UPDATE 05/29/2020 - The House voted 417-1 to pass legislation to ease restrictions on the Small Business Administration’s Paycheck Protection Program, as advocated for by ICBA.

H.R. 7010: Paycheck Protection Program Flexibility Act of 2020, sponsored by Reps. Dean Phillips (D-Minn.) and Chip Roy (R-Texas), extends the time for businesses to spend the money from eight to 24 weeks and lowers the amount that must be spent on payroll costs from 75 to 60 percent.

In its letter to Congress Wednesday, ICBA argued that the PPP loan forgiveness restrictions were “far too onerous and complex,” and hindered community banks’ ability to distribute critical funds to companies in need.

"We've got basically a two-week window here to make any reasonable reforms to the forgiveness side," ICBA’s Paul Merski told Politico.

ICBA encourages community banks to use its Be Heard grassroots action center and tell lawmakers to make these necessary changes to ensure the program reaches as many small businesses and employees as possible. Note: Internet Explorer users who experience problems accessing the ICBA Action Center can try using an alternative web browser, such as Chrome, Firefox, or Safari.
UPDATE 05/28/2020 - ​ICBA and 43 state banking associations wrote to Congress seeking more workable forgiveness loan terms under the Small Business Administration’s Paycheck Protection Program.

In a separate letter to congressional leaders Wednesday, ICBA called the program’s forgiveness rules and procedures “far too complex and onerous,” and said the U.S. Treasury’s long-awaited guidance was “a source of disappointment and frustration” that presented “a new source of liability risk for community bankers who have acted in good faith.” Among its recommendations, the banking coalition requested: 

  • More flexible spending to preserve small business viability and employment, authorizing borrowers to spend up to 50 percent of loan proceeds on allowable, non-payroll expenses and extending the current 8-week period for spending PPP funds.
  • Easy-to-use forms and procedures for PPP forgiveness, including a presumption of compliance for loans of $1 million or less, and a PPP loan forgiveness calculator to help determine forgiven debt.
  • Preserving business operating expense deductions for PPP borrowers that obtain loan forgiveness.

​ICBA encourages community banks to use its Be Heard grassroots action center and tell lawmakers to make these necessary changes to ensure the program reaches as many small businesses and employees as possible.
UPDATE 05/27/2020 - ​ICBA commended the FDIC’s proposal to partially mitigate the effects of participating in the Paycheck Protection Program and other emergency programs on deposit-insurance assessments, while calling for additional relief measures. In its filed comment letter, ICBA asked the FDIC to ensure that community banks that originated and hold PPP loans, but do not participate in Federal Reserve’s PPP Lending Facility, are not unfairly penalized.
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“All PPP loans should be excluded not only from the calculation of the loan mix index, but from any measure used to calculate an insured depository institution’s assessment rate if their inclusion would have an adverse impact on an IDI’s assessment rate. Furthermore, all PPP loans should be excluded from an IDI’s assessment base,” ICBA wrote.
UPDATE 05/26/2020 - ​ICBA is calling on community bankers to provide Congress with policy recommendations for the next COVID-19 relief bill.

With Congress considering what to include in the next relief package, ICBA's Be Heard grassroots action center offers a customizable letter to lawmakers on pro-community bank provisions.

The custom letter emphasizes ICBA-advocated policies on Paycheck Protection Program reform, capital and accounting relief, liability protections, a tax exemption for serving rural communities, and more.

ICBA will continue working with Congress and the Trump administration to implement pro-growth policies as the debate over the next stimulus continues.
UPDATE 05/22/2020 - ​The Small Business Administration released long-sought guidance on submitting the initial SBA Form 1502 for Paycheck Protection Program loans. Lenders are required to submit the form to report on PPP loans and collect the processing fees on fully disbursed loans.

In a new Procedural Notice, the SBA lays out how to create an account with the Fiscal Transfer Agent and use the portal to submit loan information. Lenders must use separate 1502 reports for PPP loans as opposed to regular 7(a) loans.

Under an interim final rule approved earlier this week, the deadline to submit the initial SBA Form 1502 for PPP loans is now the later of: (1) May 29, 2020, or (2) 10 calendar days after disbursement or cancellation of the PPP loan.

That interim final rule also extends the repayment date for the PPP certification safe harbor regarding the borrower’s need for the loan. Under that policy, any borrower that applied for a PPP loan prior to April 24 and repaid the loan in full by May 18 will be deemed by SBA to have made the required certification in good faith.

ICBA and community bankers have repeatedly called on the agencies to provide needed PPP guidance. Additional PPP guidance and resources are available on Treasury’s PPP webpage and ICBA's COVID-19 resource center.
UPDATE 05/21/2020 - ​The OCC released its final rule to reform Community Reinvestment Act regulations. Because the FDIC and Federal Reserve declined to sign on to the rule, it will apply only to national banks and savings associations.

The 372-page final rule clarifies what qualifies for CRA consideration, updates how banks define assessment areas, and introduces quantitative measures to assess the volume and value of activity, among many other provisions. The rule is set to take effect in October, though examination standards will not be in place for two years.

The FDIC said Wednesday it will not join the OCC in finalizing the agency proposal and that it recognizes the outsized effort of community banks to support small businesses and families amid the COVID-19 pandemic. The Federal Reserve said in December that it would not join the other agencies when the rule was proposed.

In a statement, ICBA said it supports provisions in the final rule allowing community banks up to $2.5 billion in assets to remain under the existing CRA framework—as advocated by ICBA in its comment letter. The new opt-in threshold is up from $500 million in the OCC's proposal.

Among other updates that reflect ICBA advocacy, the final rule also provides that retail loan originations sold within a year of origination will receive credit for 100 percent of the origination value—up from 25 percent for loans sold within 90 days. It also will provide additional consideration to minority depository institutions, as advocated by ICBA.

However, community banks remain concerned that the new regulatory framework is too complex and would impose new and excessive data-collection costs that could inhibit their ability to serve local communities, ICBA President and CEO Rebeca Romero Rainey said. ICBA will continue reviewing the final rule and working with all regulatory agencies on CRA modernization.
UPDATE 05/20/2020 - ​The Small Business Administration said it is extending the deadline for Paycheck Protection Program lenders to submit the initial SBA Form 1502, for which the agency has yet to provide detailed guidance.

In the latest update to its PPP frequently asked questions, SBA said it is extending the deadline for lenders to electronically upload the initial SBA Form 1502 to the later of: (1) May 29, 2020, or (2) 10 calendar days after disbursement or cancellation of the PPP loan.

Lenders are required to submit the form to report on PPP loans and collect the processing fees on fully disbursed loans to which they are entitled, though SBA has yet to provide guidance on the Form 1502 reporting process.

PPP lenders should not report their PPP loans on SBA Form 1502 until the SBA has released additional guidance, SBA 7(a) Fiscal and Transfer Agent Colson Services Corp. says in an online advisory.

The previous Form 1502 deadline for loans approved before the form is available was this Friday, May 22. SBA said the new deadline will be implemented through revisions to its PPP interim final rules.

Additional PPP guidance and resources are available on Treasury’s PPP webpage and ICBA's COVID-19 resource center.
UPDATE 05/19/2020 - ​ICBA launched a new Paycheck Protection Program loan campaign to connect small businesses with community banks that continue to offer these loans.

The multichannel effort features a focused community bank finder along with targeted efforts on multiple social and digital channels, including Facebook’s Economic Relief for Small Businesses Portal.

ICBA also added to its Tell Your Story Toolkit new graphic assets that community banks can use to promote their PPP lending.

A recent ICBA survey found that community bankers funded some 80 percent of loan requests during the first round of PPP. The SBA has reported that community banks with less than $10 billion in assets have made roughly $63 billion in loans during the second round, while those with between $10 billion and $50 billion in assets account for some $30 billion.
UPDATE 05/18/2020 - ​The Small Business Administration and Treasury Department released the Paycheck Protection Program Loan Forgiveness Application and instructions.

The application form and instructions inform borrowers how to apply for forgiveness of their PPP loans, consistent with the CARES Act. The SBA also said it will also soon issue regulations and guidance to help borrowers complete their applications and inform lenders of their responsibilities.

