluded from this interim rule. On April 17, 2020, this 

interim final rule was published in the Federal Register. 

On October 16, 2020, a final rule was published in the 

Federal Register that adopted the interim rule with one 

revision, with an efective date of October 16, 2020 

through December 31, 2020. The agencies also issued 

the Interagency Statement on Appraisals and Evaluations 

for Real Estate Related Financial Transactions Afected 

by the Coronavirus. This statement outlined existing 

flexibilities provided by industry appraisal standards 

and the agencies’ appraisal regulations – including that 

interior inspections are not required. An appraiser can 

determine the characteristics of a property through 

any combination of property inspection, asset records, 

photographs, property sketches and recorded media. 

For consumers who were eligible to receive economic 

impact payments authorized by the CARES Act from 

the Internal Revenue Service (IRS), the FDIC provided 

information about how to open a bank account and 

provide that bank account information to the IRS. 

During the pandemic many banks ofered ways to open 

accounts remotely — online or through a mobile app — 

without going to a bank branch. The FDIC developed a 

webpage to provide consumers with all the information 

needed to find a bank and open an account online. To 

increase the number of consumers with access to direct 

deposit, the IRS included a link to the FDIC’s economic 

impact payment landing webpage (now #GetBanked). 

By year-end, the FDIC’s resource pages on bank account 

access had received more than 800,000 page views. 

On May 5, 2020, the FDIC, FRB, and OCC announced 

an interim final rule that modifies the agencies’ 

Liquidity Coverage Ratio (LCR) rule to support banking 

organizations’ participation in the Federal Reserve’s 

Money Market Mutual Fund Liquidity Facility (MMLF) 

and the PPPLF. The interim final rule required a covered 

company to neutralize the LCR efects of the advances 

made by the MMLF and PPPLF together with the assets 

securing these advances. On May 6, 2020, this interim 

rule was published in the Federal Register. On October 

28, 2020, a final rule was published in the Federal Register 

that adopted the interim rules with no changes, with an 

efective date of December 28, 2020. 

On May 15, 2020, the FDIC, FRB, and OCC announced 

an interim final rule for temporary changes to their 

supplementary leverage ratio rule. The supplementary 

leverage ratio generally applies to subsidiaries of bank 

holding companies with more than $250 billion in 

total consolidated assets. In order to facilitate banks’ 

significant increases in reserve balances resulting 

from the Federal Reserve’s asset purchases and the 

establishment of various programs to support the 

flow of credit to the economy, as well as the continued 

need to accept exceptionally high levels of customer 

deposits, the interim final rule provided certain banks 

subject to the supplementary leverage ratio the option 

to elect to exclude temporarily Treasuries and deposits 

at Federal Reserve Banks from total leverage exposure 

through March 31, 2021. Under the interim final rule, a 

bank that opts into this treatment is required to obtain 

prior approval of distributions from its primary Federal 

banking regulator. The change is efective as of June 1, 

2020 and will be in efect through March 31, 2021. On 

June 1, 2020, this interim final rule was published in the 

Federal Register. 

On June 23, 2020, the FDIC, FRB, OCC, NCUA, and 

State Financial Regulators issued Interagency Examiner 
16 RESPONSE TO CORONAVIRUS DISEASE 2019 (COVID-19)

ANNUAL 

REPORT

Guidance for Assessing Safety and Soundness Considering 

the Efect of the COVID-19 Pandemic on Institutions. The 

interagency guidance instructed examiners to consider 

the unique, evolving, and potentially long-term nature 

of the issues confronting financial institutions due to 

the COVID-19 pandemic and to exercise appropriate 

flexibility in their supervisory response. The agencies 

also made clear that appropriate actions taken by 

institutions in good faith reliance on statements issued 

by the agencies during the pandemic, within applicable 

timeframes described in such statements, will not be 

subject to criticism or other supervisory action. 

On August 3, 2020, the Federal Financial Institutions 

Examination Council (FFIEC), on behalf of its members, 

issued a statement to provide prudent risk management 

and consumer protection principles for financial 

institutions to consider while working with borrowers 

as loans near the end of the initial loan accommodation 

periods provided during the COVID-19 pandemic. The 

statement also addressed issues relative to accounting 

and regulatory reporting and internal control systems. 

Specifically, FFIEC members encouraged financial 

institutions to consider prudent accommodation 

options that can ease cash flow pressures on afected 

borrowers, improve their capacity to service debt, and 

facilitate institutions’ ability to collect loans, consistent 

with applicable laws and regulations. The statement 

advised that such arrangements may mitigate the 

long-term impact of a financial challenge on borrowers 

by helping to avoid delinquencies or other adverse 

consequences. Further, the agencies stated that 

efective risk management practices include providing 

clear, conspicuous, and accurate communications 

and disclosures to inform borrowers of afordable and 

sustainable accommodation options prior to the end of 

the accommodation period. The statement advised that 

in accordance with U.S. Generally Accepted Accounting 

Principles (GAAP), financial institution management 

should consider the efects of external events, such as 

the COVID-19 pandemic, in its allowance estimation 

processes. Finally, the statement noted that internal 

controls for initial and additional accommodation 

periods should include quality assurance, credit risk 

review, operational risk management, compliance risk 

management, and internal audit functions that are 

commensurate with the size, complexity, and risk of a 

financial institution’s activities. 

On October 20, 2020, the FDIC announced an interim 

final rule to provide temporary relief from Part 363 

Audits and Reporting requirements for institutions 

experiencing growth due to participation in the PPP, 

PPPLF, or MMLF, or other factors, such as other stimulus 

activities.  The interim final rule allowed institutions to 

determine the applicability of Part 363 for fiscal years 

ending in 2021 based on the lesser of the institution’s 

(a) consolidated total assets as of December 31, 2019, 

or (b) consolidated total assets as of the beginning of 

their fiscal years ending in 2021. Notwithstanding any 

temporary relief provided by this interim final rule, an 

institution would continue to be subject to any otherwise 

applicable statutory and regulatory audit and reporting 

requirements. This interim final rule also reserved 

authority for the FDIC to require an institution to comply 

with one or more requirements of Part 363 if the FDIC 

determines that asset growth was related to a merger 

or acquisition. The interim final rule is efective through 

December 31, 2021, unless otherwise extended by the 

FDIC. On October 23, 2020, this interim final rule was 

published in the Federal Register. 

On November 20, 2020, the FDIC, FRB, and OCC 

announced an interim final rule that provided similar 

temporary relief from several other regulations 

applicable to institutions with $10 billion or less in total 

consolidated assets. The interim final rule amended 

such rules by allowing institutions to calculate their asset 

size for applicable thresholds during calendar years 2020 

and 2021 based on the lower of either total assets as 

of December 31, 2019 or total assets as of the normal 

measurement date. The temporary relief applied to the 

community bank leverage ratio, the FDIC’s rule regarding 

management oficial interlocks, the FFIEC 051 Report of 

Condition and Income, and rules regarding examination 

frequency. On December 2, 2020, this interim final rule 

was published in the Federal Register. The interim final 

rule became efective as of December 2, 2020. 

EXAMINATION PROCEDURES 

AND GUIDANCE 

The FDIC maintained its supervisory programs for 

both safety and soundness and consumer protection 

by establishing temporary processes and adding 

flexibility that allowed examiners to continue conducting 

examinations despite the pandemic. These actions 
RESPONSE TO CORONAVIRUS DISEASE 2019 (COVID-19) 17 

2020

 

 

— in addition to technological advancements and 

solutions adopted by the FDIC in the years leading up 

to the pandemic — were critical to the agency’s ability 

to conduct examination activities of-site and fulfill our 

supervisory obligations uninterrupted. 

Recognizing the challenges financial institution 

management faced in the early days of the pandemic, 

the FDIC provided institution management the option 

to temporarily delay examination activities, including 

examination planning. Although most financial 

institutions chose to continue with examinations as 

scheduled, a small number opted for a temporary delay 

due to operational considerations. 

We will continue to conduct examination activities 

predominantly of-site, but have developed plans for 

resuming on-site examination work when public health 

guidelines permit.