The Office of the Comptroller of the Currency, the Federal Reserve, the Federal Deposit Insurance Corporation and state bank regulators acknowledge the serious effect of Hurricane Irma on HNW customers and operations at many financial institutions and will relax the stringency of their regulation accordingly.

The phrase the agencies use is "provide regulatory assistance to affected institutions." The agencies realise that the effects of natural disasters on local businesses and individuals are often transitory and they say that "prudent efforts to adjust or alter terms on existing loans in affected areas should not be subject to examiner criticism." In supervising institutions affected by the hurricane, the agencies will consider the unusual circumstances that they are facing.

Regulatory reporting requirements

The agencies say that institutions affected by Hurricane Irma that expect to have trouble meeting their reporting obligations should contact their primary federal regulatory agencies (whichever they are) to discuss their situation. The agencies do not expect to assess penalties or take other supervisory action against institutions that take reasonable and prudent steps to comply with their regulatory reporting requirements if those institutions are hamstrung by Hurricane Irma. They realise that some institutions are going to experience problems while discharging their reporting responsibilities and will take each one's circumstances (including the status of its reporting and recordkeeping systems and the condition of its underlying financial records) into account.

Publishing requirements

The agencies understand that the damage caused by the hurricane may affect compliance with publishing and other requirements for branch closures (the regulators, for some reason, call these 'closings'), relocations and temporary facilities under various laws and regulations. Institutions experiencing disaster-related difficulties in complying with any requirements should contact their primary federal and state regulatory agencies.

Temporary banking facilities

The agencies know that many banks are going to face problems relating to power, telecoms, staffing and other things as they struggle to re-open facilities after the hurricane. If operational problems persist, they will expedite any request to operate temporary banking facilities. In most cases, a telephone notice to the primary federal and state regulator will suffice initially. The bank can send a written notification later.