The form and instructions include:
  • Options for borrowers to calculate payroll costs using an “alternative payroll covered period” that aligns with borrowers’ regular payroll cycles.
  • Flexibility to include eligible payroll and non-payroll expenses paid or incurred during the eight-week period after borrowers received their PPP loan.
  • Step-by-step instructions on how to perform the calculations required by the CARES Act to confirm eligibility for loan forgiveness.
  • Statutory exemptions from loan forgiveness reduction based on rehiring by June 30.
  • The new exemption for borrowers whose good-faith, written offers to rehire workers were declined.

ICBA and community bankers have repeatedly called on the agencies to provide guidance on PPP loan forgiveness.

Community bankers who continue to have trouble with the SBA's E-Tran and SBA Connect Lender Gateway portals can direct assistance questions to the SBA at 833-572-0502 or cls@sba.gov. Additional guidance and resources are available on Treasury’s PPP webpage and ICBA's COVID-19 resource center.
UPDATE 05/15/2020 - The Small Business Administration said it has marked some loans in Paycheck Protection Program lender portfolios with a “research” status requiring further review by lenders by 5 p.m. (Eastern time) today.

The SBA issued a document with step-by-step instructions on how to use a new search functionality within the E-Tran Servicing section of the Capital Access Financial System to locate loans with the “research” designation and to review and confirm records on those loans.

The SBA said lenders should review all fields in these files for accuracy and completeness, including borrower names and employer identification numbers or Social Security numbers. If necessary, lenders should contact borrowers to determine whether a loan should be cancelled, SBA said.

The SBA also announced it has changed how it receives PPP loan data from lenders via E-Tran. Business type will now determine whether a loan application should be submitted with either an SSN or EIN. SSNs can no longer be used in place of a primary taxpayer identification number for types of businesses that require an EIN, it said.
UPDATE 05/14/2020 - ​The SBA and Treasury Department announced a safe harbor that will apply to reviews of good-faith certifications concerning the necessity of Paycheck Protection Program loan requests.

In the latest update to their frequently asked questions on the program, the agencies said any borrower that, together with its affiliates, received PPP loans with an original principal amount of less than $2 million will be deemed to have made the required certification concerning the necessity of the loan request in good faith.

The agencies said:
  • Borrowers with loans below this threshold are generally less likely to have access to adequate sources of liquidity, and the safe harbor will promote economic certainty for them.
  • The SBA previously said all PPP loans over $2 million—and other loans as appropriate—will be subject to review.  
  • Borrowers with loans greater than $2 million that do not satisfy this safe harbor may still have an adequate basis for making the required good-faith certification.
  • If SBA determines that a borrower lacked an adequate basis for the required certification, it will seek repayment of the outstanding PPP loan balance and will inform the lender that the borrower is not eligible for loan forgiveness.
  • If the borrower repays the loan after receiving notification from SBA, the agency will not pursue administrative enforcement or referrals to other agencies.
  • SBA’s determination on these certifications will not affect its loan guarantees, which remain in place.

Community bankers who continue to have trouble with the SBA's E-Tran and SBA Connect Lender Gateway portals can direct assistance questions to the SBA at 833-572-0502 or cls@sba.gov. Additional guidance and resources are available on Treasury’s PPP webpage and ICBA's COVID-19 resource center.
UPDATE 05/13/2020 - The FDIC approved a proposed rule to mitigate the effects of participating in the Paycheck Protection Program and other emergency programs on deposit-insurance assessments.

The proposed rule also would apply to the Federal Reserve's PPP Lending Facility and Money Market Mutual Fund Liquidity Facility. It would ensure banks are not subject to significantly higher assessments for participating in these programs.

The FDIC is proposing an effective date by June 30, 2020, and an application date of April 1, 2020, which would ensure that the changes are applied to assessments starting in the second quarter.

Comments are due seven days after publication in the Federal Register.
UPDATE 05/06/2020 - ICBA called on the Treasury Department and Small Business Administration to provide additional guidance on the process for obtaining forgiveness of Paycheck Protection Program loans.
In a letter, ICBA urged the agencies to:
  • Reconsider the SBA’s non-statutory requirement that 75 percent of PPP loan proceeds must be spent on retaining payroll. ICBA recommends lowering the payroll expense requirement to no more than 50 percent to help small businesses meet other overhead costs.
  • Provide a straightforward, easy-to-apply approach to loan forgiveness, such as developing a PPP loan-forgiveness calculator that will allow borrowers and lenders to easily determine the forgiven amount.
  • Establish a presumption of compliance for all loans with an original balance of $1 million or less based on the borrower’s certification that the funds were used in accordance with the terms of the program.
  • Address the many questions that have arisen related to PPP loan forgiveness, such as the consequences if borrowers spend less than 75 percent of their PPP loans on payroll and what constitutes full-time staff and new hires.
UPDATE 05/05/2020 - The Treasury Department updated its Paycheck Protection Program frequently asked questions with new guidance on loan forgiveness, seasonal employers, and nonprofit hospitals. The latest updates note that:
  • SBA and Treasury intend to issue an interim final rule excluding laid-off employees whom borrowers have offered to rehire (but who decline to return to work) from the loan-forgiveness-reduction calculation.
  • Seasonal employers that elect to use an alternative base period to calculate maximum PPP loan amounts can make all required certifications on the Borrower Application Form.
  • Nonprofit hospitals may qualify as nonprofit organizations under the CARES Act.

The SBA reported Sunday that between April 27 and May 1, lenders with less than $10 billion in assets made more than $55 billion in loans during the second round of the PPP. Lenders with between $10 billion and $50 billion in assets made nearly $28 billion in PPP loans during that time.

ICBA, affiliated state associations, and community bankers worked to ensure at least $60 billion of the PPP funds were aside for community financial institutions, including at least $30 billion for institutions under $10 billion in assets and another $30 billion for those with between $10 billion and $50 billion in assets.

Community bankers who continue to have trouble with the SBA's E-Tran and SBA Connect Lender Gateway portals can direct assistance questions to the SBA at 833-572-0502 or cls@sba.gov.

​Additional guidance and resources are available on Treasury’s PPP webpage and ICBA's COVID-19 resource center.
UPDATE 05/04/2020 - The Small Business Administration on Friday released guidance for Paycheck Protection Program lenders on selling whole PPP loans.

According to the SBA procedural notice, loans must be sold to lenders that have signed loan guarantee agreements. SBA’s prior written consent is not required for whole-loan sales, though originating lenders must immediately notify SBA’s Office of Credit Risk Management.

Also Friday, the IRS released a notice on deductibility for federal income tax purposes of certain otherwise deductible expenses incurred in a taxpayer’s trade or business when the taxpayer receives a PPP loan.

Specifically, the IRS notice clarifies that no deduction is allowed if the payment of the expense results in forgiveness of a covered loan under the CARES Act and the income associated with the forgiveness is excluded from gross income for purposes of the law.

Community bankers who continue to have trouble with the SBA's E-Tran and SBA Connect Lender Gateway portals can direct assistance questions to the SBA at 833-572-0502 or cls@sba.gov.

​Additional guidance and resources are available on Treasury’s PPP webpage and ICBA's COVID-19 resource center.
UPDATE 05/01/2020 - The Treasury Department confirmed that while the SBA plans to review individual Paycheck Protection Program loans, the reviews will not affect SBA’s guarantee of loans for which lenders complied with their PPP obligations.

In the latest update to Treasury's frequently asked questions on the program, the department reiterated its announcement earlier this week that it will review all loans over $2 million, in addition to other loans as appropriate, after lenders submit borrower loan-forgiveness applications. Additional guidance on that is still to come.

The key point is that the reviews will not affect loan guarantees for lenders that follow the obligations set forth in paragraphs III.3.b(i)-(iii) of the April 2 Paycheck Protection Program Rule. These obligations are further explained in the first FAQ in the Treasury document.

In other words, lenders that meet their obligations will not be penalized if borrowers do not meet theirs, and the guarantee will remain.

Community bankers who continue to have trouble with the SBA's E-Tran and SBA Connect Lender Gateway portals can direct assistance questions to the SBA at 833-572-0502 or cls@sba.gov.

​Additional guidance and resources are available on Treasury’s PPP webpage and ICBA's COVID-19 resource center.
UPDATE 04/30/2020 - The Small Business Administration for nearly eight hours yesterday only accepted Paycheck Protection Program loans from lenders with less than $1 billion in assets. The SBA said it reserved its systems for these banks between 4 p.m. and 11:59 p.m. (Eastern time) to ensure access for the smallest lenders and their small-business customers.

