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.  

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.


In March of 2020, 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:


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

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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.



JANUARY 21, 2022

The Division of Banking and Financial Institutions issued a Proclamation of Emergency (Proclamation) on October 5, 2021 that allowed state-chartered institutions to close branches at any time the institution is experiencing severe staffing shortages due to, or exacerbated by, the COVID-19 pandemic, if the institution deems it necessary to protect the safety and security of persons or property or both.

The Proclamation required each institution to develop and implement a plan to continue to provide essential financial services to its customers using ATMs, drive through windows and/or mobile banking applications.  If an institution is unable to continue to provide essential services to its customers, it must notify the Montana Division of Banking and Financial Institutions immediately.  The Proclamation also encouraged banks to reduce their hours rather than fully closing the branch on an emergency basis. 

The Proclamation became effective at 8:00 a.m. on October 5, 2021 and expired on January 1, 2022 at 5 p.m. 

Due to the prevalence of the Omicron variant, and continued staffing challenges being experienced by state-chartered institutions, the Proclamation of Emergency has been extended from October 5, 2021 to May 1, 2022 at 5 p.m.

Please contact our office if you have any questions at 406-841-2920 or banking@mt.gov.

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Use this time to slow the spread of Coronavirus and protect our most vulnerable citizens from illness.

Many of the common-sense steps 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.

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