Dear Montana Community Banker,

It goes without saying that we are living through unprecedented and uncertain times as the world is dealing with the coronavirus (COVID-19) pandemic. 

The Montana Independent Bankers Association fully supports Montana’s community banks, and we would like to offer our assistance in any way during this time of need.   MIB is working to reschedule and restructure upcoming events to keep our attendees safe and healthy.  Many banks are being forced to consider how they can also keep employees’ and customers’ health and well-being at the forefront of their policies. We have compiled a list of tips and additional resources below to help direct banks when deciding how to embrace this period.  Also, there is a link for a FREE webinar being offered by Financial Education and Development, Inc. on Friday, March 20 that addresses pandemic preparedness and coronavirus’ disruption to the financial industry.

Here are some tips for banks dealing with the coronavirus pandemic:

Safety and Soundness

  • Keep ATMs and branches well-stocked with cash.
  • Maintain extra bank liquidity.
  • Contact correspondent banks and Federal Home Loan Banks to ensure all lines of credit are open and active. Additionally, contact the Federal Reserve Banks to determine discount window availability.
  • Commercial customers will begin to experience cash-flow difficulties which will result in the need for loan modifications. Prepare yourselves for credit issues.
  • Consider temporarily suspending stock buy-back programs.
  • Consider delaying Q1 Dividend payments.

Employee/Customer Health

  • Cash handlers should consider wearing protective gloves.
  • Consider changing the cleaning cycle for your facilities to daily.
  • Have employees clean ATMs and commonly touched surfaces frequently.
  • Conduct staff meetings by phone.
  • Sick employees must stay home when ill.
  • Employees caring for sick family members should consider working remotely.
  • Employees with serious underlying health conditions, including pregnancy, may need special health precautions.
  • Have employees frequently clean lunch and break areas and maintain personal space.
  • Clean drive-in pneumatic tubes and drawer extenders regularly, perhaps as often as each transaction.
  • Ask employees if they or any family members have recently traveled to high risk countries or areas such as Italy or China and if so, ask them to work remotely.
  • Overcommunicate with your employees so they understand you have their best interest in mind.
  • Ask your employees for their suggestions on the best way to continue to serve your customers while keeping all employees safe.
  • Limit non-essential business travel for your employees and ask them to limit non-essential personal travel.
  • Keep hand sanitizer and tissues available for employees and customers. Consider card/place cards reminding staff to keep their hands away from their face, wash hands often and frequently sanitize after customer interaction or with money or paperwork customers have touched.
  • Ensure all applicable staff is current with training to assist customers with all online banking needs, including expanding online usage for current customers
  • Note that many of these recommendations are best practices for good hygiene for permanent incorporation into office procedures.
  • Monitor your email for communications from Federal and State bank regulatory agencies.
  • Do your board meetings via conference call rather than in-person meetings.


  • Be sure to communicate frequently with your customers.
  • Use all available communication tools such as: social media, email, on-hold messages, lobby posters, electronic billboards, and statement messages.
  • Try to keep your lobby open if possible to do so. Opening every other teller station is a way to maintain social distancing. If you feel you need to close your lobby, try to see customers on an appointment-only basis.
  • Reach out to key customers and local centers of influence to assure them your bank will be there for them and for the community.
  • Open all drive-up windows. Consider additional staffing and additional hours to serve your clients. Opening drive-ups before and after work hours might be a great way to relieve lobby traffic.
  • Fully staff your call centers and make sure you keep call hold times to a minimum. Be sure to use message-on-hold communications for those that do need to be placed on hold.
  • Think about using courier services and armored car services to conduct business with your commercial clients.
  • Consider a “skip a pay” program for consumer loans in April.
  • Be sure to warn your customers of potential scams. Thieves will try to capitalize on this situation.


Earlier this week, the Montana Division of Banking issued guidance to Montana’s banks.  The guidance is as follows: 

Montana Statement on Financial Institutions Working with Customers Affected by the Coronavirus and Regulatory Assistance

The Montana Division of Banking and Financial Institutions (Division) recognizes the potential for the Coronavirus Disease (referred to as COVID-19) to adversely affect the customers and operations of financial institutions. The Division encourages financial institutions to take steps to meet the financial services needs of affected customers and communities. The Division will provide appropriate regulatory assistance to affected financial institutions subject to their supervision, as warranted.

