Click on each section title below to be taken directly to that area of our coronavirus resource center:
Coronavirus Resources for Community Bankers and Consumers
The Pennsylvania Association of Community Bankers (PACB) is helping support the banking industry and its consumers navigate the Coronavirus (COVID-19) pandemic by offering information and resources from state and federal regulatory agencies, health organizations, and industry allies. Regulatory agencies have encouraged financial institutions to work with customers impacted by the coronavirus. Customers experiencing difficulties beyond their control should work directly with their financial institutions.
- PA Department of Banking and Securities: Coronavirus Information and Guidance https://www.dobs.pa.gov/Businesses/COVID-19%20Information%20and%20Guidance/Pages/default.aspx
- PA Department of Health: https://www.health.pa.gov/topics/disease/Pages/Coronavirus.aspx
- PA Governor’s Office: https://www.pa.gov/guides/responding-to-covid-19/
- Independent Community Bankers of America (ICBA) Coronavirus Resources: https://www.icba.org/news/Crisis-Preparedness?utm_source=informz&utm_medium=email&utm_campaign=informz&_zs=Iw77W&_zl=uLS12
- OCC Bulletin: Pandemic Planning — Working With Customers Affected by Coronavirus and Regulatory Assistance https://www.occ.gov/news-issuances/bulletins/2020/bulletin-2020-15.html
- FDIC Coronavirus Information for Bankers and Consumers https://www.fdic.gov/coronavirus/index.html
- Federal Reserve: https://www.federalreserve.gov/
- CDC: https://www.cdc.gov/coronavirus/2019-ncov/cases-updates/summary.html?CDC_AA_refVal=https%3A%2F%2Fwww.cdc.gov%2Fcoronavirus%2F2019-ncov%2Fsummary.html
- PACB was invited to join a series of Pennsylvania Bankers Association (PBA) C-suite Coronavirus regional conversations today. Here is a link to understand the various PBA regions: https://www.pabanker.com/member-services/pa-bankers-groups/
- On March 17 federal bank regulatory agencies announced two actions to support the U.S. economy and allow banks to continue lending to households and businesses.
Federal Banking Agencies Provide Banks Additional Flexibility to Support Households and Businesses
Interagency Statement on the Use of Capital and Liquidity Buffers
Federal Register Notice
Federal Banking Agencies Encourage Banks to Use Federal Reserve Discount Window – posted 3/16/2020
PACB RESOURCES & UPDATES
UPDATE 04/03/2020 – “Pennsylvania’s Community Banks Working Hard to Deliver Small-Business Payroll Relief” – PACB Press Release
“Community banks are handling the mission being given to them despite new rules being issued only 12 hours ago.”
UPDATE 04/02/2020 – Treasury.gov posted the SBA’s Interim Final Rule on the PPP.
UPDATE 04/02/2020 – PACB updates education calendar with new program dates, virtual learning, excellent learning opportunities.
PACB has revised our educational calendar in order to provide quality programming and personal connections, when those connections are deemed safe and appropriate. Until then our virtual learning is in full force!
Please know that PACB continues to diligently serve the banking industry in these times and is focused on supporting members and keeping the public and policy-makers informed regarding the strength and soundness of the banking system.
Thank you for all that you are doing to keep the financial system for communities, businesses, neighbors and friends in the Commonwealth stable and strong.
PACB will be here to connect you when the time for connection is here!
UPDATE 04/01/2020 – “Banks remain open, but make adjustments” by Jarrad Hedes, Times News Online
“As a small community bank, we know our customers,” said Craig Zurn, president and chief executive officer of Jim Thorpe Neighborhood Bank. “We have staff personally calling on some of our customers to make sure they are OK and to reassure them that we are still here to take care of their financial needs, questions or concerns. We are all in this together.”
UPDATE 03/30/2020 – Pennsylvania Gov. Wolf today expanded the list of counties where residents ordered to stay home. Additionally, Maryland Governor Larry Hogan declared the state of Maryland to shelter in place. PACB reminds banks with Pennsylvania and Maryland employees to provide their employees with a letter on company letterhead, along with the DHS CISA guidance and the Secretary Mnuchin statement. The Mnuchin Memo is attached. A link to the ICBA sample letter for employees is below.
