FDIC FIL-16-2026: Supervisory Relief for Washington Disaster-Affected Institutions

Reference: FIL-16-2026

Official publication: Read the full FIL-16-2026 on the agency website

On April 21, 2026, the Federal Deposit Insurance Corporation issued FIL-16-2026 addressing supervisory relief and recovery measures for areas of Washington affected by severe storms, straight-line winds, flooding, landslides, and mudslides. The release is brief, but it contains several concrete operational signals for FDIC-supervised institutions, especially around borrower accommodations, reporting delays, branch operations, Community Reinvestment Act treatment, and direct coordination with the San Francisco Regional Office.

Executive Summary

• The FDIC states that FIL-16-2026 applies to all FDIC-supervised financial institutions, but the most immediate operational consequences fall on institutions with offices, borrowers, municipal exposures, or service needs in the designated Washington disaster areas.
• The release covers damage from December 5, 2025 through December 19, 2025, and notes that FEMA declared a federal disaster for selected Washington areas on April 7, 2026, with possible additional designations to follow.
• The FDIC is encouraging institutions to work constructively with affected borrowers and indicates that prudent efforts to extend repayment terms, restructure existing loans, or ease terms on new credit can be consistent with safe and sound banking practices.
• The agency also identifies possible CRA consideration for qualifying community development loans, investments, and services supporting disaster recovery, and it signals willingness to consider relief from certain filing and publishing requirements.
• The release does not create blanket waivers or automatic deadlines. Institutions expecting reporting delays, publishing difficulties, or a need for temporary facilities should engage the San Francisco Regional Office directly and document the basis for those requests.

What the Regulator Issued

On April 21, 2026, the FDIC published Supervisory Relief to Help Financial Institutions and Facilitate Recovery in Areas of Washington Affected by Severe Storms, Straight-line Winds, Flooding, Landslides, and Mudslides. The release is identified on the page as FIL-16-2026. The FDIC’s published summary states that the agency announced a series of steps intended to provide regulatory relief to institutions and facilitate recovery in affected Washington areas. The release also directs institutions to the FDIC disaster page for further information about what to do if a bank is affected.

The official highlights identify the underlying disaster period as December 5, 2025 through December 19, 2025 and state that FEMA declared a federal disaster for selected areas in Washington on April 7, 2026. The release says FEMA may make additional designations after damage assessments are completed. The affected areas listed in the FIL are Chelan, Grays Harbor, King, Lewis, Pacific, Pierce, Skagit, Snohomish, Thurston, and Whatcom Counties; the Chehalis, Lummi, Muckleshoot, Nisqually, Nooksack, Puyallup, Quinault, Sauk-Suiattle, Shoalwater Bay, Squaxin Island, Stillaguamish, Swinomish, Tulalip, and Upper Skagit Indian Reservations; and Samish (TDSA).

The FDIC states that it will provide regulatory relief to institutions subject to its supervision to help facilitate recovery. The release addresses lending, CRA, investments, reporting requirements, publishing requirements, consumer laws, and temporary banking facilities. It specifically says institutions may receive CRA consideration for qualifying disaster-recovery activity, should notify the San Francisco Regional Office if they expect delays in filing Reports of Income and Condition or other reports, and should contact that office if disaster conditions affect compliance with branch-related publishing or other requirements. For principal dwelling-secured loans, the release notes that Regulation Z allows waiver or modification of the three-day rescission period where a bona fide personal financial emergency exists and the consumer provides the required statement. The FIL also states that the San Francisco Regional Office will expedite requests for temporary banking facilities and that, in most cases, telephone notice will suffice initially, with written notice to follow later.

Who Is Impacted

The release’s statement of applicability is broad: it says the contents of the FIL and referenced material apply to all FDIC-supervised financial institutions. Even so, the most direct operational impact falls on institutions with physical operations, customers, collateral, or lending activity in the designated counties, tribal areas, and Samish (TDSA), as well as institutions serving those areas through digital channels, mobile operations, or correspondent relationships.

Within affected institutions, the release has implications beyond frontline lending. Credit, workout, mortgage, branch administration, operations, CRA, finance, regulatory reporting, legal, compliance, and business continuity teams all have distinct roles. The lending and workout functions will need to determine when and how to adjust terms for affected borrowers. Finance and regulatory reporting teams will need to evaluate whether operational disruption could delay required filings. Branch and facilities teams may need to address temporary locations, relocations, or interrupted publishing processes. CRA personnel will need to track qualifying disaster-recovery activity with more discipline than usual if the institution expects examination credit.