Working with Customers: The Division encourages financial institutions to work with affected customers and communities. The Division recognizes that such efforts serve the long-term interests of communities and the financial system when conducted with appropriate management oversight and consistent with safe and sound banking practices and applicable laws. These efforts may include, but are not limited to:

  • Waiving certain fees, such as:

o Automated teller machine (ATM) fees for customers and non-customers,

o Overdraft fees,

o Late payment fees on credit cards and other loans, and

o Early withdrawal penalties on time deposits;

  • Increasing ATM daily cash withdrawal limits;
  • Easing restrictions on cashing out-of-state and non-customer checks;
  • Increasing credit card limits for creditworthy borrowers; and
  • Offering payment accommodations, such as allowing borrowers to defer or skip some payments or extending the payment due date, which would avoid delinquencies and negative credit bureau reporting caused by COVID-19 related disruptions.

The Division emphasizes that prudent efforts to modify the terms on existing loans for affected customers will not be subject to examiner criticism. For example, when appropriate, a financial institution may restructure a borrower’s debt obligations due to temporary hardships resulting from COVID-19 related issues. Such cooperative efforts can ease cash flow pressures on affected borrowers, improve their capacity to service debt, and facilitate the financial institution’s ability to collect on its loans.

Financial institutions may also ease terms for new loans to affected borrowers, consistent with prudent banking practices. Such practices may help borrowers to recover or maintain their financial capacity and enhance their ability to service their debt.

Any decision by the Bank or its Board to ease terms to help an affected borrower should be specifically documented in the minutes of the Board meeting and the loan file as being made as a COVID-19 accommodation.

The Division recognizes there may be other accommodations that could assist customers and communities in responding to challenges from COVID-19. The Division supports and will not criticize efforts to accommodate customers in a safe and sound manner. The Division encourages financial institutions to work with their regulator regarding additional actions that may more effectively manage or mitigate any adverse impact due to COVID-19.

Financial Condition Review, Supervisory Response, and Regulatory Relief: The Division appreciates that some financial institutions with customers affected by COVID-19 related issues may experience an increase in their levels of delinquent and nonperforming loans. Consistent with long-standing practices, the Division will consider the unusual circumstances these financial institutions face when reviewing an institution’s financial condition and determining any supervisory response. As needed, the Division will work with affected financial institutions to reduce burden when scheduling examinations or inspections, including making greater use of off-site reviews, consistent with applicable legal and regulatory requirements.

Regulatory Reporting Requirements: Financial institutions affected by COVID-19 related issues that expect to encounter difficulty meeting regulatory reporting requirements, including audited financial statements and related reports, as applicable, are encouraged to contact the Division to discuss their situation. The Division’s staff stand ready to work with affected financial institutions that may experience problems fulfilling their reporting responsibilities, considering each financial institution’s circumstances.

Alternative Service Options for Customers: The Division understands that financial institutions may need to temporarily close a facility due to staffing challenges or to take precautionary measures. The Division encourages financial institutions to reduce disruptions to their customers, provide alternative service options when practical, and reopen affected facilities when it is safe to do so. Affected financial institutions do not need to notify the Division of temporary closure of an institution’s facilities unless the institution is unable to provide financial services in some other manner, as such as ATMs, drive through branches or mobile apps. If a financial institution must change hours at an existing facility, please provide a copy of the customer notice as provided herein. This is required by Mont. Code Ann. § 32-1-484.

Should you need additional resources on the COVID-19 pandemic, please consider the following:

MIB strongly encourages member banks to participate in a FREE Webinar, hosted by Financial Education and Development, Inc. (Community Bankers Webinar Network).  The “Pandemic Preparedness: Managing Coronavirus & Other Epidemics” webinar will be available Friday, March 20. Use the attached link for additional information and to sign up.


