NCBA Members,
We are monitoring the incoming snow and ice event, and according to the North Carolina Emergency Operations Center, most of North Carolina is expected to be affected. The NCBA is engaged with the NC Business Emergency Operations Center on behalf of the banking industry, and we are already receiving regular updates on preparations and weather conditions.
During the storm and in the aftermath, attention will shift to storm damage, road conditions, power outages, water issues, and potential business interruptions. Please watch for emails from me, and possibly other members of the NCBA team, during this event with updates and requests for information.
Governor Stein’s State of Emergency Declaration
https://governor.nc.gov/executive-order-no-31-declaration-state-emergency-and-temporary-waiver-and-suspension-motor-vehicle
Temporary Branch Closures for Weather Emergencies
North Carolina law and federal regulations give banks discretion to temporarily close branches when severe weather or other emergencies make normal operations unsafe.
State-Chartered Banks
North Carolina state-chartered banks determine their own days and hours of operation. During an emergency, the Commissioner of Banks may authorize banks in affected areas to suspend operations for a defined period. The statute also permits a bank officer to suspend operations without prior approval when an emergency prevents normal business, provided the bank notifies the Commissioner as soon as practicable. In past weather events, banks have relied on this authority to delay openings or close branches when road conditions, power outages, or other hazards made operations unsafe for employees or customers. (North Carolina General Statutes § 53C-6-19.)
FDIC, Federal Reserve, and OCC Guidance
Federal law distinguishes temporary emergency closures from permanent branch closings. For temporary emergency closures, federal regulators expect banks to act prudently, prioritize safety, resume operations as soon as conditions allow, and maintain internal documentation supporting the closure. When storms are severe or disruptions are widespread, federal agencies may issue public statements acknowledging that affected institutions may temporarily close. For national banks and federal savings associations, the OCC may reference its Supervisory Guidance on Natural Disasters and Other Emergency Conditions, which outlines expectations for emergency response, communication, and continuity of operations.
Your NCBA team will continue monitoring the storm through the weekend in anticipation of possible branch closures and other operational challenges. Please do not hesitate to call or email us if you have questions or if we can be of assistance to you and your team.
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