The release also matters for institutions that are not headquartered in the designated areas but hold municipal securities, public-sector loans, warehouse lines, consumer mortgage exposure, or vendor dependencies tied to those communities. The FDIC expressly encourages institutions to monitor securities and loans of municipalities in affected areas and take prudent efforts to stabilize those investments. That instruction reaches beyond branch footprint questions and into balance-sheet monitoring, collateral valuation, and concentration management.

Key Dates and Deadlines

No separate compliance deadline or relief expiration date is specified in the release. The following dates are clearly stated in the official materials:

• December 5, 2025 to December 19, 2025: the disaster period identified in the FDIC highlights.
• April 7, 2026: FEMA declared a federal disaster for selected Washington areas, according to the FDIC release.
• April 21, 2026: the FDIC issued FIL-16-2026.
• Not specified in the release: any automatic extension period for Call Reports or other filings, any firm end date for supervisory relief, and any separate deadline for requesting temporary facilities or publishing relief.

Practical Action Checklist

1. Map the institution’s exposure to the designated Washington counties, tribal areas, and Samish (TDSA), including branches, ATMs, borrowers, pledged collateral, municipal holdings, service providers, and workforce location.
2. Open a centralized disaster-response log that records borrower-relief decisions, operational disruptions, communications with the San Francisco Regional Office, and any branch or temporary-facility actions taken under the FIL.
3. Review loan-modification and accommodation protocols now, including extension, deferral, renewal, and restructuring templates, so frontline teams are not improvising terms under pressure.
4. Require credit and accounting teams to document individualized analysis of modified loans under ASC Subtopic 310-10, as amended by ASU 2022-02, together with ASC Topic 326 considerations, because the FIL expressly preserves those case-by-case judgments.
5. Identify any community development loans, investments, or services that could support recovery in federally designated disaster areas and set up CRA tracking at the time the activity is approved rather than trying to reconstruct support later.
6. Stress-test municipal and public-sector exposure in the affected areas, including payment interruption risk, insurance proceeds timing, collateral deterioration, and covenant compliance.
7. If operational disruption could delay Reports of Income and Condition or other required filings, notify the San Francisco Regional Office promptly and preserve evidence showing why the delay is beyond the institution’s control.
8. Assess whether any branch closing, relocation, reduced-hours arrangement, or temporary-facility need could trigger publishing or notice obligations that are impracticable under current conditions, and raise those issues with the regional office before deadlines are missed.
9. Reinforce Regulation Z emergency-waiver procedures for principal dwelling-secured loans so mortgage and consumer-lending staff understand the circumstances in which a rescission period may be waived or modified and what borrower documentation is required.
10. Prepare customer-facing communications that describe available relief accurately, avoid implying guaranteed accommodations, and distinguish clearly between institution-specific assistance and the FDIC’s supervisory posture.

Open Questions / Watch Items

First, the release expressly says FEMA may make additional designations after further damage assessments. Institutions with lending or operational exposure in nearby Washington areas should not treat the listed geography as static. Additional designations could affect customer outreach, collateral review, CRA planning, and branch-contingency decisions.

Second, the release offers flexibility, but it does not define the outer limits of that flexibility. There is no blanket statement that all affected reporting delays will be excused, that all branch-related publication requirements are suspended, or that every borrower accommodation will receive the same supervisory treatment. Institutions should assume the quality of their documentation, credit judgment, and communications with the regional office will matter.

Third, the CRA point is favorable but still operationally sensitive. The release says institutions may receive consideration for qualifying community development loans, investments, and services that revitalize or stabilize federally designated disaster areas within the parameters described by the interagency CRA Questions and Answers. It does not describe documentation standards, exam-cycle timing, or how exam teams will weigh disaster-response activity against ordinary CRA performance metrics.

Fourth, the accounting footnote matters. The FDIC’s statement that institutions should evaluate loan modifications individually under ASC Subtopic 310-10, ASU 2022-02, and ASC Topic 326 leaves little room for a purely programmatic approach. A disaster-relief initiative may be prudent and encouraged, but institutions still need disciplined borrower-level analysis, reserve implications, and consistent treatment across credit, finance, and audit functions.

My Law Tampa publishes this website memo as part of its public-facing coverage of banking and financial services regulatory developments.

This material is informational only, is not legal advice, and does not create an attorney-client relationship.

Source Materials

• Official publication: FIL-16-2026
• Regulator archive: FDIC memo archive
• Memo library: browse the full regulatory memo archive
• Related memo: FDIC Revises Interagency Model Risk Management Guidance
• Related memo: FDIC Issues 2026 Consumer Compliance Supervisory Highlights
• Related memo: FDIC First Quarter 2026 Call Report Instructions: FIL-10-2026