The Stay at Home order now includes these 26 counties: Allegheny, Beaver, Berks, Bucks, Butler, Carbon, Centre, Chester, Cumberland, Dauphin, Delaware, Erie, Lackawanna, Lancaster, Lehigh, Luzerne, Monroe, Montgomery, Northampton, Philadelphia, Pike, Schuylkill, Washington, Wayne, Westmoreland and York counties. All stay-at-home orders now extend through April 30.
According to U.S. Department of the Treasury and Department of Homeland Security guidance, the financial services sector are identified as a Critical Infrastructure Sector. The guidance from DHS and Treasury identifies essential critical infrastructure workers during the COVID-19 response emergency, and provides guidance to state and local officials as they work to protect their communities. The ICBA prepared a draft letter for bankers to prepare on bank letterhead for their employees. The letters identify the employee’s job description matches the criteria laid forth in the attached guidance, and they should be considered essential workforce, and shall be permitted to perform these critical functions throughout the COVID-19 emergency.
UPDATE 03/30/2020 – PACB Schedules Member Call with ICBA to Discuss 7a Lending/PPP Program in CARES Act.
The ICBA government affairs team will explain the new CARES Act and PPP program with PACB members at 4 p.m. on Wednesday, April 1. If you would like to participate in the discussion, please RSVP to Jena Wolgemuth.
UPDATE 03/26/2020 – PACB President and CEO Kevin Shivers recently appeared on the Lincoln Radio Journal to discuss the community bankers response to the COVID-19 pandemic. The interview linked below on the Lincoln Radio Journal is broadcast on 900 radio stations across Pennsylvania.
UPDATE 03/26/2020 – The US Senate passed the Coronavirus Stimulus bill last night. It now goes on to the House for a vote. It includes the following important provisions related to financial services:
- 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.
Language and specifics remain elusive. ICBA was not able to release a summary yet either. As soon as we have details we will facilitate an all member call with ICBA to review its important provisions.
UPDATE 03/25/2020 – Community bankers from each PACB region provided feedback on what they are doing as a result of the coronavirus pandemic. A summary of comments follows:
- Most bank activity is being done over phone, online or in the bank parking lot, with very limited lobby access.
- Almost every transaction can be handled via the drive thru, phone/email, in the parking lot.
- Some banks reported they require a phone conversation prior to coming in the branch, with the intent to exhaust all possible ways to serve the client without them having to enter the branch.
- Lobby visits now by appointment, limited to safe deposit box, loan closing where information is gathered ahead of time or electronically and interaction is for signature only; Coin and currency (change orders), customers asked to pre order and wait outside; Wire transactions, large currency transactions with business customers (communication with customer in advance regarding process)
- Banks are instructing employees to ask customers if they have traveled in the last 10 days or have been to any of the six PA counties that are shelter in place and whether they have had any illnesses or symptoms of illnesses or have been exposed to someone who has. Banks reserve the right to restrict access to anyone they don’t feel comfortable allowing in to the offices.
- Opening accounts by obtaining information over the phone, preparing papers and running them out to the parking lot, or via drive-thru, where the customer is waiting in their car.
- Banks are rotating front-line staff, 2-3 days on and then 2-3 days off, while instructing staff aged 70+ to stay at home, with pay, while most back-office staff is able to work remotely.
What is the proper course of action to take if/when an employee tests positive?
From the CDC: If an employee is confirmed to have COVID-19 infection, employers should inform fellow employees of their possible exposure to COVID-19 in the workplace but maintain confidentiality as required by the Americans with Disabilities Act (ADA). The fellow employees should then self-monitor for symptoms (i.e., fever, cough, or shortness of breath): https://www.cdc.gov/coronavirus/2019-ncov/downloads/sick-with-2019-nCoV-fact-sheet.pdf
What is the proper protocol for cleaning/sanitizing an office? What products are effective?
Please see the guidance from the CDC: https://www.cdc.gov/coronavirus/2019-ncov/community/organizations/cleaning-disinfection.html
How do banks prepare for COVID-19?
UPDATE 03/24/2020 – Tune in to the Pennsylvania Cable Network (PCN) at 12:10 p.m. on Wed. March 25, to hear PACB President and CEO Kevin Shivers discuss the response by community bankers to the Coronavirus pandemic.
