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Federal Reserve Suspends Regulatory Examination Activity for Banks with Total Consolidated Assets Under $100 Billion

By James M. Kane, Daniel C. McKay, II, James W. Morrissey, Jennifer Durham King, Juan M. Arciniegas & Mark C. Svalina on March 25, 2020
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On March 24, 2020, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued a statement on its supervisory activities (“Statement”) during the unprecedented COVID-19 pandemic.  As part of that Statement, the Federal Reserve indicated that “to minimize disruption and burden on financial institutions, the Federal Reserve is reducing its focus on examinations and inspections at this time.”  In its effort to minimize the regulatory burdens placed on financial institutions, the Federal Reserve made the following pronouncements:

  • Applicable to All Financial Institutions. Any examination activities will be conducted off-site until normal operations are resumed at the bank and the applicable Federal Reserve Bank.
  • Applicable to Financial Institutions with Less Than $100 Billion in Assets. For financial institutions with less than $100 billion in total consolidated assets, the Federal Reserve intends to “cease all regular examination activity, except where the examination work is critical to safety and soundness or consumer protection, or is required to address an urgent or immediate need.”
  • Applicable to Financial Institutions with More Than $100 Billion in Assets. For institutions with total consolidated assets greater than $100 billion, the Federal Reserve intends to defer a significant portion of planned examination activity based on its assessment of the burden on the institution and the importance of the exam activity to the supervisory understanding of the firm, consumer protection or financial stability.  With respect to the upcoming Comprehensive Capital Analysis and Review, or CCAR, exercise, firms should submit the capital plans that they have developed by April 6, 2020.  The plans will be used to monitor how firms are managing their capital in the current environment, planning for contingencies, and positioning themselves to continue lending.
  • These changes to the Federal Reserve’s examination cycle will be reassessed during the last week of April 2020.

We note that the Statement is only applicable to institutions supervised by the Federal Reserve, including state member banks, bank holding companies, savings and loan holding companies, Edge Act Corporations, and the U.S. operations of foreign banking organizations.  To date, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency and state banking regulators have not issued similar guidance.

Click here to read the Federal Reserve’s Statement on Supervisory Activities.

As noted above, if you would like to discuss the matters addressed in this blog post, please contact James M. Kane at (312) 609-7533, Daniel C. McKay, II at (312) 609-7762, James W. Morrissey at (312) 609-7717, Jennifer D. King at (312) 609-7835, Juan M. Arciniegas at (312) 609-7655, Mark C. Svalina at (312) 609-7741 or your Vedder Price attorney.

Photo of James M. Kane James M. Kane
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Photo of Daniel C. McKay, II Daniel C. McKay, II
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Photo of James W. Morrissey James W. Morrissey
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Photo of Jennifer Durham King Jennifer Durham King
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Photo of Juan M. Arciniegas Juan M. Arciniegas

Mr. Arciniegas works primarily as a derivatives lawyer and covers markets for over-the-counter (OTC) derivatives, structured finance products and listed futures. He advises on every stage throughout the life cycle of a derivatives transaction, providing assistance to a wide range of market participants…

Mr. Arciniegas works primarily as a derivatives lawyer and covers markets for over-the-counter (OTC) derivatives, structured finance products and listed futures. He advises on every stage throughout the life cycle of a derivatives transaction, providing assistance to a wide range of market participants engaged in the markets in various capacities. Regulatory matters range from assisting clients on financial reform legislation, registration and membership with the CFTC, NFA, and other financial market utilities, to providing guidance to commercial end-users and sell-side participants on exemptions, cross-border access issues, and matters involving the overlapping jurisdiction of securities and commodities regulation. Transactional matters include the negotiation and implementation of comprehensive documentation for agency-MBS, cleared and OTC derivatives, FX, futures, loan-level hedging arrangements, prime brokerage, repurchase transactions, securities lending, structured finance transactions, and related industry protocols implementing changes in those markets. Mr. Arciniegas has appeared before the CFTC, the Federal Reserve, the SEC, and is a frequent speaker and published author on futures and derivatives topics.

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Photo of Mark C. Svalina Mark C. Svalina
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  • Posted in:
    Banking, Finance and Securities
  • Blog:
    The 21st Century Banker
  • Organization:
    Vedder Price PC
  • Article: View Original Source

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