Guidelines for Relief - Macro Financial
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Guidelines for Relief

FDIC provides procedures for covered institutions (CI) to follow when submitting requests for relief from aspects of Part 370. These are covered in a straight-forward, four page document entitled “Guidelines for Relief from Part 370” on the FDIC website. These guidelines include the process by which the FDIC will consider requests and are subject to modification. The four types of requests for relief are:

Exemptions: The rule set is intended for deposit-taking CIs. Non-deposit taking CIs may request an exemption from the rule.

Exceptions: This is for instances where circumstances exist that would make it impractical or overly burdensome to meet the requirements (FDIC provides significant detail on how these must be conveyed and demonstrated).

Extensions: A CI may request additional time to prepare for compliance with clearly articulated timeline, reasons and impact costs.

Release: CIs with fewer than the two million deposit accounts during three consecutive quarters may seek a release from the rule.

Complete and sufficient requests are expected prior to compliance date (April 2020) and will be considered by FDIC with responses expected within 120 days of receipt. Please refer to the FDIC website for complete and official instructions on the guidelines for relief.