I have been asked to research any compliance guidance in the event of a civil war. Would anyone like to opine whether this would fall under Act of God? I am not sure where to begin. Any suggestions would be greatly appreciated.

an act of God normally is indicative of a weather related type of event, so i would say that war does not fall under this.

i'd suggest a call to your primary regulator and pose that question, i am not aware of any civil war guidance

Isn't it kind of going to depend which side you end up on?

War is one of the emergency conditions listed in Regulation CC:

(f) Emergency conditions. Sections 229.10(c) and 229.12 do not apply to funds deposited by check in a depositary bank in the case of--

(1) An interruption of communications or computer or other equipment facilities;

(2) A suspension of payments by another bank;

(3) A war; or

(4) An emergency condition beyond the control of the depositary bank, if the depositary bank exercises such diligence as the circumstances require.

I would consider it an Act of Man, not god.

Let me check my copy of the Federal Register from 1859

Randy

They say history repeats itself and wasn't the civil war a battle of ideologies and what people thought was right. Given the events of last week at the capital and rumors of what might yet happen--Well I guess we will have to wait until it happens- if it does and see what guidance our regulators provide us.

If we do have a civil war, which I very very highly doubt, the last thing I am going to be worried about is some dumb examiner giving me grief for some regulation violation.

To be fair - I wouldn't be overly worried about what a smart examiner would say, either.

Are you all prepared for a "run" on the bank?

We are considering imposing a $5000.00 max cash withdrawal per account.

Good point! 😁

Look at all of the bank's insurance carefully. Expect to find exclusions of coverage for losses due to war and acts of God. Assuming that to be the case, your success with a claim would depend on what caused the loss, the policies' definitions of exactly what is/isn't an act of war, and the type of evidence you will have to produce to support a claim.