The Federal Reserve (Fed) announced on March 24 that they will temporarily suspend examinations for banks with less than $100 billion in assets so all can concentrate on the coronavirus pandemic, to “help financial institutions of all sizes understand the challenges and risks of the current environment.”
Federal Reserve Suspends Exams for Banks Under $100 Billion
Banks over $100 billion will have some exam activity deferred
For banks with more than $100 billion, the Fed will defer some examination activity and concentrate exams for those banks with a financial stability or consumer protection issue. All examination activity will be done virtually until normal operations have resumed.
The time for existing remediation responses is extended
For existing regulatory orders, the Fed is extending the time for remediation responses by 90 days unless otherwise noted (i.e. heightened risk or to help consumers). Other federal regulatory agencies may follow the Fed’s lead to lessen the exam burden for financial institutions.
Terri Luttrell, CAMS-Audit
Terri Luttrell is a seasoned AML professional and former director and AML/OFAC officer with over 20 years in the banking industry, working both in medium and large community and commercial banks ranging from $2 billion to $330 billion in asset size. She has successfully worked with institutions in developing BSA/OFAC programs, optimizing various automated solutions, and streamlining processes while ensuring all regulatory requirements are met. As the Compliance and Engagement Director at Abrigo, Terri provides insights that contribute and support long-term banking strategies based on analysis of market and industry trends, competitor developments, and financial and regulatory technology changes. She is an audit-certified anti-money laundering specialist and a board member of the Central Texas chapter of the Association of Certified Anti-Money Laundering Specialists (ACAMS). Terri earned her bachelor’s degree in business administration, specializing in business and finance, from the University of North Texas.