CAPITAL, ACCOUNTING AND LIQUIDITY

Guidance released by the FFIEC on March 25, 2020 indicate that the federal banking agencies will not take action against any institution for submitting its March 31, 2020, Reports of Condition and Income (Call Report) after the respective filing deadline, as long as the report is submitted within 30 days of the official filing date. Institutions are encouraged to contact their primary federal regulator in advance of the official filing date if they anticipate a delayed submission.

In addition the Federal Reserve has indicated that it will not take action against a bank holding company with $5 billion or less in assets for submitting March 31, 2020, bank holding company reports (FR Y-9C or FR Y-11) after the filing deadline, as long as the report is submitted within 30 days of the filing date.

Institutions are encouraged to contact their Reserve Bank in advance of the normal filing deadline if they anticipate a delayed submission. Institutions anticipating difficulty submitting their reports within the 30 days following the official filing due date, or experiencing challenges in obtaining director attestations, should likewise contact their Reserve Bank.

• An employer will resume payment of payroll taxes incurred after January 1, 2021. But payroll taxes deferred in 2020 are not yet due.
• 50 percent of deferred taxes are due December 31, 2021. The remaining 50 percent is due December 31, 2022.
• No interest accrues on deferred amounts.