The FDIC has approved temporary relief for financial institutions that have grown as a result of their participation in the Paycheck Protection Program and other stimulus programs.
The new interim final rule (IFR) applies to Part 363 requirements, which require institutions with assets of $500 million or more to be independently audited and meet strict reporting requirements. Part 363 added more requirements for institutions with assets of more than $1 billion.
This new relief applies to institutions that experienced temporary growth from participation in the PPP, the Paycheck Protection Program Liquidity Facility (PPPLF), the Money Market Mutual Liquidity Fund (MMLF), or other stimulus activities. The IFR is effective immediately and will remain in effect until Dec. 31, 2021, unless extended by the FDIC.
The FDIC’s decision will allow institutions themselves to decide whether they are subject to the requirements of Part 363 of the FDIC’s regulations for fiscal years ending in 2021 based on the lesser of their:
- consolidated total assets as of December 31, 2019, or
- consolidated total assets as of the beginning of their fiscal years ending in 2021
Currently, a financial institution can determine if it is subject to the annual independent audit and reporting requirements of Part 363 based on its consolidated total assets as of the beginning of its fiscal year.
How will this change impact your financial institution? Reach out to a member of our financial institutions industry team for answers to your questions.