The SBA noted that lenders of all sizes will continue to be able to submit PPP loans outside this timeframe. The agency said it will work with the Treasury Department to evaluate whether to create a similar reserved time again in the future.

ICBA, affiliated state associations, and community bankers worked to ensure at least $60 billion of the PPP funds have been set aside for community financial institutions, including at least $30 billion for institutions under $10 billion in assets and another $30 billion for those with between $10 billion and $50 billion in assets. This has helped community banks meet their PPP customers’ needs.

The SBA reported earlier this week that community banks under $10 billion in assets neared the $30 billion in PPP funds set aside for them by the law restarting the program. These entities will continue to be able to submit loans to be funded by the $250 billion in general funds authorized for the second phase of the PPP.

ICBA President and CEO Rebeca Romero Rainey this week said in a national news release that many community banks found themselves continually kicked out of the SBA systems after the PPP went live. Community bankers can direct E-Tran and SBA Connect Lender Gateway assistance questions to the SBA at 833-572-0502 or cls@sba.gov.
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Additional guidance and resources are available on Treasury’s PPP webpage and ICBA's COVID-19 resource center.
UPDATE 04/29/2020 - Community banks under $10 billion in assets neared the $30 billion in Paycheck Protection Program funds set aside for them by the law restarting the program, according to reports of Small Business Administration data.

The SBA reportedly said that as of 1 p.m. (Eastern time) Tuesday, these institutions made 331,119 approved loans worth nearly $30 billion. They will continue to be able to submit loans to be funded by the $250 billion in general funds authorized for the second phase of the PPP.

Lenders with between $10 billion and $50 billion in assets have been approved for nearly 84,000 loans worth more than $10 billion. The law allocated $30 billion of the overall $310 billion for these institutions.

Overall, the SBA said it has approved more than 475,000 loans worth more than $52 billion from more than 5,100 lenders. The agency said the average loan size under phase two of the PPP is $111,000, down from $207,000 in the first round. Roughly 85 percent of the loans have been worth $150,000 or less, it said.

​ICBA continues encouraging community bankers to use its Be Heard grassroots alert to tell policymakers to ensure community banks have equitable access to PPP systems and to demand answers on why so many community banks have been locked out from submitting loans.
UPDATE 04/28/2020 - ICBA has heard loud and clear about the many problems community bankers have had with the relaunch of the Paycheck Protection Program—and they are unacceptable, ICBA President and CEO Rebeca Romero Rainey said in a message to community bankers.

Romero Rainey encouraged community bankers to use ICBA's Be Heard grassroots action center to tell policymakers to ensure community banks have equitable access to PPP systems. The grassroots alert also demands answers and solutions about why so many community banks were locked out from submitting loans.

The message followed a national news release in which Romero Rainey said most community banks found themselves continually kicked out of the E-Tran system after the PPP went live and received little information from the SBA and Treasury.

The SBA told Congress that it has implemented "pacing" for its CAFS/E-Tran system to limit the number of PPP applications that can be submitted each hour. The agency said the pacing may cause users to experience error messages in both the Connect Lender Gateway and E-Tran, a message that the application is taking longer than normal to process, server timeout messages, or a lack of access to the systems. SBA is advising lenders to continue trying to enter new applications.

The SBA separately said that it processed more than 100,000 PPP loans by more than 4,000 lenders by 3:30 p.m. (Eastern time) Monday. The agency said that E-Tran response times have been slowed partly because there are double the number of users accessing the system compared with any day during the initial round of PPP. The SBA is actively working to ensure system security and integrity while loan processing continues, it said.

Treasury and SBA also released additional PPP guidance that said the minimum amount of lender-approved and SBA-ready PPP loans that a lender must have ready for the XML file submission process is now 5,000 loans—down from 15,000. Those XML files of 5,000 or more approved PPP loans were due to SBA by 9 p.m. (Eastern time) last night.

​Community bankers can direct E-Tran assistance questions to the SBA at 833-572-0502 or cls@sba.gov. Additional guidance and resources are available on Treasury’s PPP webpage and ICBA's COVID-19 resource center.
UPDATE 04/27/2020 - The Small Business Administration and Treasury Department on Sunday announced measures they will take during the next phase of the Paycheck Protection Program.

In a message to lenders, the agencies announced the following measures:
  • Pacing the number of loans processed in the E-Tran system for participating lenders when processing resumes at 10:30 a.m. (Eastern time) today.
  • Instituting a maximum dollar amount at 10 percent of PPP funding authority that any lending institution will be able to originate, exclusive of the additional $60 billion preserved for lenders with assets under $50 billion.
  • Implementing operational standards to ensure that lenders access PPP funds based on their asset size.
  • Ensuring the PPP continues to operate on a first-come, first-serve basis.
  • Issuing new guidance allowing lenders that have received a significant amount of loan applications to make a one-time bulk submission of XML files to E-Tran.

ICBA this weekend confirmed that any PPP applications received by lenders prior to April 25 can be processed based on guidance in effect prior to that day. Any applications received by lenders moving forward will have to comply with new Treasury and SBA guidance.

That clarification follows this weekend's release of additional resources for PPP participants, including:
All additional prior guidance can be found on Treasury’s PPP webpage. Additional resources for community banks are available on ICBA's COVID-19 resource center.

​The new law restarting the PPP dedicates at least $30 billion for loans from institutions under $10 billion in assets and another $30 billion for those with between $10 billion and $50 billion in assets. This allocation reflects ICBA, affiliated state association, and community banker advocacy for dedicating program funds for loans from community banks under $50 billion in assets.
UPDATE 04/24/2020 - The House passed bipartisan legislation to restart the Paycheck Protection Program and dedicate a portion of the funding exclusively to community banks, sending the bill to President Trump to be signed into law.

The bill authorizes an additional $310 billion in PPP funds with at least $60 billion set aside for loans made by community financial institutions, including minority depository institutions and Community Development Financial Institutions.

Specifically, the bill dedicates at least $30 billion for loans from institutions under $10 billion in assets and another $30 billion for those with between $10 billion and $50 billion in assets.

The allocations reflect repeated ICBA and community banker calls for policymakers to quickly pass a PPP funding extension and dedicate at least a quarter of the funds for loans from community banks under $50 billion in assets. ICBA has also urged the Treasury Department and SBA to immediately prepare to administer the community bank funding allocation.

The White House indicated President Trump will sign the bill into law today.
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More information on the program and other elements of the federal response to the COVID-19 emergency is available on ICBA's online resource center. ICBA will continue keeping community bankers posted of the very latest information as the agencies begin to restart the PPP and allocate funds.
UPDATE 04/23/2020 - The House today is set to take up Senate-passed legislation that includes an additional $310 billion to restart the Paycheck Protection Program with at least $60 billion set aside for community banks.

The bipartisan bill responding to the COVID-19 outbreak dedicates at least $30 billion of the PPP to institutions under $10 billion in assets and another $30 billion to those with between $10 billion and $50 billion in assets.

ICBA and the nation's community bankers have repeatedly called on policymakers to quickly extend the PPP and dedicate at least a quarter of the funds to community banks under $50 billion in assets.

In an American Banker op-ed published ahead of the Senate vote, ICBA Chairman Noah Wilcox urged Congress to ensure the legislation includes these policies.

ICBA also this week urged the Treasury Department and SBA to begin preparing to administer the community bank funding allocation. Community bankers can continue to use ICBA's Be Heard grassroots action center to urge Congress to immediately approve the legislation.
UPDATE 04/22/2020 - The Senate passed bipartisan legislation that includes an additional $310 billion to restart the Paycheck Protection Program and an ICBA-advocated $60 billion minimum set aside for community banks.

The legislation responding to the COVID-19 outbreak dedicates at least $60 billion of the PPP funds to community financial institutions, including $30 billion for institutions under $10 billion in assets and another $30 billion for those with between $10 billion and $50 billion in assets.

ICBA and the nation's community bankers have repeatedly called on policymakers to quickly pass a PPP funding extension and dedicate at least a quarter of the funds to community banks under $50 billion in assets.

In an American Banker op-ed published ahead of the vote, ICBA Chairman Noah Wilcox called on policymakers to ensure the legislation includes the ICBA-advocated policies to support local communities.

Looking ahead toward implementation by the Treasury Department and SBA, ICBA urged the agencies to begin preparing to administer the community bank funding allocation.
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With the bill headed to the House for a final vote tomorrow, ICBA continues calling on community bankers to urge Congress to immediately approve the additional PPP funding and community bank allocation via ICBA's Be Heard grassroots action center.
UPDATE 04/21/2020 - With the Senate scheduled to reconvene today amid negotiations over the next bill responding to the COVID-19 outbreak, ICBA is urging community bankers to continue their grassroots outreach on the Paycheck Protection Program.

