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 InfoSight Business Continuity page contains important information and sample policies and is being updated regularly.
Governor Gianforte’s Feb. 12 directive lifted the statewide mask mandate. Cities and counties can no longer have restrictions in place that are greater than the state mandate, but individual businesses can. Your credit union should consider the needs of your staff and members in setting your expectations, and make them clear to all.
Other helpful resources include:
Governor Gianforte’s Feb. 12 directive does note (page 4) that foreclosure remains limited by federal CDC guidelines.
March 31, 2021 the CFPB rescinded several of their COVID-related policy statements. Some are referenced within the links below, but any directly rescinded have been removed from the following list.
The SBA closed the Paycheck Protection Program to new applications on May 28, 2021. They will continue to process applications that were submitted through June 30, and forgiveness applications are also still being accepted and processed.
NCUA and other regulators issued a statement March 9, 2020 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 —
The Montana Division of Banking also issued–
- 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
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 directive discusses information for credit unions to consider on social distancing, disinfection, and employee screening. Masks are no longer required by the state, and local jurisdictions are not allowed to impose mandates that are more restrictive than the state, although individual businesses can.
Below are resources to use as your credit union returns to full service in branches.