Finally, the Division of Banking and Financial Institutions has a means for you to obtain immediate information on this topic. 

To update your contact information, check your subscription preferences, or add a new email address in govDelivery, please go to https://public.govdelivery.com/accounts/MTDOA/subscriber/new?preferences=true#tab1. Once there, you can enter your email address and click the submit button.

A list of your current subscriptions will be listed as well as a link at the bottom to “Add Subscriptions”. At a minimum, please subscribe to Bank Emergency Notices or CU Emergency Notices as applicable.

As stated above, MIB is here to support our community bankers.  We will pass along any update or additional information we may receive.  As always, do not hesitate to reach out to me at jbrown@mibonline.org or call the office at 406-449-7444 with questions.  We will do our best to answer questions or attempt to find answers.  Stay safe and best wishes for the coming days!


James E. Brown, Esq.



From the Governor’s coronavirus task force


The state recognizes the substantial economic impact that some businesses have experienced due to novel coronavirus or COVID-19. The Department of Commerce in partnership with the U.S. Small Business Administration are working to hard to make emergency funding available for those businesses.


When disaster assistance will be available in Montana

If a small business has suffered substantial economic injury as a result of COVID-19, it may be eligible for financial assistance from the U.S. Small Business Administration.

Small businesses and small agricultural cooperatives that have suffered substantial economic injury may be eligible for the SBA’s Economic Injury Disaster Loan (EIDL) Program.

Substantial economic injury is the inability of a business to meet its obligations as they mature and to pay its ordinary and necessary operating expenses.

An EIDL can help meet necessary financial obligations that a business could have met had the disaster not occurred.

It provides relief from economic injury caused directly by the disaster and permits the business to maintain a reasonable working capital position during the period affected by the disaster.

The SBA provides EIDL assistance only to those businesses that SBA determines are unable to obtain credit elsewhere.

The loan amount will be based on the business’ actual economic injury and financial needs.

The interest rate on EIDLs is currently at 3.75 percent per year.

The term of the loans cannot exceed 30 years.

Terms and conditions will be determined by the business’ ability to repay the loan






This week, President Trump issued a national call to action: Use the next 15 days to slow the spread of Coronavirus and protect our most vulnerable citizens from illness.
Many of the common-sense steps he outlined are simple, such as washing your hands regularly, avoiding large gatherings, and working from home if possible. But as health experts explain, small actions by each of us can lead to a massive collective impact.
 Do your part – slow the spread now!
Social distancing, for example, is one of the most important actions every American can take. Dr. Deborah Birx, the Administration’s Coronavirus Response Coordinator, says that social distancing is “what we refer to when we ask people to stay six feet apart.”
Why six feet apart? Because scientific evidence shows “that’s how far your droplets can go when you sneeze or cough,” Dr. Birx says.
🎬 Surgeon General: Why millennials should take Coronavirus seriously




ICBA offers Washington coronavirus response playbook

Mar 18, 2020 

ICBA recommended the Trump administration and Congress enact several stimulus measures to help community banks support local communities amid the coronavirus outbreak.

Following intensive discussions with community bankers since the beginning of the crisis, ICBA encouraged the White House, Treasury Department, and relevant congressional committees to:

  • Raise the annual issuance limit for bank-qualified municipal bonds to $30 million from $10 million.
  • Allow more banks to access the Small Business Administration’s low-doc, expedited 7(a) loan program.
  • Exempt from taxation interest on community bank small-business loans and loans secured by agricultural real estate or primary residences in rural communities.
  • Reduce the Community Bank Leverage Ratio from 9 percent to 8 percent.
  • Delay implementation of the Current Expected Credit Loss accounting standard.

In a separate message, ICBA expressed support for legislation introduced by Senate Banking Committee member Kevin Cramer (R-N.D.) to set the CBLR at 8 percent and extend CECL implementation for community banks until 2025.

ICBA also sent letters to the House and Senate Agriculture committees advocating reforms to support farm borrowers and agricultural communities. Those recommendations include trade aid payments, tax provisions for farm and mortgage borrowers, enhanced government guaranteed loan programs, and more.

