Community banks face many challenges during the COVID-19 pandemic. Bankers should evaluate current functions and activities throughout this uncertain time. Below you can find CRI’s community bank COVID-19 checklist, by functional area, to be used as a resource to assist in this evaluation process.
- Ensure effective communications are ongoing with bank customers and employees given this evolving situation. Be sure to focus on health and safety.
- Examine and update the bank’s risk assessment and present any significant changes to the Audit Committee.
- Emphasize to bank staff and customers the possible threat of a cyber-event. Bankers should consider the need for specific social engineering exercises since staff are working remotely and could be more vulnerable during the pandemic.
- Consider increasing mobile remote deposit daily and monthly limits for well-known customers to further reduce branch deposit activity.
- Maintain accurate and detailed records of Pandemic Committee actions so the bank can perform an effective self-assessment when the pandemic has ended.
- Reassess the bank’s pandemic policy based on current bank actions as well as March 6, 2020, pandemic preparedness guidance issued by the Federal Financial Institutions Examination Council.
- Consider additional lines of business or products to generate fee revenue (e.g., insurance, wealth management, lock-box services, etc.) on a long-term basis.
- Evaluate the bank’s current project list and consider delaying projects to a later implementation date so that project resources can be deployed for COVID-19 assistance.
- Contact businesses/customers proactively in industries particularly impacted by COVID-19 to discuss potential banking solutions.
- Consider waiving late, overdraft, and CD early withdrawal fees if caused by COVID-19 related issues with documented approval.
- Communicate with the Financial Crimes Enforcement Network (FinCEN) and the bank’s primary regulators as soon as practicable regarding any potential COVID-19 delays in filing required Bank Secrecy Act (BSA) reports.
- Engage internal audit to perform specific procedures related to COVID-19 policy changes and any new services.
- Reassess information technology resources given increased staff working remotely.
- Ensure that borrowers submit a request for loan deferment in writing and specifically reference the COVID-19 basis for the request. The borrower should outline and explain how they have been impacted by COVID-19, including quantitative and qualitative analysis.
- Prepare a written response to each borrower request for COVID-19 relief and include standard language developed by the bank. Make sure any changes in lending practices are consistent, particularly for individual borrowers, to prevent any potential Fair Lending issues.
- Code COVID-19 loans in the loan system so a report or query can be generated of all impacted loans.
- Consult with appraisers and individuals performing real estate inspections about alternative arrangements if the property owner does not allow access to the property due to COVID-19.
- Evaluate and consider adjusting allowance for loan losses and qualitative factors, including change in economic factors. Banks should consider certain hard-hit industries, such as hospitality, which includes hotel/motel, entertainment, retail, and restaurants.
Monitor liquidity proactively to ensure the bank has sufficient liquidity. Financial management should revisit potential funding sources and review contingency funding plans given the pandemic.
- Liquidity monitoring activities should be frequently shared with executive management, given current economic uncertainty.
- Remember FIL-28-2020 provides additional time in filing the March 31, 2020, Call Report provided the report is submitted within 30 days of the official filing deadline.
- If additional time in filing is necessary, the bank should contact its FDIC regional office in advance of the official filing date.
- Re-evaluate the bank’s month-end close process given some activities are remote. The Accounting Department should consider the need to conduct greater communications among team members to ensure all critical close functions are occurring timely.
- Examine the bank’s insurance policies to determine if the current policy includes business interruption coverage. Review notification requirements in the insurance policy for any future action needed to be taken under the policy during this event.
- Consider revisions to the bank’s budget, given changes in interest rates and economic uncertainty.
- Discuss with the board of directors the bank’s current dividend plans and consider those future modifications that may be warranted.
- Review the bank’s investment portfolio. A number of banks have built-in gains in their portfolio. Evaluate specific actions to determine if gains should be realized to improve short-term liquidity or if investments should be held for future needs.
- Analyze the bank’s current held-to-maturity (HTM) investment portfolio and determine if HTM debt securities should be sold prior to maturity for liquidity during this pandemic. Refer to Accounting Standards Codification (ASC) 320-10-25 for further information about the ability to sell these securities before maturity without “tainting” the portfolio.
- Determine how the bank is reporting delinquent loans due to COVID-19. Generally, borrowers who were current prior to becoming impacted by COVID-19 and obtain insignificant payment accommodations as a result of its effects would not be reported as past due. Please see FDIC COVID-19 FAQ for additional information.
- Consider requiring staff to take their temperature before coming to work to reduce the risk of possibly infecting healthy employees.
- Request that branch managers regularly compile common questions received from customers and have management draft specific responses with follow-up staff training.
- A clear and consistent message to customers is important.
- Evaluate the need to extend call center hours and increase staffing, given the volume of customer calls.
- Ensure staff are appropriately trained on FDIC insurance so they can outline coverage to customers and answer questions as they arise.
- Encourage staff to refrain from posting inappropriate information to social media that may not be in accordance with the bank’s mission or values.
- Consider splitting bank departments into separate teams to ensure that critical functions can always be handled. Many banks have formulated “A,” “B,” and “C” teams to further facilitate this split. Also, executive management should assess participating in a scheduled rotation.
- Increase ATM and branch cash limits.
- Evaluate the need to limit cash withdrawals (daily and weekly limits).
- Remind customers how to set-up appointments with bankers. Consider requiring checklists to be completed prior to a visit to make sure the customer has not traveled recently and has not had a fever within 72 hours to limit potential exposure to staff.
- Consider special appointment hours for certain high-risk customer visits.
- Remind customers of scams and potentially fraudulent emails and the bank’s policy for email correspondence as fraudsters take advantage of the pandemic.
- Increase branch cleaning procedures to reduce the risk of potential exposure and encourage branch staff to regularly disinfect drive-thru tubes.
- Communicate proactively with customers to use online, mobile, ATM, and voice banking services.
- Establish procedures for customers to access their safe deposit boxes safely by appointment upon confirming their health status and recent travel. Determine internal procedures to allow access to the safe deposit box while maintaining security procedures and social distancing requirements.
While this COVID-19 community bank checklist is not exhaustive, we believe it will serve as a valuable resource as bankers carefully manage their bank’s response to COVID-19. CRI professionals are ready to assist with any questions or specific needs as this situation evolves.