While congressional and administration officials continue negotiations for some $300 billion in additional PPP funding, ICBA is working to ensure lawmakers include an ICBA-advocated provision that would dedicate 25 percent of the funds to community banks.

ICBA continues calling on community bankers to urge Congress to immediately approve additional funding for the PPP and the carve-out for community banks. ICBA offers a custom message to lawmakers on its Be Heard grassroots action center.

The Senate is set to reconvene at 4 p.m. (Eastern time) today, and the House has alerted its members to be ready to convene in Washington by 10 a.m. tomorrow for a recorded vote. ICBA will keep community bankers updated on the latest developments.

UPDATE 04/21/2020 - The Treasury Department today corrected a previous notice to financial institutions clarifying that Economic Impact Payment checks will be dated for this Friday, April 24—not tomorrow, April 22, as previously stated.

Treasury began mailing hard-copy checks on Saturday, with twice-daily mail pick-ups starting yesterday. Some customers have begun seeking to deposit the post-dated checks, including through remote deposit.

While Treasury has not yet issued written guidance on accepting the checks, banks are not expected to return EIP checks deposited before the April 24 pay date.
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More information on the EIPs are available on ICBA's COVID-19 resource center. ICBA will continue to keep community banks informed of the latest developments.
UPDATE 04/20/2020 - ICBA President and CEO Rebeca Romero Rainey called on community bankers to tell Congress to immediately approve additional funding for the SBA's Paycheck Protection Program now that it has exhausted its funds.

Romero Rainey urged community bankers to use ICBA's Be Heard grassroots action center to tell policymakers to immediately approve at least $250 billion in new PPP funds.

The customizable grassroots alert also calls on lawmakers to dedicate 25 percent of program funds to community banks with $50 billion or less in assets.
​
ICBA's other suggested reforms include more workable loan terms, more flexibility in the timing of loan disbursements, expanded PPP loan uses, a robust lender safe harbor, and suspending "beneficial ownership" rules.
UPDATE 04/17/2020 - With the SBA's Paycheck Protection Program officially out of funds, ICBA is urging community bankers to tell Congress to immediately approve additional funding for the small-business program.

Community bankers can use ICBA's Be Heard grassroots action center to tell policymakers to immediately approve at least $250 billion in new PPP funds.

The customizable grassroots alert also calls on lawmakers to dedicate 25 percent of program funds to community banks with $50 billion or less in assets.
​
ICBA's other suggested reforms include more workable loan terms, more flexibility in the timing of loan disbursements, expanded PPP loan uses, a robust lender safe harbor, and suspending "beneficial ownership" rules.
​UPDATE 04/16/2020 - ICBA called on policymakers to immediately approve additional funds for the Paycheck Protection Program as the initial round of program funds run out. ICBA is urging Congress to advance at least $250 billion in additional funds immediately for the Small Business Administration program.

ICBA is urging community bankers to use its Be Heard grassroots action center to tell policymakers to immediately approve the new PPP funds.

ICBA also strongly supports dedicating 25 percent of program funds to community banks with $50 billion or less in assets. ICBA's other suggested reforms include:
  • More workable loan terms to ensure community banks are not expected to extend credit at rates that are below funding costs.
  • More flexibility in the timing of loan disbursements to ensure the smooth flow of funds.
  • Expanded PPP loan uses to help small business meet significant non-payroll expenses.
  • A robust lender safe harbor to facilitate and speed loan processing.
  • Temporarily suspending "beneficial ownership" rules for applicants that are not current customers.

ICBA this week called for the additional funds and reforms in a message to congressional leaders. In a separate joint letter with more than 250 state and national organizations, ICBA on Wednesday again called on lawmakers to quickly advance additional funds.

​ICBA will continue working with policymakers to continue the program and ensure it reaches as many small businesses and employees as possible.
​UPDATE 04/15/2020 - The Treasury Department and Small Business Administration issued a new interim final rule answering key ICBA questions about the Paycheck Protection Program relating to bank directors, partnerships, self-employed borrowers, and more. The new interim rule supplements the one that was issued on April 2.
  • Participating PPP lenders are not barred by existing SBA restrictions from lending to outside bank directors and shareholders that own less than 30 percent equity in the bank. The rule notes that lenders should comply with all other state and federal regulations concerning loans to associates.
  • Officers and key employees of a PPP lender may not obtain a PPP loan from the lender in which they are associated but may borrow from a different PPP lender.
  • Self-employed individuals should complete IRS Schedule C for 2019, line 31, to determine self-employment income for 2019, and use that amount both for computing the maximum loan amount and for computing the allowable salary/payroll costs that may be forgiven during the eight-week period following loan disbursement. Self-employed individuals that have employees should also include the gross wages and tips computed using 2019 IRS Form 941.
  • Partners in a partnership should apply for PPP loans at the partnership level, not as self-employed individuals. Instead, self-employment income of active partners (up to $100,000 annualized) may be reported as a payroll cost by the partnership.
  • Pledging 7(a) loans to a Federal Reserve Bank or Federal Home Loan Bank, among others, does not require the SBA’s prior written consent or a notice to the SBA.
  • Businesses that are otherwise eligible for a PPP loan are not rendered ineligible due to receipt of legal gaming revenues if certain conditions are met.

Treasury and SBA also released updates to their PPP FAQ document. Among the newest FAQs, the agencies clarify that lenders must collect the information and certifications contained in the borrower application form and fulfill their obligations under the PPP final rule before submitting a PPP loan application.

ICBA is adding this latest information to its frequently asked questions on the PPP and other elements of the federal response to the COVID-19 outbreak. More information from the agencies is available on the SBA's PPP landing page.

SBA is taking questions at 7aPaycheckLoanProgramQuestions@sba.gov. However, the auto reply notes that SBA might not be able to provide an individual response due to the high volume of inquiries and cannot answer E-Tran or Capital Access Financial System questions via that email address. E-Tran assistance questions should continue to be directed to the hotline 833-572-0502 or cls@sba.gov.

Further, SBA has clarified that E-Tran users should choose “PPP” from the drop-down menu, not “7(a),” which will apply a set of requirements that aren’t relevant to PPP.

​ICBA will continue keeping community bankers informed of the very latest developments on the PPP and other elements of the federal response to the COVID-19 pandemic.
​UPDATE 04/14/2020 - Join ICBA Thursday, April 16, for the next Community Bank Briefing on the coronavirus outbreak. Spots are limited and are expected to fill up. Be sure to register ASAP:

ICBA Community Bank Briefing #6: COVID-19 Regulatory Update & Q&A
April 16 | 2 p.m. (Eastern)
This briefing addresses ICBA’s continued advocacy related to the COVID-19 outbreak, federal banking agency action to date–including Q&A on the SBA “Paycheck Protection Program”–and the remarkable response of community banks across the country.

ICBA experts highlight the latest guidance from the Treasury and SBA. While key questions remain unanswered, the ICBA team addresses the action it continues to take to push for more details and information for community banks.

Participants are encouraged to bring questions to the briefing as the ICBA team spends a majority of the time taking inquiries from community bankers.

Speakers:
  • Rebeca Romero Rainey, ICBA President & CEO
  • Karen Thomas, Senior Executive Vice President, Government Relations & Public Policy
  • Paul Merski, Group Executive Vice President, Congressional Relations
  • Chris Cole, Executive Vice President, Senior Regulatory Counsel
  • Ron Haynie, Senior Vice President, Mortgage & Finance Policy
  • Steve Keen, Vice President, Congressional Relations
  • James Kendrick, First Vice President, Accounting & Capital Policy

REGISTER HERE

UPDATE 04/14/2020 - ICBA Chairman Noah Wilcox and ICBA Vice Chairman Brad Bolton went on the Fox Business network to discuss how community banks are meeting the needs of their small-business customers amid the COVID-19 pandemic.

Appearing on Monday's episode of Mornings with Maria, Wilcox and Bolton said community banks have stepped up to the challenge and are closing loans under the Paycheck Protection Program despite problems accessing the program's loan portal.

Wilcox told host Maria Bartiromo that his Minnesota Lakes Bank is making roughly 40 percent of its PPP loans to new customers that have been turned away by larger financial institutions, while Bolton urged small businesses to use ICBA's Community Bank Locator to find a community bank near them.

