Supervisory Relief to Help Financial Institutions and Facilitate Recovery in Areas of Wisconsin Affected by Severe Storms, Straight-line Winds, Flooding, and Mudslides

Disaster Relief

September 23, 2025

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Summary:
The FDIC has announced a series of steps intended to provide regulatory relief to institutions and facilitate recovery in areas of Wisconsin affected by severe storms, straight-line winds, flooding, and mudslides.
Please review the
FDIC’s Disaster Page to review information about what to do if your bank is affected.
Statement of Applicability:
The contents of, and material referenced in, this FIL apply to all FDIC-supervised financial institutions.
Highlights:
Severe storms, straight-line winds, flooding, and mudslides caused significant property damage in areas of Wisconsin from August 9, 2025, to August 12, 2025.
The Federal Emergency Management Agency (FEMA) declared a federal disaster for selected areas affected in Wisconsin on September 11, 2025. FEMA may make additional designations after damage assessments are completed in the affected areas. A current list of designated areas is available at www.fema.gov . The FDIC is encouraging banks to work constructively with borrowers experiencing difficulties beyond their control because of damage in affected areas . Institutions that extend repayment terms, restructure existing loans, or ease terms for new loans in a manner consistent with sound banking practices can contribute to the health of the local community and serve the long-term interests of the lending institution. Institutions may receive favorable Community Reinvestment Act consideration for community development loans, investments, and services in support of disaster recovery. The FDIC also will consider regulatory relief from certain filing and publishing requirements. SUPERVISORY RELIEF TO HELP FINANCIAL INSTITUTIONS AND FACILITATE RECOVERY IN AREAS OF WISCONSIN AFFECTED BY SEVERE STORMS, STRAIGHT-LINE WINDS, FLOODING, AND MUDSLIDES The Federal Deposit Insurance Corporation (FDIC) recognizes the serious impact of severe storms, straight-line winds, flooding, and mudslides on customers and operations of institutions in affected areas of Wisconsin and will provide regulatory relief to institutions subject to its supervision to help facilitate recovery. The FDIC encourages institutions to work constructively with customers in affected areas to meet their financial services needs. The affected areas in Wisconsin are Milwaukee, Washington, and Waukesha Counties. Lending:
The FDIC encourages institutions to work constructively with borrowers in affected areas, and will not criticize prudent efforts to adjust or alter terms on existing loans. Efforts to work with borrowers in communities under stress can be consistent with safe-and-sound banking practices and in the public interest. 1 Community Reinvestment Act (CRA):
Institutions may receive CRA consideration for community development loans, investments, or services that revitalize or stabilize federally designated disaster areas in their assessment areas or in the states or regions that include their assessment areas. For additional information, institutions should review the Interagency Questions and Answers Regarding Community Reinvestment at Section 12(g)(4)(ii). For help in identifying community development activities to revitalize or stabilize a disaster area, institutions can contact their regional Community Affairs Officer . Investments:
Institutions are encouraged to monitor securities and loans of municipalities in affected areas, and take prudent efforts to stabilize such investments.
Reporting Requirements:
FDIC-supervised institutions in affected areas should notify the Chicago Regional Office if they expect a delay in filing Reports of Income and Condition or other reports. The FDIC will evaluate any causes beyond the control of a reporting institution when considering the length of an acceptable delay. Publishing Requirements:
The FDIC understands the damage in affected areas may affect an institution’s ability to comply with publishing and other requirements for branch closings, relocations, and temporary facilities under various laws and regulations. Institutions experiencing disaster-related difficulties in complying with any publishing or other requirements should contact the Chicago Regional Office. Consumer Laws:
For principal dwelling-secured loans, Regulation Z provides consumers an option to waive or modify the three-day rescission period when a “bona fide personal financial emergency” exists. To exercise this option, the consumer must provide the lender with a statement describing the emergency in accordance with the regulation. Temporary Banking Facilities:
The Chicago Regional Office will expedite any request to operate temporary banking facilities by an institution in an affected area whose offices have been damaged or that desires to provide more convenient availability of services. In most cases, a telephone notice to the FDIC will suffice initially. Institutions may submit a written notification at a later time. 1 Institutions should individually evaluate modifications of existing loans in accordance with Accounting Standards Codification (ASC) Subtopic 310-10, Receivables – Overall, as amended by Accounting Standards Update (ASU) 2022-02, Troubled Debt Restructurings and Vintage Disclosures, to determine whether the modification of the existing loan is a modification to a borrower experiencing financial difficulty. Under both ASC Topic 326, Financial Instruments – Credit Losses, and ASU 2022-02, this evaluation should be based on the facts and circumstances of each borrower and modification.

FIL-44-2025

Related Topics

Applications and Notices

Community Reinvestment Act

Credit

Contact(s)

Division of Risk Management Supervision