Even before COVID-19, the first quarter of 2020 was shaping up to be an uncertain one for large public banks. Now, it could be a disaster.

There is broad concern that the current expected credit loss standard, which has been effective since the start of 2020 for big banks, will aggravate an already bad situation by discouraging lending and loan modification efforts just when the new coronavirus is wreaking havoc on the economy. Congress is poised to offer banks temporary relief from the standard as a part of its broader relief act.

Section 4014 of the Coronavirus Aid, Relief, and Economic Security Act, or CARES Act, would give insured depository institutions and bank holding companies the option of temporarily delaying CECL implementation until Dec. 31, 2020, or “the date on which the public emergency declaration related to coronavirus is terminated.”

Congress’ bill comes as the Financial Accounting Standards Board has already rebuffed the efforts of one regulator to delay the standard.

On March 19, Federal Deposit Insurance Corp. Chairman Jelena McWilliams sent a letter to the board seeking, among other requests, a postponement of CECL implementation for banks currently subject to the standard and a moratorium for banks with the 2023 effective date.

McWilliams wrote that a moratorium would “allow these financial institutions to focus on immediate business challenges relating to the impacts of the current pandemic and its effect on the financial system.”

FASB declined to act on both proposals. “We’re continuing to work with financial institutions to understand their specific challenges in implementing the CECL standard,” wrote spokesperson Christine Klimek in an email to me later that day.

It’s not an overstatement to say that the standard’s reporting effective date could not come at a worse time for banks — or that a potential delay necessitating a switch back to the incurred loss model may be a major undertaking for banks scheduled to report results in the next several weeks.

“Banks are being tasked with something pretty complex in a very short timeframe. And of course, this is the first period that they’re including these numbers and a lot of the processes are brand new,” says Reza Van Roosmalen, a principal at KPMG who leads the firm’s efforts for financial instruments accounting change. “They’ve practiced with parallel runs. But you’re immediately going to the finals without having had any other games. This is the hardest situation you could be in.”

CECL has been in effect since the start of the new year for large banks and its impact was finally expected to show up in first-quarter results. But the pandemic and related economic crisis creates major implications for banks’ allowances and could potentially influence their lending behavior.

The standard requires banks to reserve lifetime loan losses at origination. Banks took a one-time adjustment to increase their reserves to reflect the lifetime losses of all existing loans when they switched to the standard, deducting the amount from capital with the option to phase-in the impact over three years. Afterwards, they adjusted their reserves using earning as new loans came onto the books, or as their economic forecasts or borrowers’ financial conditions changed. The rapid spread and deep impact of COVID-19, the bulk of which has been experienced by the U.S. in March, has led to a precipitous economic decline and interest rate freefall. Regulators are now encouraging banks to work with borrowers facing financial hardship.

“For banks, [CECL is] going to be a true test for them. It’s not just going through this accounting standard in the macroeconomic scenario that we’re in,” says Will Neeriemer, a partner in DHG’s financial services group, pointing out that the change comes as many bankers adjust to working from home or in shifts to keep operations running. “That is almost as challenging for them as going through the new standard for the first time in a live environment.”

The concern is that CECL will force allowances to jump once more at the beginning of the standard as once-performing loans become troubled all at the same time. That could discourage new lending activity — leading to procyclical behavior that mirrors, rather than counters, economic peaks and troughs.

It remains to be seen if that would happen if Congress doesn’t provide temporary accounting and provisioning relief, or if some banks decline the temporary relief and report their results under CECL. Regardless, the quarter will be challenging for banks.

“It’s temporary relief and it’s only for this year. It keeps the status quo, which I think is important,” says Lawrence Kaplan, chair of the bank regulatory group in Paul Hasting’s global banking and payments systems practice. “You don’t have to have artificial, unintended consequences because we’re switching to a new accounting standard during a period where there are other extraordinary events.”