ICBA will continue working with policymakers to advance these and other pro-community bank policies.


Trump Signs Coronavirus Aid Package with Paid Sick Leave, Free Testing

“President Trump on Wednesday signed into law a multibillion-dollar emergency aid package aimed at helping Americans impacted by the coronavirus,” Morgan Chalfant reports in The Hill.
The bipartisan measure, resulting from negotiations last week between the Trump Administration and Congress, “includes provisions offering paid leave benefits for Americans, bolstered unemployment benefits and free diagnostic testing for the virus.”
Click here to read more.



Pandemic Planning : Joint Statement on Community Reinvestment Act Consideration for Activities in Response to COVID-19




The Office of the Comptroller of the Currency (OCC), along with the Board of Governors of the Federal Reserve System (Federal Reserve) and the Federal Deposit Insurance Corporation (FDIC) (collectively, the agencies), recognize the potential for Coronavirus Disease (also referred to as COVID-19) to adversely affect the customers and operations of financial institutions. The agencies encourage financial institutions to work with affected customers and communities, particularly those that are low- and moderate-income. The agencies recognize that such efforts—when consistent with safe and sound banking practices and applicable laws, including consumer protection laws—serve the long-term interests of these communities and the financial system.


On March 9, 2020, the federal financial institution regulatory agencies and state bank regulators issued a statement to encourage financial institutions to meet the financial services needs of their customers and members in areas affected by COVID-19.2 Consistent with the March 9, 2020, statement, the OCC, Federal Reserve, and FDIC

  • encourage financial institutions to work with affected customers and communities, particularly those that are low- and moderate-income.
  • clarify that financial institutions will receive Community Reinvestment Act (CRA) consideration for qualifying community development activities.

Further Information

Please contact the Community Reinvestment Act and Fair Lending Policy unit at (202) 649-5470.



FDIC chief urges CECL delay


FDIC Chairman Jelena McWilliams urged the Financial Accounting Standards Board to postpone implementation of the Current Expected Credit Losses accounting standards due to the coronavirus outbreak. McWilliams said the CECL accounting changes could strain the ability of some banks to serve their communities in a time of need.


Among other recommendations, McWilliams also called on FASB not to classify coronavirus-related loan modifications as troubled debt restructurings. She noted that the FDIC has encouraged banks to work with borrowers affected by COVID-19, including through loan modifications.


ICBA this week has repeatedly advocated delaying CECL as part of a slew of recommended stimulus measures to address the coronavirus outbreak. ICBA strongly supports new legislation introduced by Senate Banking Committee member Kevin Cramer (R-N.D.) to extend CECL implementation for community banks until 2025 and reduce the Community Bank Leverage Ratio from 9 percent to 8 percent.


In a new document and in letters to the Trump administration and Congress, ICBA advocated these policies as well as measures to: raise the annual issuance limit for bank-qualified municipal bonds, expand access to the SBA 7(a) loan program, and enact tax exemptions for small-business and agricultural loans.


In a joint letter Wednesday, ICBA and other groups also called on Washington to immediately provide unsecured credit to businesses of all sizes, suspend business tax filings for the duration of the pandemic, and restore the ability of businesses to carryback any net operating losses against previous-year tax payments.




CRA consideration for coronavirus response


Federal banking regulators continued their response to the coronavirus outbreak, clarifying that they will provide favorable Community Reinvestment Act consideration of certain activities related to the national emergency.


The agency announcement follows several recent steps to improve flexibility during the outbreak. The FDIC has said it will work to reduce exam burdens and will conduct supervisory activities off-site for at least two weeks. Regulators have also encouraged banks to use their capital and liquidity buffers as they respond to the outbreak.


Additional regulatory announcements responding to the coronavirus outbreak are available on ICBA’s Crisis Response and Preparedness Center. Community bankers can contact ICBA directly at crisisresponse@icba.org.




During yesterday’s Community Banking Briefing webinar, ICBA President and CEO Rebeca Romero Rainey and ICBA staff experts discussed the coronavirus (COVID-19) pandemic, its effect on community banks, and resources for your bank to use.


