On March 22, 2020, the United States Office of the Comptroller of the Currency (OCC) announced an interim final rule effective immediately to revise its short-term investment fund (STIF) rule for national banks acting in a fiduciary capacity.[1] The amendment allows the OCC to authorize banks to temporarily extend maturity limits of STIFs in order to address the market stress caused by the COVID-19 outbreak that is adversely affecting banks’ ability to operate in compliance with maturity limits identified in the STIF rule. While the amendment directly applies to national banks, other managers of STIF may be indirectly affected.[2]

In connection with the announcement of the interim final rule, the OCC announced an order, effecting the amendment to the STIF rule, to extend maturity limits for STIFs affected by COVID-19.[3] Pursuant to the order, a bank will be deemed to be in compliance with the STIF rule if:

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