The interview followed ICBA President and CEO Rebeca Romero Rainey's Friday appearance on the CBS Evening News, where she said community banks need more responsiveness and clarity from the Small Business Administration on the PPP. That broadcast cited letters from ICBA and state banking associations seeking updates to the PPP, including enhanced support for SBA systems and additional funds allocated for community banks.

ICBA continues to press the Treasury Department and SBA for answers to the questions that remain unanswered about the PPP, including whether banks can lend to their directors with eligible small businesses and whether owner draws or distributions count as payroll costs.

​ICBA continues to update its frequently asked questions on the PPP with the latest from the SBA's frequently asked questions and other information available on the agency's PPP landing page.
​UPDATE 04/13/2020 - The Treasury Department and Small Business Administration this weekend answered key questions about the Paycheck Protection Program. In updates to the agencies' PPP frequently asked questions, the agencies confirmed:
  • Lenders do not need to receive the usual separate SBA Loan Authorization document for the PPP loan in order for it to be guaranteed, though lenders must execute SBA Form 2484 (the PPP Lender Application form) for each PPP loan and receive a loan number for each originated PPP loan.
  • Lenders may include in their promissory notes for PPP loans any terms and conditions, including those relating to amortization and disclosure, that are not inconsistent with Sections 1102 and 1106 of the CARES Act, the PPP interim final rule and guidance, and SBA Form 2484. (For example, the act, interim rule and Form 2484 specify the 1 percent interest rate, two-year maturity and six-month payment deferral.)

SBA has also launched an email address for questions at 7aPaycheckLoanProgramQuestions@sba.gov. However, the auto reply notes that SBA might not be able to provide an individual response due to the high volume of inquiries and cannot answer E-Tran or Capital Access Financial System questions via that email address. E-Tran assistance questions should continue to be directed to the hotline 833-572-0502 or cls@sba.gov.

Further, SBA has clarified that E-Tran users should choose “PPP” from the drop-down menu. Do not choose “7(a),” which will apply a set of requirements that aren’t relevant to PPP.

ICBA has added this latest information to its own FAQs on the PPP and other elements of the federal response to the COVID-19 outbreak, including details of the Federal Reserve's new liquidity facility for PPP loans. These latest updates follow PPP clarifications earlier this week related to promissory notes, disbursements, and loan forgiveness.

​Nevertheless, key questions remain unanswered, ICBA President and CEO Rebeca Romero Rainey noted in a weekend message to community bankers. ICBA continues to ask Treasury and the SBA to provide definitive guidance on whether banks can lend to their directors with eligible small businesses and when owner draws or distributions count as payroll costs.
​UPDATE 04/10/2020 - The Federal Reserve took several actions to support the federal response to the COVID-19 pandemic, including providing details and a term sheet on its previously announced facility for SBA-guaranteed Paycheck Protection Program loans and launching a new Main Street Lending Program.

The Fed’s Paycheck Protection Program Facility provides liquidity by extending credit at a rate of 35 basis points on a non-recourse basis to eligible financial institutions that originate PPP loans, taking the loans as collateral at face value.

Through the Main Street Lending Program, the Fed will purchase up to $600 billion in four-year loans to companies with up to 10,000 workers or revenues of less than $2.5 billion. Banks will retain a 5 percent share and sell the remaining 95 percent to the Main Street facility, with principal and interest payments deferred for one year.

Under the Main Street Lending Program, eligible banks may originate new Main Street loans or use the facility to increase the size of existing loans to businesses. The minimum loan size is $1 million. The loans carry a four-year maturity and an adjustable rate of SOFR plus 250-400 basis points.

The Fed also expanded its Primary and Secondary Market Corporate Credit Facilities and Term Asset-Backed Securities Loan Facility, which together will support up to $850 billion in credit. And it established a Municipal Liquidity Facility that will offer up to $500 billion in lending to states and municipalities.

​The Fed released detailed term sheets on the PPP liquidity facility, new and expanded loans under the Main Street Lending Program, and the other programs. Additionally, ICBA updated its frequently asked questions on the federal response to COVID-19 with details of these and other emergency programs.
​UPDATE 04/09/2020 - The Treasury Department and Small Business Administration answered key ICBA questions about the Paycheck Protection Program. In new updates to the agencies' PPP frequently asked questions, they confirmed the following:
  • Lenders may use their own promissory note or an SBA form of promissory note for PPP loans. SBA Standard Loan Note (Form 147) is posted on the SBA website.
  • The lender must make the first disbursement of the loan no later than 10 calendar days from the date of loan approval.
  • The eight-week period of borrower payroll costs that determines the amount of forgiveness for PPP loans begins on the date the lender makes the first disbursement of the PPP loan to the borrower.

Meanwhile, pages 21-24 of the interim final rule detail the documentation and attestations lenders need to obtain from borrowers. The rule says the SBA will hold harmless any lender that relies on such borrower documents and attestation, as required by the CARES Act.

ICBA has added information from the Treasury/SBA FAQs to its own FAQs on the PPP. Nevertheless, key questions remain unanswered. ICBA continues to ask Treasury and the SBA to provide definitive guidance on:
  • Whether banks can lend to their directors with eligible small businesses, and
  • Whether owner draws or distributions count as payroll costs.

ICBA President and CEO Rebeca Romero Rainey said ICBA will let community bankers know as soon as there are answers to these questions. "And we thank you for all of your efforts to support local communities throughout the United States at this challenging time," she wrote in a message to community bankers.
​UPDATE 04/08/2020 - The Small Business Administration launched its long-awaited portal to facilitate Paycheck Protection Program access. The new portal allows non-SBA-certified lenders to:
  • Create an account on SBA Connect.
  • Request authorization to the Paycheck Protection Lender Gateway by providing their FDIC or Federal Reserve number and authorization number.
  • Proceed to the Lender Gateway to begin submitting loan authorization requests.

The SBA launched the portal while ICBA Chairman Noah Wilcox and ICBA Vice Chairman Brad Bolton participated in a virtual White House meeting with President Donald Trump, Treasury Secretary Steven Mnuchin, and SBA Administrator Jovita Carranza to discuss the status of the PPP.

Wilcox and Bolton cited ICBA's informal survey in which more than one-third of community bank respondents said they were unable to access the PPP system after its launch. At the meeting, Mnuchin said he is working with congressional leaders to approve another $250 billion for the PPP as soon as this week.

These developments follow the Treasury and SBA release of frequently asked questions on the PPP related to verifying borrower calculations, SBA affiliation rules, and more. ICBA has added information from those FAQs to its own FAQs on the PPP, which it continues to update with new information as it comes in.

​The latest updates follow the announcement of a Federal Reserve facility to provide term financing backed by PPP loans and the SBA's Friday night release of its Lender Agreement, an application for non-SBA-certified lenders to apply to enter the PPP system, input borrower applications, and register for SBA loan guarantees.
​UPDATE 04/07/2020 - The Federal Reserve said it will launch an ICBA-advocated facility to provide term financing backed by loans originated under the Small Business Administration's Paycheck Protection Program.

The announcement follows this weekend's ICBA call for a secondary market facility for the Fed to purchase program loans from originating institutions. In its Saturday night letter responding to community bank problems accessing the PPP, ICBA also called on policymakers to enhance the overburdened SBA systems, increase program funds, and dedicate funds to community banks.

Meanwhile, ICBA continues calling on policymakers to immediately launch its PPP portal for non-SBA lenders, which have had many problems accessing the new program. The SBA on Friday night released its Lender Agreement, an application for non-SBA-certified lenders to apply to enter the PPP system and input borrower applications.

The SBA continues encouraging lenders who need assistance to call its Lender Customer Service Line at 833-572-0502, though community bankers who have called that number are reporting mixed results on the agency's assistance. PPP resources are available on the Treasury and SBA websites.

​ICBA continues encouraging community bankers to weigh in on the launch of the program by completing a new survey on PPP access and processing. ICBA President and CEO Rebeca Romero Rainey said in a Main Street Matters post Friday night that one community bank left out is one too many.
​UPDATE 04/06/2020 - Following the flawed launch of the Paycheck Protection Program, ICBA this weekend urged the Treasury Department and SBA to update the program so every community bank can access the system.

“Nearly 48 hours after the Program went live, hundreds of lenders are still trying to get approval to access the SBA system so they can process loans,” ICBA President and CEO Rebeca Romero Rainey wrote in a letter to the agencies.

