FDIC COVID Operational 6 – Sales of Held-to-Maturity Securities. If a financial institution …, will that financial institution's intent to hold other investment securities to maturity be questioned?

Compliance > COVID & Pandemic-Related
Q:   Sales of Held-to-Maturity Securities. If a financial institution affected by the impact of COVID-19 sells investment securities that were classified as "held to maturity" (HTM) to meet its liquidity needs, will that financial institution's intent to hold other investment securities to maturity be questioned?
 
A:   Under normal circumstances, the sale of any HTM investment would call into question an institution's intent to hold its remaining HTM investments to maturity. However, ASC Section 320-10-25 indicates that events that are isolated, nonrecurring, and unusual for the reporting enterprise that could not be reasonably anticipated may cause an enterprise to sell or transfer an HTM debt security without necessarily calling into question its intent to hold other HTM debt securities to maturity. ASC Section 320-10-25 specifically states that extremely remote disaster scenarios should not be anticipated by an entity in deciding whether it has the positive intent and ability to hold a debt security to maturity.  Accordingly, in this situation, the sale of any HTM investment security would not necessarily call into question the bank’s intent to hold its remaining HTM investment securities until maturity. Financial institutions are encouraged to maintain documentation memorializing the intent and purpose of transactions involving the sale of HTM investment securities.
 
 
This Q&A was contained in the Frequently Asked Questions for Financial Institutions Affected by the Coronavirus Disease 2019 (Referred to as COVID-19) – As of March 3, 2021 (which may be updated from time to time).  This may be found on the FDIC’s website here:  https://www.fdic.gov/Coronavirus/faq-fi.pdf.
 

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