Recognizing the significant and long-lasting effects of the coronavirus pandemic on financial institutions, federal and state financial regulators on Tuesday issued joint guidance for how examiners should assess the effects of COVID-19 on the safety and soundness of banks and credit unions. The guidance directs examiners to assess institutions according to existing agency policies and procedures and to consider the appropriateness of management actions to address COVID-19 challenges. It provides specific instructions for examiners when considering an institution’s risk assessment, capital adequacy, asset quality, management actions, earnings, liquidity and market risk sensitivity.‌

“Examiners should assess the reasonableness of management’s actions in response to the pandemic given the institution’s business strategy and operational capacity in the distressed economic and business environment in which the institution operates,” the agencies said. “When assigning the composite and component ratings, examiners will review management’s assessment of risks presented by the pandemic, considering the institution’s size, complexity and risk profile.”

When determining whether a formal or informal enforcement is necessary, examiners should consider whether the institution appropriately planned for resiliency and operational continuity, has implemented prudent policies and is pursuing “realistic resolution of the issues confronting the institution,” they added.

With respect to credit risk, the agencies acknowledged that the pandemic could cause substantial, temporary changes to property values and noted that "examiners will not subject a renewed, extended or modified loan to adverse classification" solely because of such a decline, provided management determines the borrower has an ability to repay according to "reasonable modified terms."  View the guidance. For more information, contact ABA's Josh Stein. ‌