The Office of the Comptroller of the Currency encourages national banks and federal savings associations to work with customers affected by Hurricane Harvey.
OCC Bulletin 2012-28 provides examples of steps national banks and federal savings associations may take to support customers affected by natural disasters. The OCC encourages national banks and federal savings associations to consider:
- waiving or reducing ATM fees.
- temporarily waiving late payment fees or penalties for early withdrawal of savings for affected customers.
- working with borrowers who have been affected by the event by
- restructuring borrowers’ debt obligations, when appropriate, by altering or adjusting payment terms. Payment extensions should reflect individual borrower situations and generally should not exceed 90 days.
- expediting lending decisions when possible, consistent with safety and soundness principles.
- reassessing the current credit needs of the community and helping meet those needs by originating or participating in sound loans to rebuild damaged property.
- contacting state and federal agencies, as well as other financial institutions, to help mitigate the effects of the event.
Examiners will not criticize these types of responses as long as the actions are taken in a manner consistent with sound banking practices. The OCC recognizes adjusting or modifying payment terms may be the most reasonable option for some borrowers when done prudently, and documentation deficiencies may occur because of bank staffing shortages and business disruptions during a recovery period. The OCC’s Bank Accounting Advisory Series and the Federal Financial Institutions Examination Council instructions to the Reports of Condition and Income (“call reports”) provide additional guidance on accounting and reporting issues that may arise in the event of a disaster. The OCC may also temporarily waive the Qualified Thrift Lender requirements for federal savings associations in order to help rebuild affected businesses. Additionally, the OCC will consider a bank’s support of recovery-related activities in a disaster and help in revitalizing and stabilizing the affected area under provisions of the Community Reinvestment Act.