If you were unable to attend, there is a free recording available for viewing.


Be sure to visit ICBA’s Crisis Response and Preparedness page for on-going updates and resources for your bank during this time.


Let us know how your community bank is responding to the COVID-19 outbreak by taking a brief survey.





While the Federal Reserve has promised to pump trillions of dollars through large banks to keep financial markets moving, and rolled out support for large company debt, perhaps the most serious economic aspect of the coronavirus crisis is yet to be solved: how to get funds all the way to families and small businesses bearing the brunt of the shutdowns across America. The country’s thousands of community banks and regional banks may be part of the answer. Using a playbook they have developed over years dealing with crises from floods and tornadoes to superstorm Sandy, which ravaged the east coast in 2012, many have already started to help their own customers.




ICBA issues coronavirus bill summary


ICBA released a summary of the ICBA-advocated provisions in the Senate-passed Coronavirus Aid, Relief, and Economic Security Act, which is expected to pass the House and be signed into law as soon as today.


Following relentless ICBA advocacy, the CARES Act includes several ICBA-advocated measures to help community banks support their communities. The bill would:

  • enhance the Small Business Administration’s 7(a) loan program,
  • advance net-operating-loss tax relief,
  • increase the amount of interest expenses businesses may deduct on their tax returns,
  • ensure robust FDIC deposit insurance coverage,
  • delay implementation of the Current Expected Credit Losses accounting standard,
  • provide temporary relief from troubled-debt-restructuring classifications,
  • reduce the Community Bank Leverage Ratio from 9 percent to 8 percent during the COVID-19 emergency, and
  • support livestock and specialty crop producers.

ICBA is encouraging regulators to issue guidance to answer open questions regarding the details of these provisions and will continue to keep community bankers informed of these developments.


Additional information and resources about the COVID-19 response are available on ICBA’s Crisis Response and Preparedness Center.




  1. Thank you for participating in the call with Melanie Hall today.


  1. A reminder that we have arranged a call with Congressman Gianforte for this coming Tuesday at 1015 am.  Again, 1015 AM


MBA’s membership will be joining us on that call.


Here are the call in details


Topic: MIB-MBA Meeting with Rep. Gianforte

Time: Mar 31, 2020 10:30 AM Mountain Time (US and Canada)


Join Zoom Meeting



Meeting ID: 393 059 731


One tap mobile

+16699009128,,393059731# US (San Jose)

+13462487799,,393059731# US (Houston)


Dial by your location

        +1 669 900 9128 US (San Jose)

        +1 346 248 7799 US (Houston)

        +1 301 715 8592 US

        +1 312 626 6799 US (Chicago)

        +1 646 558 8656 US (New York)

        +1 253 215 8782 US

Meeting ID: 393 059 731

Find your local number: https://zoom.us/u/aqyvgyBpD




U.S. Department of Labor | March 26, 2020


U.S. Department Of Labor Announces Additional Guidance

Explaining Paid Sick Leave and Expanded Family and Medical Leave

Under The Families First Coronavirus Response Act


WASHINGTON, DC – Today, the U.S. Department of Labor’s Wage and Hour Division (WHD) announced more guidance to provide information to workers and employers about how each will be able to take advantage of the protections and relief offered by the Families First Coronavirus Response Act (FFCRA) when it takes effect on April 1, 2020.


The new guidance includes two new posters, one for federal workers and one for all other employees, that will fulfill notice requirements for employers obligated to inform employees about their rights under this new law. It also includes questions and answers about posting requirements, and a Field Assistance Bulletin describing WHD’s 30-day non-enforcement policy. The new guidance addresses critical issues such as whether employers may post required notice electronically, whether employers must provide notice of this law to recently laid-off individuals, when FFCRA applies to federal workers and when enforcement of the new rules will begin.


“The Wage and Hour Division continues to prioritize providing this vital information to workers and employers so that both are fully prepared to maximize the benefits available to them as quickly as possible when this law goes into effect on April 1, 2020,” said Wage and Hour Division Administrator Cheryl Stanton. “These critical protections will provide a lifeline to untold numbers of struggling families, and to countless employers trying to balance their business needs with the needs of their workers, their communities and their own families.”