In its letter, ICBA called on policymakers to:
  • Support and enhance the overburdened SBA systems.
  • Increase program funds beyond the $349 billion appropriated.
  • Allocate at least 25 percent of existing and future program funds for banks with $50 billion or less in assets.
  • Launch a secondary market facility with the Federal Reserve to purchase program loans from originating institutions.

ICBA has worked tirelessly through the weekend to address the problems community banks have encountered in attempting to access the PPP, which Romero Rainey laid out in a new Main Street Matters post. "In my opinion, one community bank left out is one too many," she wrote.

​ICBA will continue working with policymakers to implement these recommendations to address the PPP's failed technology links and portals and ensure access for community banks.
​UPDATE 04/05/2020 - Join Community Banker University Tuesday, April 7, for a webinar on the practical implications of the COVID-19 pause for community banks. Spots are limited and are expected to fill up. Be sure to register ASAP:

The Great Pause of 2020: What COVID-19 Means for Community Banks
April 7 • 11 a.m. (Eastern)

History may reflect the current environment as “The Great Pause of 2020."

The webinar does not focus on the medical, political, or legislative ramifications of the situation but instead focuses on how community banks can continue to operate in the current environment and the potential outlook for strategic and capital planning, regulatory issues, board governance, shareholder concerns, and other areas.

Speakers: Philip K. Smith & Greyson Tuck

REGISTER TODAY!

​This webinar is free to all ICBA members and includes the opportunity to ask questions. Live event registration is limited to 900 participants.
You can also order a recording of the webinar, which is posted 24 hours after the live event.
​UPDATE 04/04/2020 - With many community bankers working through the weekend to help local customers access the Small Business Administration's Paycheck Protection Program, we are with you every step of the way and want you to have access to the latest resources from ICBA and the SBA.

ICBA today extensively updated our frequently asked questions on the PPP, including a breakdown of the additional guidance on affiliated companies issued overnight by the Treasury Department. The updated FAQs also include new information on faith-based organizations, payroll requirements, and many more details on various aspects of the program.

This follows the SBA's release yesterday of its Lender Agreement, an application for non-SBA-certified lenders to apply to enter the PPP system, input borrower applications, and register for SBA loan guarantees. The SBA encourages lenders who need assistance accessing the agency's E-Tran system to call its Lender Customer Service Line at 833-572-0502.

As I laid out in a Main Street Matters post last night, we know the flawed launch of the PPP has been filled with high tensions and desperate attempts by community bankers to access the SBA programs to meet the needs of their small-business customers. Too many community banks have been excluded from this process as they attempt to help their local communities through the COVID-19 challenge.

While Treasury and the SBA continue directing lenders and borrowers to their PPP webpages, ICBA and state community banking associations have clearly and repeatedly expressed community bank concerns about the program's terms and lack of timely guidance.

And through the weekend, ICBA will continue pulling out all stops to rectify this problematic program rollout and get you what you need to serve your customers and communities. We remain committed to our mission of creating and promoting an environment where community banks flourish, and we are dedicated to preserving your stellar reputation.

​Throughout this process, we will continue to keep you informed of the latest developments as soon as they are available. As always, thank you for all that you are doing—and trying to do—to serve your communities at this challenging time.
​UPDATE 04/03/2020 - We know today's flawed launch of the Small Business Administration's Paycheck Protection Program has been filled with high tensions and desperate attempts by community bankers to meet the needs of their small-business customers, as I laid out in a new Main Street Matters post.

Community bankers have always been there to meet their customers’ needs, and to be faced with a situation like they experienced today—in which they were unable to access the SBA programs promised to America’s small businesses due to failed technology links and portals—has been beyond stressful and disappointing for community bankers.

At the time of this release, the new portal is still not up and running and there is no ETA as to when that will occur. In addition, those banks with access to the E-Tran have expressed significant challenges with user access and latency in application processing. At the same time, media reports continue to indicate successful launches through the country by community banks, few of which we have been able to confirm.

Throughout the day today we have been in constant communication with Treasury and SBA to follow through on their promise to deliver much-needed funding to the thousands of small businesses that serve as the economic engines to our nation.

Community banks make 60 percent of all small-business loans, but they have been excluded from the process, and even implicated in numerous media stories as being unable to deliver, which could not be further from the truth. Rest assured, if community banks had been given the tools to deliver, they would have delivered.

We are continuing to work through this process and have been informed that the following developments are in the works to help community banks access this program.

The SBA has posted its Lender Agreement, an application for non-SBA-certified lenders to apply to enter the PPP system, input borrower applications, and register for SBA loan guarantees. The SBA encourages lenders who need assistance accessing the agency's E-Tran system to call its Lender Customer Service Line at 833-572-0502.

The latest updates follow the release last night of an interim final rule on the program. That rule increased the PPP interest rate to 1 percent from 0.5 percent and provided additional clarity on lender due diligence responsibilities, though access has remained extremely limited or altogether closed off for community banks across the nation.

With Treasury and SBA continuing to point lenders and borrowers to their PPP webpages, ICBA and state community banking associations have clearly and repeatedly expressed community bank concerns about the program's terms and lack of guidance.

Throughout this difficult rollout, please know that ICBA understands the gravity of this situation and is pulling out all stops to rectify this debacle. We remain committed to our mission and dedicated to preserving the stellar reputation of community banks throughout this great nation.

We will continue to keep you informed of the latest developments as soon as they are available. Thank you again for all that you are doing—and trying to do—on behalf of your communities at this challenging time.

UPDATE 04/03/2020 - After ICBA expressed serious concerns this week about terms and needed guidance, the Treasury Department and Small Business Administration last night issued an interim final rule on the Paycheck Protection Program.

According to the new rule, the agencies increased the PPP interest rate to 1 percent from 0.5 percent and have provided additional clarity on lender due diligence responsibilities.

The rule also notes that lenders do not need to conduct verification if borrowers submit documentation supporting their requests for loan forgiveness and attest that they have accurately verified the payments for eligible costs. It says the SBA will hold harmless any lender that relies on such borrower documents and attestation, as required by the CARES Act.

These updates are reflected in the information pages and borrower application posted to Treasury's landing page, including a lender application form.

The update follows letters from ICBA and state banking associations expressing concerns that the interest rate is below break-even for community banks, the two-year loan terms are unreasonably short, guidelines on the use of loan proceeds are excessively restrictive, and the lack of detailed guidance shifts too much liability to the lender.

In a press briefing last night with President Trump, Treasury Secretary Mnuchin said the program will go live today and asked for “patience,” despite the limited guidance.

​In a message to community bankers last night, ICBA President and CEO Rebeca Romero Rainey said ICBA hears their concerns about this new program and its rollout and retains a seat at the table in Washington. "ICBA is with you, will keep you informed of the latest developments, and is working on your behalf just as you are working on behalf of your communities," she wrote.
​UPDATE 04/02/2020 - ICBA President and CEO Rebeca Romero Rainey shared the latest information on the Small Business Administration's hot-button Paycheck Protection Program.

In a message to community bankers after a call with the Treasury Department and SBA, Romero Rainey offered updates on non-SBA lenders, additional forthcoming guidance, tomorrow's expected launch, and the program's interaction with Economic Injury Disaster Loans.
With today's complimentary ICBA webinar on the PPP at capacity, community bankers can pre-order a free recording of the program, which will feature The Coleman Report's Bob Coleman.

Further, ICBA staff will answer questions about the PPP and other aspects of the federal response to the COVID-19 outbreak at its next Community Bank Briefing scheduled for 11 a.m. (Eastern time) tomorrow.

​"ICBA will continue to be at the table in Washington to shape this program, maximize community bank access, and keep you informed of the latest developments," Romero Rainey wrote. "Thank you again for your continued commitment to your communities as we persevere through this challenging time."
UPDATE 04/01/2020 - New information is coming in about the Small Business Administration's hot-button Paycheck Protection Program, and we want you to be the first to know. ICBA just got off the phone with the Treasury Department and SBA, and here's the latest on the $350 billion program:

Non-SBA Lenders: The SBA plans to shortly release a streamlined application form that non-SBA lenders can use to become an approved PPP lender. On Friday, when the program becomes live, these newly approved lenders will have access to a new portal being developed by Amazon Web Services that will allow them to input borrower application information, receive an SBA loan guarantee number, and fund loans under the PPP.

