We also had the FinCEN Advisory
from April 2020 very early in the pandemic where financial institutions were instructed to notify FinCEN and their regulator if they were struggling to meet BSA reporting deadlines due to the pandemic.
If our internal controls had to be adjusted, if we had some late CTRs or SARs as a result of staffing issues with office closures, staff rotations and the like, then the examiners could be looking to the risk assessment to see if we identified risks that impacted our program as a result of COVID.
One of my clients just started their OCC exam and one of the first questions asked was, "Did you have to revise and procedures or processes as a result of COVID?"
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