Missed the broadcast? VISIT PCNTV.COM/CORONAVIRUS/, scroll down to the FREE TO WATCH – Coronavirus Impact section & select Coronavirus Impact 03/25/20
UPDATE 03/22/2020 – “Pennsylvania’s Banks Committed to Providing Essential Services to Consumers and Businesses During COVID-19 Health Emergency” – A joint industry news release
“Access to financial institutions is essential for consumers, businesses and working families to quickly utilize the checks that the federal government seeks to provide as soon as possible and, if necessary, access, manage, and utilize any other assets they may have, such as retirement, securities and trust accounts.”
UPDATE 03/20/2020 – “Community banks are showing their strength amid COVID-19 crisis” op-ed by Kevin Shivers, Central Penn Business Journal
“The top priority of our Pennsylvania Association of Community Bankers (PACB) family is to protect the health and well-being of our employees, our customers, and every Pennsylvanian. To that end, our members have taken significant safety measures, such as expanded drive-thru banking hours and lanes and assigned tellers to meet the increased demand. In addition to their responsibility to keep customers and employees safe, community banks also are making special arrangements with customers who still depend on personalized banking services.”
UPDATE 03/20/2020 – As community bankers across Pennsylvania navigate choppy waters, the PACB would like to convene a peer discussion for bankers. This is a forum for our members to gather and learn how each is dealing with the access, HR and other issues everyone is currently experiencing. Additionally, PACB wants to serve as a clearinghouse for useful resources so everyone can pull through this pandemic and the economic fallout.
On Monday, March 23rd at 4:00 pm, PACB will host a conference call/video for all of its members to work through the current situation, as well as post questions that our associate members can provide answers/insight to. PACB is here to be a resource for you at this time and we feel the ability to speak to your peers and ask questions will prove to be a benefit to you.
In order to participate in this 45 minute conference, please email email@example.com and you will receive connection details.
We will remind everyone that the PACB anti-trust policy will be complied with during these calls.
UPDATE 03/19/2020 – Federal banking regulators are looking to offer banks additional regulatory points for lending to mid- to low-income consumers who have been impacted by the coronavirus pandemic, Reuters reports, citing an official within a banking agency. One of the plans being discussed is to offer regulatory credits to lenders through the Community Reinvestment Act. Additionally, regulators are also considering pushing banks to show customers leniency in the repayment of automobile and home loans.
After taking emergency actions over the past week, the U.S. Federal Reserve could take additional measures to ease liquidity strains facing the financial system and the U.S. economy more broadly. Potential options for the Fed involve steps that either require congressional approval or that the central bank can undertake already. They include technical measures like increasing its interventions into short-term funding markets as well as broadening the range of parties the Fed can loan to, like small business and municipal bond issuers.
UPDATE 03/16/2020 – PACB staff will be working remotely, effective immediately, in response to the coronavirus (COVID-19) pandemic. We hope to be back in the office some time during the week of March 30, but we will be guided by the recommendations of the the Governor, PA Department of Health, and other relevant public health officials in making that decision.
Despite the fact that we are taking this extraordinary step, our staff is committed to carrying out ongoing responsibilities. We will be readily accessible by email or by leaving a voicemail on our office phone system. Although we will not be physically present in the PACB office, we are committed to being readily available to our members and allies.
ICBA RESOURCES & UPDATES
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.
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.
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!
- 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
- 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)
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.
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 firstname.lastname@example.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 email@example.com.
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 firstname.lastname@example.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.”
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 email@example.com.
LEGISLATIVE RESOURCES & UPDATES
Federal & State Financial Regulators Issue Guidance/Info on COVID-19
Interagency Statement on Pandemic Planning
PURPOSE: The Federal Financial Institutions Examination Council (FFIEC) on behalf of its member agencies1 are issuing guidance to remind financial institutions that business continuity plans should address the threat of a pandemic outbreak and its potential impact on the delivery of critical financial services. Click here to read the FFIEC Guidance.