Additional Guidance Imminent: SBA will shortly provide additional guidance in the form of an interim rule that will, among other things, make clear:
  • Exactly what a borrow must attest to.
  • What the banker responsibilities are for verification.
  • Acceptable forms of borrower signatures, e.g. electronic, Docusign, scanned copies, etc.

Friday Launch: SBA expects systems for both currently certified lenders (SBA E-Tran system) and newly certified lenders (through the new portal) to go live on Friday. Banks can collect applications and supporting documentation from borrowers now, to be ready to input into the PPP systems on Friday. Treasury yesterday released initial information and resources on the PPP, including a borrower application form.

EIDL Interaction: Small-business borrowers cannot get both an EIDL (Economic Injury Disaster Loan) and PPP loan at the same time. A borrower can apply for an EIDL loan now and the PPP loan when it becomes available. If a borrower accepts the EIDL loan, and subsequently qualifies for the PPP loan, the borrower can re-finance the EIDL loan into a PPP loan. Loans are limited to one per Taxpayer Identification Number.

ICBA staff will answer questions about the PPP and other aspects of the federal response to the COVID-19 outbreak at its next Community Bank Briefing scheduled for 11 a.m. (Eastern time) this Friday.

ICBA will continue to be at the table in Washington to shape this program, maximize community bank access, and keep you informed of the latest developments. Thank you again for your continued commitment to your communities as we persevere through this challenging time.

UPDATE 04/01/2020 - ICBA launched a new resource page with answers to frequently asked questions about the federal response to the COVID-19 outbreak, including programs authorized by the Coronavirus Aid, Relief, and Economic Security Act.

The new FAQs answer questions related to the Small Business Administration's Paycheck Protection Program, the Federal Home Loan Banks, mortgage lending, loan modifications, Federal Reserve lending support, compliance, and more.

ICBA will continue adding to this resource to provide clarity to community bankers about the COVID-19 response programs. Meanwhile, ICBA offers a brief summary of the key community banking provisions of the CARES Act.

In addition to the SBA program, the CARES Act also includes ICBA-advocated measures related to tax relief, transaction accounts, loan modifications, Current Expected Credit Losses implementation, the Community Bank Leverage Ratio, and more.

​Additional resources on the COVID-19 response are available on ICBA's Crisis Response and Preparedness Toolkit.
UPDATE 03/31/2020 - The Small Business Administration is working to issue guidance as soon as today on its $349 billion in new lending capacity under the Coronavirus Aid, Relief, and Economic Security Act. The new Paycheck Protection Program expands the SBA's 7(a) loan program to help small businesses cover their near-term operating expenses and retain employees.

Meanwhile, ICBA offers a summary of the community banking provisions of the CARES Act and is developing frequently asked questions on the law's key measures, including the SBA program. Further, new analyses from the Economic Innovation Group, Independent Bankers Association of Texas and Senate Small Business Committee offer additional information on the program.

Following relentless ICBA advocacy on behalf of the nation's community banks, President Donald Trump signed the CARES Act into law on Friday. In addition to the SBA program, the law includes tax relief, robust FDIC deposit insurance coverage for transaction accounts, and other ICBA-advocated measures.

UPDATE 03/31/2020 - Just as community bankers are working nonstop to support their local customers and communities amid the coronavirus outbreak, ICBA is working around the clock and committed to getting you the facts and resources you need as soon as possible so you can focus on running your bank.

To that end, we want you to be the first to know that Treasury Department just released initial information and resources with more to follow on the Small Business Administration's $349 billion lending program under the Coronavirus Aid, Relief, and Economic Security Act. The new Paycheck Protection Program expands the SBA's 7(a) loan program to help small businesses cover their near-term operating expenses and retain employees. As more information is available, we will get it to you as quickly as possible.

While speculation and misinformation have been circulating, the resources help provide some answers. Further, ICBA staff will answer questions about the program at its next Community Bank Briefing scheduled for 11 a.m. (Eastern time) this Friday.

ICBA has been at the table from the beginning, in phone calls and meetings with the Congress, White House, Treasury Department, and SBA, to shape this program and ensure community banks can participate in a user-friendly way.

Thanks to relentless advocacy, the CARES Act also includes tax relief; authority for the FDIC to provide full deposit insurance coverage for transaction accounts; troubled debt restructuring, Current Expected Credit Losses, and Community Bank Leverage Ratio relief; and other ICBA-advocated measures.

With much more information to come on these and other programs, ICBA will continue working to ensure you have the facts and the latest resources to help your customers while containing COVID-19's economic damage in your local communities.

The entire ICBA family thanks you for your continued commitment and wishes you safety and health as we work together to persevere through this challenging time.

​ACCESS THE TREASURY RESOURCES HERE
UPDATE 03/30/2020 - Join us Tuesday, March 31, for two webinars on the coronavirus outbreak. Spots are limited and are expected to fill up. Be sure to register ASAP!
  1. ICBA Community Banker University Webinar: Coronavirus in the Workplace Round #2: An Update
    March 31 | 11 a.m. (Eastern)
    The Coronavirus pandemic is not only changing the way we live, it is rapidly changing the way we work. Topics include an overview of the most recent state and federal mandates, leave and disability implications, wage and hour issues, and key considerations with furloughs and reductions-in-force.
    Speakers: Jennifer Nodes, Jackson Lewis; Janet Olawsky, Jackson Lewis
    REGISTER HERE
  2. ICBA Community Bank Briefing: COVID-19 Update With Special Guest OCC
    March 31 | 2 p.m. (Eastern)
    This third briefing focuses on the country’s national banking system and how the OCC is addressing the COVID-19 impact to the U.S. financial system. Discussion includes how the OCC is currently operating, the interagency process, national bank examinations, and bank supervision issues.
    Speakers: Joseph Otting, Comptroller of the Currency; Blake Paulson, OCC, Senior Deputy Comptroller for MidSize and Community Bank Supervision; Rebeca Romero Rainey, ICBA President and CEO (moderator)
    REGISTER HERE

These webinars are free to all ICBA members and include the opportunity to ask questions. Live event registration is limited to 900 participants.

The recordings are available to everyone 24 hours after the live events and can be ordered through our website.

UPDATE 03/30/2020 - Following relentless ICBA advocacy on behalf of the nation's community banks, President Donald Trump signed into law bipartisan economic stimulus legislation responding to the coronavirus outbreak.

The Coronavirus Aid, Relief, and Economic Security Act includes several ICBA-advocated measures that will better enable community banks to provide needed credit in local communities.

Trump signed the bill into law Friday after it passed the House on a voice vote following a unanimous vote in the Senate earlier in the week.
ICBA President and CEO Rebeca Romero Rainey thanked community bankers for being on the front line helping local communities during the coronavirus pandemic. "While you have stood strong for your customers and communities, ICBA has been standing strong in Washington to shape and advance this critical legislation to support you during this uncertain time," she said.

The CARES Act:
  • enhances the Small Business Administration’s 7(a) loan program,
  • provides net-operating-loss tax relief,
  • authorizes robust FDIC deposit insurance coverage for transaction accounts,
  • delays implementation of the Current Expected Credit Losses accounting standard,
  • ensures coronavirus-related loan modifications are not classified by regulators as troubled debt restructurings,
  • reduces the Community Bank Leverage Ratio from 9 percent to 8 percent during the COVID-19 national emergency, and
  • funds USDA Commodity Credit Corporation support for livestock and specialty crop producers.

ICBA offers a summary of key provisions in the law, including mortgage-forbearance measures, and is encouraging regulators to issue guidance as soon as possible to answer questions regarding the details.

​ICBA will continue to provide information to community bankers about the new law as the details come into focus. Additional information and resources about the COVID-19 response are available on ICBA's Crisis Response and Preparedness Center.
UPDATE 03/27/2020 - The ICBA and community banking star shines brightest during a challenge. Today's House passage of the coronavirus stimulus bill with ICBA-advocated provisions—sending it to President Trump to be signed into law—proves that once again to be true.

While you have stood strong for your customers and communities, ICBA has been standing strong in Washington to shape and advance this critical legislation to support you during this uncertain time.

