FDIC provides temporary relief from part 363 audit and reporting requirements
The interim final rule amends the measurement date for determination of applicability of part 363 of the FDIC’s regulations. Now, banks can determine applicability of part 363 based on the lesser of consolidated total assets as of Dec. 31, 2019 or as of the beginning of the fiscal year ending in 2021. This interim final rule is effective as of the date of publication in the Federal Register and will remain in effect through Dec. 31, 2021, barring further action by the FDIC.
It should also be noted that the FDIC reserves the authority to require a bank to comply with requirements under part 363 if asset growth is determined to be related to a merger or acquisition.