FFCRA will help the United States combat and defeat COVID-19 by giving all American businesses with fewer than 500 employees tax credits to provide employees with paid leave, either for the employee’s own health needs or to care for family members. The legislation will enable employers to keep their workers on their payrolls, while at the same time ensuring that workers are not forced to choose between their paychecks and the public health measures needed to combat the virus.


The guidance announced today augments information WHD published yesterday, including a Fact Sheet for Employees, a Fact Sheet for Employers and a Questions and Answers document. Additional guidance is forthcoming.


WHD provides additional information on common issues employers and employees face when responding to COVID-19 and its effects on wages and hours worked under the Fair Labor Standards Act and job-protected leave under the Family and Medical Leave Act at https://www.dol.gov/agencies/whd/pandemic.


For more information about the laws enforced by the WHD, call 866-4US-WAGE, or visit www.dol.gov/agencies/whd.


For further information about COVID-19, please visit the U.S. Department of Health and Human Services’ Centers for Disease Control and Prevention.


WHD’s mission is to promote and achieve compliance with labor standards to protect and enhance the welfare of the nation’s workforce. WHD enforces federal minimum wage, overtime pay, recordkeeping and child labor requirements of the Fair Labor Standards Act. WHD also enforces the Migrant and Seasonal Agricultural Worker Protection Act, the Employee Polygraph Protection Act, the Family and Medical Leave Act, wage garnishment provisions of the Consumer Credit Protection Act and a number of employment standards and worker protections as provided in several immigration related statutes. Additionally, WHD administers and enforces the prevailing wage requirements of the Davis Bacon Act and the Service Contract Act and other statutes applicable to federal contracts for construction and for the provision of goods and services.



IF YOU ARE LOOKING FOR ADDITIONAL GUIDANCE IN THIS AREA, ICBA has some excellent resources for you to use.  These are as follows



On Wednesday of this week, ICBA hosted a webinar that addressed employment law working with a team from Jackson Lewis, a national law firm with considerable expertise in this area. Please note that the information is coming at all of us fast and furiously.  In fact, details shared on the 3/25 webinar were further updated by lawmakers as recently as last night.  The most up-to-date information is posted on the Jackson Lewis website.  ICBA is working on scheduling a second webinar with the firm and ICBA will share details as soon as they are confirmed. 



  1. March 25, 2020 ICBA’s Coronavirus in the Workplace Webinar – Jackson Lewis https://www.03-25-2020-coronavirus-in-the-workplace-webinar.html
  2. Jackson Lewis has created a robust coronavirus webpage for reference at www.jacksonlewis.com/practice/coronaviruscovid-19




Coronavirus stimulus with ICBA-advocated measures signed into law


Following relentless ICBA advocacy on behalf of the nation’s community banks, President Donald Trump signed into law bipartisan economic stimulus legislation responding to the coronavirus outbreak.


The Coronavirus Aid, Relief, and Economic Security Act includes several ICBA-advocated measures that will better enable community banks to provide needed credit in local communities.


Trump signed the bill into law Friday after it passed the House on a voice vote following a unanimous vote in the Senate earlier in the week.


ICBA President and CEO Rebeca Romero Rainey thanked community bankers for being on the front line helping local communities during the coronavirus pandemic. “While you have stood strong for your customers and communities, ICBA has been standing strong in Washington to shape and advance this critical legislation to support you during this uncertain time,” she said.


The CARES Act:

  • enhances the Small Business Administration’s 7(a) loan program,
  • provides net-operating-loss tax relief,
  • authorizes robust FDIC deposit insurance coverage for transaction accounts,
  • delays implementation of the Current Expected Credit Losses accounting standard,
  • ensures coronavirus-related loan modifications are not classified by regulators as troubled debt restructurings,
  • reduces the Community Bank Leverage Ratio from 9 percent to 8 percent during the COVID-19 national emergency, and
  • funds USDA Commodity Credit Corporation support for livestock and specialty crop producers.

