FDIC rescinds pandemic-related, 45-day extension period for Part 363 annual report filing

A March 2020 Financial Institution Letter (FIL) that gave insured banks an additional 45 days, in response to the coronavirus, to file their statutorily required annual reports with the federal bank deposit insurer has been rescinded, the agency said Tuesday in a new letter.

The rescission of FIL-30-2020 is effective for fiscal years beginning after Dec. 31, 2021, the Federal Deposit Insurance Corp. (FDIC) said; as a result, the deadline for filing the annual report for fiscal years beginning after that date reverts to either 90 or 120 days after the end of the insured depository institution’s fiscal year, depending on the institution’s status as a public filer.

Annual reports are required of all FDIC-insured depository institutions having $500 million or more in assets under Part 363 of the agency’s rules and regulations. The FDIC, in FIL-10-2022, said the decision to rescind the 45-day extension was made in consultation with federal and state financial regulators.

It noted, however, that institutions that are unable to timely file all or any portion of their annual reports may still submit a notice of late filing to the FDIC under the provisions of §363.4(e) and Guideline 23 to Part 363. A notice of late filing must be submitted to the FDIC, the appropriate federal banking agency, and any appropriate state bank supervisor by the 90- or 120-day report filing deadline, it said. These provisions also apply if the reason for late filing is related to the effects of the pandemic, it noted.

FDIC FIL-10-2022