Joint Press Release: Board of Governors, Federal Reserve System; CFPB; FDIC; OCC; NCUA; CSBS: Agencies Encourage Financial Institutions to Meet Financial Needs of Customers and Members Affected by Coronavirus
Federal financial institution regulators and state regulators today encouraged financial institutions to meet the financial needs of customers and members affected by the coronavirus. The agencies recognize the potential impact of the coronavirus on the customers, members, and operations of many financial institutions and will provide appropriate regulatory assistance to affected institutions subject to their supervision. Click here to read the Joint Press Release.
State Legislature Changes Due to COVID-19
UPDATE 03/20/2020 – Gov. Tom Wolf’s order closing businesses that are not considered life-sustaining was updated Saturday, March 20. A list of both life-sustaining and non-life-sustaining businesses is here. Business guidance has been updated after conversations with PACB and other financial- and businesses-stakeholders, and has been aligned with the Cybersecurity and Infrastructure Security Agency advisory released yesterday.
In response to COVID-19. Governor Wolf closed the Pennsylvania State Capitol to anyone but employees effective last Friday, March 13th. The state legislature was previously scheduled to return to session on March 16th.
The House met for Session on Monday, March 16th to pass a series of internal rules changes that will allow the 203-member chamber to continue to conduct its business remotely during the course of the outbreak.
The Senate cancelled their Monday and Tuesday Session, but met briefly on Wednesday to pass a resolution regarding temporary emergency rules, to allow the Senate to pass legislation remotely.
The House and Senate will operate under a “12-hour call time,” meaning members should be prepared to vote remotely if called upon.
These rules will be in effect until Governor Wolf ends the coronavirus disaster declaration.
House and Senate Republican and Democrat Legislators are committed to helping Governor Wolf’s efforts to combat the coronavirus.
PA Department of Banking & Securities COVID-19 Resources
UPDATE 03/20/2020 – The Pennsylvania Department of Banking and Securities has provided a process by which individual banks may seek waivers to exclude from the governor’s prohibition certain banking operations, such as the operation of trust departments, legal services, real estate and title services, etc.
Should your institution seek a waiver to continue certain financial operations, or are seeking information about the process, you can submit your request via RAfirstname.lastname@example.org
The Department of Community and Economic Development (DCED) will email back with information about the process.
Please copy or notify the Department of Banking and Securities on your waiver application so they can track your application and possibly intervene in support. These waiver requests will be given high priority.
General information for businesses seeking information about whether they are covered under yesterday’s order, please email: email@example.com
The Department of Banking and Securities has provided resources about COVID-19 https://www.dobs.pa.gov/Pages/default.aspx
From the DOBS website: “The Department of Banking and Securities has received a number of questions about whether banks and other financial institutions are subject to Governor Wolf’s order that non-life-sustaining businesses in Pennsylvania close their physical locations in order to mitigate the spread of the COVID-19.
Please be aware that banks, credit unions, and non-depository licensees are NOT required to shutdown their physical locations. Credit intermediation and related activities also do not require physical closure. Banks, credit unions, and non-depository licensees are encouraged to remain open and operational and to follow best practices for social distancing.“
Federal Regulator COVID-19 Response
Federal Banking Agencies Provide Banks Additional Flexibility to Support Households and Businesses
The federal bank regulatory agencies today announced two actions to support the U.S. economy and allow banks to continue lending to households and businesses. They are:
- A statement encouraging banks to use their resources to support households and businesses; and
- A technical change to phase in, as intended, the automatic distribution restrictions gradually if a firm’s capital levels decline.
Read the press release here.
UPDATE 03/20/2020 – FDIC has issued FAQ’s for Financial Institutions related to COVID-19. If includes issues like TDR’s, deferments, delinquencies, & more, etc.
Please see the following link: https://www.fdic.gov/coronavirus/faq-fi.pdf
Here is the link to FDIC’s notice: https://www.fdic.gov/news/news/financial/2020/fil20018.html
Read all Responses to COVID-19 from FDIC here
FDIC Issued a Financial Institution Letter on Working with Customers Affected by the COVID-19
- The FDIC encourages financial institutions to work with customers and communities affected by COVID-19 in a prudent manner.
- The FDIC understands that this unique and evolving situation could pose significant temporary business disruptions and challenges.
- The FDIC encourages financial institutions to work with all borrowers, especially borrowers from industry sectors particularly vulnerable to the volatility in the current economic environment and small businesses and independent contractors that are reliant on affected industries.
