Article

FDIC IFR on applicability of part 363 for Annual Independent Audits

FDIC Interim Final Rule (IFR) on applicability of part 363 for Annual Independent Audits and Reporting Requirements for Fiscal Years Ending in 2021 issued

Summary: 

Insured depository institutions (IDIs) have experienced increases in their consolidated assets as a result of large cash inflows resulting from participation in the Paycheck Protection Program (PPP), the Money Market Mutual Fund Liquidity Facility (MMLF), the Paycheck Protection Program Liquidity Facility (PPPLF), and the effects of other government stimulus efforts. Since these inflows may be temporary, but are significant and unpredictable, the FDIC is issuing an interim final rule (IFR) that will allow IDIs to determine the applicability of part 363 of the FDIC’s regulations, Annual Independent Audits and Reporting Requirements, for fiscal years ending in 2021. 

Impact:

Interim rule provides temporary relief for an IDI whereas IDI that would be otherwise subject to certain annual audit requirements due to temporary increases in the IDIs asset size that would trigger part 363 annual requirements.  The IFR also reserves the authority to require an IDI to comply with one or more requirements of part 363 if the FDIC determines that asset growth was related to a merger or acquisition.

For more information on this topic or to learn how Baker Tilly specialists can help, contact our team.

Ivan Cilik
Partner, CPA
Fraud in Government: Prevention and Detection
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