United States

FDIC FAQ for financial institutions affected by COVID-19


The Federal Deposit Insurance Corporation (FDIC) recently issued Frequently Asked Questions for Financial Institutions Affected by the Coronavirus Disease 2019 (Referred to as COVID-19). The FAQ discusses answers to a wide range of questions, including, among others, the following addressing financial-reporting-related topics:

  • Do loans that receive payment accommodations have to be reported as delinquent or non-performing?
  • When does a payment accommodation become a troubled debt restructuring (TDR)?
  • Will FDIC examiners make banks categorize all loan modifications related to COVID-19 events as a TDR?
  • Do loans that receive payment accommodations have to be reported as nonaccrual, reflect appropriate allowance for credit losses (ACL) or allowance for loan and lease losses (ALLL), and be charged off?
  • Is there an ability for a financial institution to disclose additional information in its regulatory reports about the consequences of the impacts of COVID-19?
  • If a financial institution affected by the impact of COVID-19 sells investment securities that were classified as “held to maturity” to meet its liquidity needs, will that financial institution’s intent to hold other investment securities to maturity be questioned?
  • How should financial institutions with borrowers affected by the effects of COVID-19 determine the appropriate amount to report for their ALLL or ACL, if applicable, in their first quarter regulatory reports?

It should be noted, however, that the views expressed by the FDIC are not authoritative accounting guidance for financial reporting under U.S. generally accepted accounting principles.

For additional COVID-19-related guidance specifically for financial institutions, see RSM’s articles:

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