Your guide to financial institution regulatory deadline extensions.
As a result of the impacts of COVID-19, financial institution regulators have been working to grant extensions to many of the regulatory deadlines that private financial institutions must meet. Below is a summary of these extensions and links to the underlying regulatory guidance. We suggest financial institutions work with their service providers to ensure all regulatory deadlines are met.
Privately Held Banks
| Submission Type | Original Deadline | Extension | Notes |
| Call Report | April 30, 2020 | June 1, 2020 | Institutions are encouraged to contact their primary federal regulator in advance of the original filing date if they anticipate a delayed submission. |
| FR Y-9C | May 11, 2020 | June 9, 2020 | Institutions are encouraged to contact their Reserve Bank in advance of the original filing deadline if they anticipate a delayed submission. |
| FR Y-11 | June 1, 2020 | June 29, 2020 | Institutions are encouraged to contact their Reserve Bank in advance of the original filing deadline if they anticipate a delayed submission. |
| FDIC Statement on Part 363 Annual Reports (FDICIA) | April 29, 2020 | June 15, 2020 | IDIs are encouraged to contact the FDIC in advance of the original filing date if the IDI anticipates a delayed submission. The staff of the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the state banking regulators have confirmed the FDIC’s treatment of the annual report required by Part 363. |
Credit Unions
| Submission Type | Original Deadline | Extension | Notes |
| Call Report | April 26, 2020 | April 26, 2020 | Call Reports should be filed on time. If it cannot be filed on time, credit union should inform NCUA’s Office of Examination and Insurance |
| Annual capital plan and/or Stress testing | May 31, 2020 | August 31, 2020 | The Office of National Examinations and Supervision will individually contact credit unions meeting the criteria |
| CUSO Registry | March 31, 2020 | April 30, 2020 |
All Private Financial Institutions
| Submission Type | Original Deadline | Extension | Notes |
| CFPB Reporting Flexibility – HMDA | May 30, 2020 | Indefinite | At a later date, the Bureau will provide information as to how and when it expects institutions under its jurisdiction to resume quarterly HMDA data submissions. |
| CFPB Reporting Flexibility – Credit Card and Prepaid Account Issuers | Various | Indefinite | At a later date, the Bureau will notify entities of when and how to submit information under these requirements. |
| HUD – FHA Lenders | March 31, 2020 | April 30, 2020 | Lenders that can complete the annual recertification before April 30th are encouraged to do so. |
| Freddie Mac Reporting | Various | Various | See specific guidance for deadline and other loan requirement modifications. |
| Fannie Mae Reporting | Various | Various | See specific guidance for deadline and other loan requirement modifications. |
CLA is here to help. Please contact us with any questions you might have related to your institutions regulatory reporting requirements.
Scott is the leader in CLA’s Financial Institutions group, and a member of the National Assurance Technical Group. He has 15 years of experience with audit and accounting services for financial institutions of all sizes.
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