ICBA offers a summary of key provisions in the law, including mortgage-forbearance measures, and is encouraging regulators to issue guidance as soon as possible to answer questions regarding the details.


ICBA will continue to provide information to community bankers about the new law as the details come into focus. Additional information and resources about the COVID-19 response are available on ICBA’s Crisis Response and Preparedness Center.


Regulatory Capital : Joint Statement on the Interaction of the Revised Transition of the CECL Methodology for Allowances With Section 4014 of the CARES Act



On March 27, 2020, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, the agencies) issued an interim final rule that delays the estimated impact on regulatory capital stemming from the implementation of Accounting Standards Update No. 2016-13, “Financial Instruments—Credit Losses,” Topic 326,

“Measurement of Credit Losses on Financial Instruments” (commonly referred to as CECL1) for a transition period of up to five years. Also on March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law. The CARES Act provides banking organizations with optional, temporary relief from complying with CECL. Today’s joint statement clarifies the interaction between the CECL interim final rule and the CARES Act for purposes of regulatory capital requirements.


  • The CARES Act provides banking organizations that are required to adopt CECL in 2020 in accordance with Topic 326 with optional, temporary relief from complying with CECL (statutory relief) during the statutory relief period, which ends on the earlier of
    • the termination date of the current national emergency, declared by the President on March 13, 2020, under the National Emergencies Act concerning the COVID-19 outbreak, or
    • December 31, 2020.
  • Banks that elect to use the optional, temporary statutory relief may delay compliance with CECL until the statutory relief period expires and then elect the remaining period of regulatory capital relief provided under the CECL interim final rule.
  • Alternately, banking organizations may continue adopting CECL in 2020 and use the regulatory capital relief provided under the CECL interim final rule starting at the time of adoption.
  • The CECL interim final rule does not replace the current three-year transition option in the 2019 final rule announced in OCC Bulletin 2019-10, “Implementation of the Current Expected Credit Losses Standard: Final Rule.” The option remains available to any banking organization at the time that it adopts CECL. Banking organizations that have already adopted CECL have the option to elect the three-year transition option contained in the 2019 CECL rule or the five-year transition contained in the CECL interim final rule.

Further Information

Please contact the following individuals with Capital Policy at (202) 649-6370: Mark Ginsberg, Senior Risk Expert; Benjamin Pegg, Senior Risk Expert; Jung Sup Kim, Risk Specialist. Also contact John P. Shelly, Professional Accounting Fellow, Office of the Chief Accountant, at (202) 649-6550, or Kevin Korzeniewski, Counsel, Chief Counsel’s Office, at (202) 649-5490.

Grovetta N. Gardineer
Senior Deputy Comptroller for Bank Supervision Policy

Related Links

1 CECL stands for current expected credit losses.
2 The term “banks” refers collectively to national banks, federal savings associations, and federal branches and agencies of foreign banking organizations.




I know you have been getting calls from small business customers since the CARES Act was passed and signed into law only a couple of days ago. In just the last couple of hours the United States Treasury Department released information and resources (with more to follow) on the Small Business Administration’s $349 billion lending program under the Coronavirus Aid, Relief, and Economic Security Act.


The new Paycheck Protection Program expands the SBA’s 7(a) loan program to help small businesses cover their near-term operating expenses and retain employees. The following was copied from the Treasury website and will provide guidance and forms needed to launch the program at your institution.



The Paycheck Protection Program prioritizes millions of Americans employed by small businesses by authorizing up to $349 billion toward job retention and certain other expenses.


Small businesses and eligible nonprofit organizations, Veterans organizations, and Tribal businesses described in the Small Business Act, as well as individuals who are self-employed or are independent contractors, are eligible if they also meet program size standards.





You can view the Treasury’s website here: https://home.treasury.gov/cares



The SBA website where more information can be found is at this link: https://www.sba.gov/page/coronavirus-covid-19-small-business-guidance-loan-resources



Information will likely begin flowing much faster as the agencies launch these programs. MIB, in concert with ICBA, will be monitoring all sites and helping you get factual information and the latest resources to help your customers while containing COVID-19’s economic damage in our communities.