Credit unions have been expected by NCUA to plan for business continuity since their 2008 joint guidance with the FFIEC. At the time, they stated, “the impact of a pandemic is much more difficult to determine because of the anticipated difference in scale and duration.” It also notes that “perhaps the most significant challenge likely from a severe pandemic event will be staffing shortages due to absenteeism.”
FFIEC pandemic planning information continues to encourage financial institutions to take action to minimize impact to consumers.
CU PolicyPro model policy #2195 is Pandemic Influenza Preparedness & Response and can serve as a basis for implementing or updating your credit union’s plan.
The Business Continuity page in InfoSight contains important information and sample policies and is being updated regularly.
Economic Stimulus payments for round #2 began arriving Jan. 4 and will continue until the week of Jan. 22, both via ACH and paper check. Refer to the resources below for common questions and challenges related to them.
Please note that round 2 does contain an exemption from garnishment and collections. Credit unions are encouraged to handle ACH name/account number mismatches in the same manner you would for tax refunds. (You can return them, but are not obligated to.) Consumers who were alive after Jan. 1, 2020 are entitled to payments, so you may receive them for deceased individuals. If the account is still open, you can allow it to post, per Treasury.
Governor Gianforte issued an updated directive, effective Feb. 12, that masks are no longer required statewide, but some local jurisdictions will continue to have mask requirements and other directives. We encourage you to check with your local public health officials if you are unsure of the status where your branches are located.
Other helpful resources include:
- Sept 11 Update from US Dept of Labor on FFCRA Leave
- Montana Dept. of Labor Remote Workforce Toolkit
- Best Practices: Bringing Employees Back to the Workplace Webinar (see the Video Series section by AE on this page)
- CDC Toolkit for Businesses with FAQ, guidance, social media information, posters, and more
- Coronavirus Resources for Employers in InfoSight
- The WellVia program for employees and dependents of the MCU Group Benefit Trust allows remote check in with a doctor.
- The U.S. Dept. of Labor guidance on FFCRA includes fact sheets, Q&A, and posters for employers
- Employers need to provide the FFCRA poster with paid leave rights (by April 1)
- CUNA Mutual Group FAQ on retirement plans related to coronavirus
- NCUA Alert on remote work cybersecurity considerations
Governor Gianforte’s Feb. 12 directive does note (page 4) that foreclosure remains limited by federal CDC guidelines.
Round 2 of PPP Lending is currently open and receiving applications.
NCUA and other regulators issued a statement March 9 encouraging financial institutions to work with borrowers and affected communities. They stated “Prudent efforts that are consistent with safe and sound lending practices should not be subject to examiner criticism.” Other directives, highlighted below, have since been issued to clarify details.
NCUA has a page with all COVID-19 related materials, including —
2020 Notices:
2021 Notices:
The Montana Division of Banking also issued–
2020 Notices:
- March 20 Statement for state-chartered CUs
- March 31 letter notifying credit unions of Directive prohibiting residential foreclosures and encouraging flexibility.
- April 2 Emergency Rule to allow virtual annual meetings
- Model Bylaws revision to incorporate virtual meetings option
- Division FAQ on foreclosure directive released
2021 Notices:
- Jan. 15 Supervisory Memo on branch closure and continuing service to members during COVID
FinCEN issued guidance (4/3) regarding BSA obligations during COVID.
*Guidance from all federal regulators and state agencies was issued on 6/23/20 about how COVID relief activities will be viewed in exams and areas they will not criticize.
Governor Gianforte’s updated Feb 12, 2021 directive discusses information for credit unions to consider on social distancing, disinfection, and employee screening. Masks are no longer required by the state, so check with your county health department to see if they have additional guidance or requirements, as county restrictions would need to be followed.
Below are resources to consider as your credit union moves toward opening lobbies and returning to full service in branches.
Along with all the news of COVID-19 and stimulus payments that are now hitting accounts comes news of scams and fraudulent situations. Below are some resources and recent alerts:
