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OCC Bulletin 2020-17 | March 19, 2020

Pandemic Planning: Joint Questions and Answers Regarding Statement About the Use of Capital and Liquidity Buffers


Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties


The Office of the Comptroller of the Currency (OCC), along with the Board of Governors of the Federal Reserve System (Federal Reserve) and the Federal Deposit Insurance Corporation (FDIC) (collectively, the agencies), recognize the potential for Coronavirus Disease (also referred to as COVID-19) to adversely affect the customers and operations of financial institutions. On March 17, 2020, the agencies issued a statement encouraging banking organizations to use their capital and liquidity buffers as they respond to the challenges presented by the effects of COVID-19-related issues.1 The agencies today issued these questions and answers in response to public questions about the use of capital and liquidity buffers.

Note for Community Banks

This bulletin applies to all OCC-supervised banks.2


Since the global financial crisis of 2007-2008, U.S. banking organizations have built up substantial levels of capital and liquidity in excess of regulatory minimums and buffers. These capital and liquidity buffers were designed to provide banking organizations with the means to support the economy in adverse situations and allow banking organizations to continue to serve households and businesses. The agencies support banking organizations that choose to use their capital and liquidity buffers to lend and undertake other supportive actions in a safe and sound manner.

These questions and answers respond to public inquiries from banking organizations regarding

  • liquidity buffers.
  • capital buffers.
  • recovery and resolution plan triggers.
  • total loss-absorbing capacity rule.

Further Information

Please contact the Capital Policy unit at (202) 649-6370.

Grovetta N. Gardineer
Senior Deputy Comptroller for Bank Supervision Policy

Related Link

1 Refer to OCC News Release 2020-34, "Federal Banking Agencies Provide Banks Additional Flexibility to Support Households and Businesses."

2 The term "banks" refers collectively to national banks, federal savings associations, and federal branches and agencies of foreign banking organizations.