The truthful answer is that you just have to do your best to comply on time. It’s called guidance, but the FDIC expects all state-chartered non-member banks to follow the guidance. You do the best you can, and if you get dinged, you can make the argument that it’s merely guidance, which should not be considered mandatory. Document the reasons why you could not comply on time and steps taken to comply, and take some solace in the fact that it’s guidance — not a regulation.