ICBA-advocated provisions in the Coronavirus Aid, Relief, and Economic Security (CARES) Act—which ICBA details in a new bill summary—include:
  • Enhancing the Small Business Administration’s 7(a) loan program,
  • Providing net-operating-loss tax relief,
  • Authorizing robust FDIC deposit insurance coverage for transaction accounts,
  • Delaying implementation of the Current Expected Credit Losses accounting standard,
  • Ensuring coronavirus-related loan modifications are not classified by regulators as troubled debt restructurings,
  • Reducing the Community Bank Leverage Ratio from 9 percent to 8 percent during the COVID-19 national emergency, and
  • Funding USDA Commodity Credit Corporation support for livestock and specialty crop producers.

In our national news release, we thanked policymakers for finalizing these critical measures and resources that support the economy and provide access to credit. Our thanks also go to you for being the guiding light for local communities amid this current challenge.

ICBA will continue to provide additional details and as much information as we can—as soon as we can—on the issues of importance to community banks. Meanwhile, ICBA will continue to keep you informed of the latest updates and resources on COVID-19 via our daily NewsWatch Today email and our Crisis Response and Preparedness Center.

While you are fighting for your customers and communities, know that ICBA will always be there doing the same for you. From our entire ICBA family to you and yours, we thank you for your service to our nation and wish you good health and safety as we persevere through this challenge.

UPDATE 03/27/2020 - ICBA released a summary of the ICBA-advocated provisions in the Senate-passed Coronavirus Aid, Relief, and Economic Security Act, which is expected to pass the House and be signed into law as soon as today.

Following relentless ICBA advocacy, the CARES Act includes several ICBA-advocated measures to help community banks support their communities. The bill would:
  • enhance the Small Business Administration’s 7(a) loan program,
  • advance net-operating-loss tax relief,
  • increase the amount of interest expenses businesses may deduct on their tax returns,
  • ensure robust FDIC deposit insurance coverage,
  • delay implementation of the Current Expected Credit Losses accounting standard,
  • provide temporary relief from troubled-debt-restructuring classifications,
  • reduce the Community Bank Leverage Ratio from 9 percent to 8 percent during the COVID-19 emergency, and
  • support livestock and specialty crop producers.

ICBA is encouraging regulators to issue guidance to answer open questions regarding the details of these provisions and will continue to keep community bankers informed of these developments.

​Additional information and resources about the COVID-19 response are available on ICBA's Crisis Response and Preparedness Center.
UPDATE 03/26/2020 - Following relentless ICBA advocacy, the Senate-passed Coronavirus Aid, Relief, and Economic Security (CARES) Act includes several ICBA-advocated measures to help community banks support their communities.

A new ICBA analysis summarizes the key community banking provisions of the bill, which is expected to pass the House and be signed into law as soon as Friday.

There are many open questions regarding the details of the provisions described below. These questions will not be clarified until the agencies issue guidance, which we are encouraging them to do on an expedited basis. ICBA will continue to provide information to community bankers as the details of the act come into focus.
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READ THE ENTIRE ICBA SUMMARY HERE
UPDATE 03/25/2020 - ICBA this week is hosting another Community Bank Briefing focused on the coronavirus pandemic and the impact on community banks. Scheduled for 11 a.m. (Eastern time) this Friday, the interactive webinar will provide an overview of the federal banking agency response and include time for questions.

A recording of last week’s ICBA briefing and additional resources remain available on the Crisis Response and Preparedness Center. The resource center also features a survey that allows community bankers to share how they are helping their communities amid the coronavirus outbreak to educate policymakers, news media, and the general public.

Community bankers who have questions or need assistance can contact ICBA at crisisresponse@icba.org.

UPDATE 03/25/2020 - ICBA posted a template letter for community bank employees affirming that they are essential workers according to guidance from the Departments of Homeland Security and Treasury.

With community bankers in certain states reporting being stopped by law enforcement as they attempt to go to work, ICBA encourages community bankers to fill out and distribute the template letter to staff to keep with them along with the federal guidance.

The template and guidance are available on ICBA's Crisis Response and Preparedness Center under "Essential Business Management Resources." Community bankers who have questions or need assistance can contact ICBA at crisisresponse@icba.org.
UPDATE 03/24/2020 - ICBA has been working around the clock to ensure critical measures and resources are available to help community banks support the coronavirus response, ICBA President and CEO Rebeca Romero Rainey wrote.

In a message to community bankers, Romero Rainey covered ICBA's many advocacy efforts, including several ICBA-advocated measures in congressional stimulus legislation, regulatory relief on troubled debt restructurings, multiple Federal Reserve facilities, and guidance on "essential critical infrastructure workers."

She also cited ICBA efforts reminding consumers that their deposits are insured, providing community banks with custom resources on its Crisis Response and Preparedness Center, and answering community banker questions submitted to crisisresponse@icba.org.

"While ICBA remains steadfast in representing community banks before policymakers and the public, we are ever grateful of your efforts to support local communities amid this global pandemic," Romero Rainey wrote. "It’s times like this when community banks shine the brightest."
​
READ THE MESSAGE HERE
UPDATE 03/21/2020 - Community Banker University, powered by ICBA is hosting three free webinars pertaining to the ongoing COVID-19 pandemic:

Preparing the Bank for the Economic Downturn
March 25 | 11:00am (Eastern) | REGISTER HERE
Banks have rushed to help their customers manage this extraordinary event. Instead of a short downturn, many are predicting a longer “U” shaped recovery. Unfortunately, many borrowers will not make it through this downturn.

Presenters will reflect on budgeting, asset quality, liquidity, accounting, capital, technology, people, and examination considerations that every bank must keep top-of-mind regardless of whether economic headwinds occur in the short- or long-term.

Coronavirus in the Workplace
March 25 | 3:00pm (Eastern) | REGISTER HERE
Get current, up-to-date information on how to legally manage your workforce while maintaining the health and safety of your workforce, how to avoid legal pitfalls associated with work-from-home arrangements and other common responses to the pandemic, and prepare for what is likely to come.

Topics include an overview of the most recent state and federal mandates, leave and disability implications, wage and hour issues, and key considerations with furloughs and reductions-in-force. There will be time to ask questions.

COVID-19: The Insurance Implications for Banks and Their Customers
March 26 | 11:00am (Eastern) | REGISTER HERE
Businesses around the country are either closing or incurring substantial reductions of business activity due to the COVID-19 virus. Learn possible ways insurance may help with the recovery from such business losses.

Discussion topics include:
  • Business interruption and contingent business interruption insurance coverage.
  • Event cancellation insurance coverage and implications.
  • Shutdown of customer business activities and its effect on banks.
  • Assignment of insurance claims and insurance rights.
UPDATE 03/20/2020 - ICBA is encouraging community bankers to share how they are helping their communities amid the coronavirus outbreak. A new survey on ICBA's Crisis Response and Preparedness Center allows community bankers to tell their stories to educate policymakers, news media, and the general public.

Additionally, during yesterday's Community Banking Briefing webinar, ICBA President and CEO Rebeca Romero Rainey and ICBA staff experts discussed the coronavirus (COVID-19) pandemic, its effect on community banks, and resources for your bank to use.
​
If you were unable to attend, there is a free recording available for viewing.
​UPDATE 03/19/2020 - Unfortunately, due to coronavirus travel and meeting restrictions, ICBA cannot proceed with their usual in-person ICBA Capital Summit event in Washington, originally scheduled for April 27 – May 1, 2020.

Instead of holding the Capital Summit in person, it is ICBA's intent to conduct portions of the meeting program in a virtual format. In the coming days, ICBA will provide information about the schedule for virtual Federal Delegate Board and committee meetings. In addition, they will be considering opportunities for additional virtual programming with policymakers.

If you have already made a hotel reservation within the ICBA room block, they are working to cancel those reservations on your behalf and request a refund of all deposits.

​UPDATE 03/19/2020 - ICBA released three customizable news releases that community banks can distribute in their local communities to reassure consumers amid the coronavirus outbreak. The custom documents spotlight the safety and soundness of the banking system and deposit insurance while showcasing the strength and resiliency of the community banking industry.

ICBA at 3 p.m. (Eastern time) today also is hosting its inaugural Community Bank Briefing, which will feature ICBA staff experts focusing exclusively on the coronavirus outbreak. Space is limited for the complimentary interactive webinar, but it will be recorded and available to ICBA members afterward.

ICBA’s Crisis Response and Preparedness Center offers community banks a variety of information and resources on the COVID-19 outbreak, including a recent “Sprint Exercise” on resiliency plans and an online course on preventing the spread of the virus.
​
Community bankers who have questions or need assistance can contact ICBA at crisisresponse@icba.org.

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