OCC 2005-33
OCC BULLETIN

Subject:        Hurricane Katrina
Description:   Supervisory Guidance

Date:  September 19, 2005

TO:  Chief Executive Officers of All National Banks, Federal
     Branches and Agencies, Department and Division Heads, and
     All Examining Personnel


PURPOSE
This bulletin transmits guidance that the Office of the
Comptroller of the Currency (OCC) has issued to assist national
banks and their customers affected by Hurricane Katrina and
informs bankers that the OCC has established sections on its Web
site and BankNET that provide information on, and links to,
Katrina-related information.

SUMMARY
On August 29, 2005, the OCC issued a press release (NR 2005-83)
encouraging national banks to consider measures to assist
borrowers who have been affected by Hurricane Katrina. The
attached interagency release (NR 2005-87), issued on September 2,
2005, outlines additional actions that financial institutions can
take to meet the critical financial needs of their customers and
their communities. Efforts taken by national banks to work with
their borrowers and customers in affected communities, if
conducted in a reasonable and prudent manner, are consistent with
safe and sound banking practice.   In accordance with the
Community Reinvestment Act (CRA), the OCC will favorably consider
activities that revitalize or stabilize a designated disaster
area.

In addition to the steps outlined in the interagency release, the
OCC has

*    Authorized national banks in affected areas to establish
     temporary branches with only an after-the-fact notice
     requirement;
*    Authorized several unaffected national banks to establish
     temporary branches to serve evacuees with minimal prior 
     notice;
*    Permitted national banks to share branch facilities and
     employees without entering into a prior written agreement
     spelling out the rights, obligations, and duties of the parties,
     provided a formal agreement is entered into as soon as 
     reasonably practical thereafter; and
*    Issued additional guidance, in the form of frequently asked
     questions and answers (FAQs), on various issues that have 
     arisen as bankers work to address the needs and concerns of 
     their customers and communities. Topics covered in the FAQs 
     include CRA, Bank Secrecy Act, credit practices, temporary 
     branching, and shared facilities/employees.  A copy of these 
     FAQs is attached to this bulletin.

Given the need to get information to banks as quickly as possible
and recognizing that mail service has been disrupted to certain
affected areas, the OCC is using its Web site and BankNET to
relay Katrina-related guidance and to provide links to other Web
sites and information that may assist bankers and their
customers. Bankers are encouraged to check these sites
periodically for updated information.

The OCC and other federal financial regulatory agencies recognize
that Hurricane Katrina may affect banks' ability to submit
accurate and timely regulatory reports. National banks that
anticipate having difficulty submitting accurate and timely call
reports or other required regulatory reports are encouraged to
notify their supervisory office as soon as possible. The OCC will
not take supervisory action against national banks that take
appropriate and prudent steps to comply with regulatory reporting
requirements but are unable to do so due to circumstances caused
by Hurricane Katrina.  More generally, consistent with its
longstanding practice, the OCC will consider the unusual
circumstances that banks in affected areas may have with respect
to safety and soundness or compliance issues, including those
regarding the Bank Secrecy Act, in determining the appropriate
supervisory response.

The OCC is committed to working with the banking industry and
other federal financial regulators to respond to issues that
arise in the aftermath of Hurricane Katrina and to minimize
disruption and burden on banks in affected areas. In this regard,
the OCC will work with national banks affected by the disaster
and will use appropriate discretion in establishing the scope and
frequency of examinations.
For additional information or assistance related to Hurricane
Katrina, please contact your supervisory office or Fred Finke,
senior policy liaison, at (202)-874-4468.




_____________________________
Emory W. Rushton
Senior Deputy Comptroller and Chief National Bank Examiner


Attachments:

NR 2005-83:
OCC Encourages Customers to Work with Customers Affected by
Hurricane Katrina
[http://www.occ.treas.gov/toolkit/newsrelease.aspx?]

NR 2005-87:
Agencies Encourage Institutions to Assist Displaced Customers
[http://www.occ.treas.gov/toolkit/newsrelease.aspx?]

FAQs:
http://www.occ.treas.gov/HurricaneQA.htm
[http://www.occ.treas.gov/HurricaneQA.htm]