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ARTICLE · 04 NOVEMBER 2020

FDIC Issues Interim Final Rule To Provide Temporary Relief From Part 363

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On October 20, 2020, the FDIC issued an interim final rule (the "Interim Final Rule") to provide banks temporary relief from the Part 363 audit and reporting requirements.

United StatesFinance and Banking
Adam Smith
Adam Smith
Douglas M. Weissinger
Douglas M. Weissinger
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On October 20, 2020, the FDIC issued an interim final rule (the "Interim Final Rule") to provide banks temporary relief from the Part 363 audit and reporting requirements. Due to participation in various government stimulus efforts, including the Paycheck Protection Program, the Paycheck Protection Program Liquidity Facility, the Money Market Mutual Fund Liquidity Fund, and receipt of deposits through federal stimulus payments, banks have experienced large inflows of cash. The Interim Final Rule is applicable to all FDIC insured financial institutions with at least $500 million in consolidated total assets.

Part 363 generally requires financial institutions with at least $500 million in total consolidated assets to obtain annual independent audits, meet related reporting requirements, and establish an audit committee comprised of a majority of outside directors. Part 363 requires banks with at least $1.0 billion in total consolidated assets to prepare assessments of

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