- A financial institution’s prudent efforts to modify the terms on existing loans for affected customers will not be subject to examiner criticism.
- The FDIC will work with affected financial institutions to reduce burden when scheduling examinations, including making greater use of off-site reviews, consistent with applicable legal and regulatory requirements.
- The FDIC’s staff stands ready to work with financial institutions that may experience challenges fulfilling their regulatory reporting responsibilities and will act expeditiously if institutions need to temporarily close facilities.
- The FDIC has launched a COVID-19 webpage on its public website to provide useful information to bankers, consumers, and others. Financial institutions that have questions about guidance in the statement are encouraged to contact their FDIC Regional Office
Read the FDIC FIL here.
Read all Responses on COVID-19 from OCC here
UPDATE 03/22/2020 – The Office of the Comptroller of the Currency (OCC) today announced an interim final rule to revise its short-term investment fund (STIF) rule for national banks acting in a fiduciary capacity. The rule allows the OCC to authorize banks to temporarily extend maturity limits of these funds. The financial markets are in a period of significant stress negatively affecting the ability of banks to operate in compliance with maturity limits identified in the rule. The rule is effective immediately. The agency will accept comments for 45 days following publication in the Federal Register.
Simultaneously to announcing the interim final rule, the OCC also announced an order extending the maturity limits for STIFs affected by the market effects of COVID-19. The order provides that a bank will be deemed in compliance with the rule if:
- The STIF maintains a dollar-weighted average portfolio maturity of 120 days or less, as determined in the same manner as is required by the Securities and Exchange Commission SEC) pursuant to Rule 2a-7 for money market mutual funds (17 CFR 270.2a-7);
- The STIF maintains a dollar-weighted average portfolio life maturity of 180 days or less, as determined in the same manner as is required by the SEC pursuant to Rule 2a-7 for money market mutual funds (17 CFR 270.2a-7).;
- The bank is acting in the best interests of the STIF under applicable law in connection with using these temporary limits; and
- The bank makes any necessary amendments to the written plan for the STIF to reflect these temporary changes.
The OCC also determined that the relief provided by this administrative order terminates on July 20, 2020, unless the OCC revises this order to provide otherwise before that date.
The best compendium of issuances around COVID-19 related information is https://occ.gov/covid-19.
Pandemic Planning: Working With Customers Affected by Coronavirus and Regulatory Assistance
The Office of the Comptroller of the Currency (OCC) recognizes the potential for the Coronavirus Disease 2019 (also referred to as COVID-19) to adversely affect the customers and operations of banks.1 The OCC encourages banks to take steps to meet the financial services needs of customers adversely affected by COVID-19-related issues. The OCC will provide appropriate regulatory assistance, as warranted, to banks affected by COVID-19-related issues.
Read more from OCC here.
Read all responses to COVID-19 from the Federal Reserve here.
UPDATE 03/22/2020 – The federal financial institution regulatory agencies and the state banking regulators issued an interagency statement encouraging financial institutions to work constructively with borrowers affected by COVID-19 and providing additional information regarding loan modifications.
The agencies encourage financial institutions to work with borrowers, will not criticize institutions for doing so in a safe and sound manner, and will not direct supervised institutions to automatically categorize loan modifications as troubled debt restructurings (TDRs). The joint statement also provides supervisory views on past-due and nonaccrual regulatory reporting of loan modification programs.
UPDATE 03/21/2020 – US Department of Homeland Security – Cybersecurity and Infrastructure Security Agency (CISA) Federal Guidance on Critical Infrastructure Workforce
Read the memorandum and Guidance here
The federal bank regulatory agencies released a statement encouraging banks to use the Federal Reserve’s “discount window” so that they can continue supporting households and businesses.
The discount window provides short-term loans to banks and plays an important role in supporting the liquidity and stability of the banking system. By providing ready access to funding, the discount window helps depository institutions manage their liquidity risks efficiently and avoid actions that have negative consequences for their customers. Thus, the discount window supports the smooth flow of credit to households and businesses.
US Department of the Treasury
UPDATE 04/02/2020 – US Treasury Guidance on SBA Paycheck Protection Program (PPP): https://home.treasury.gov/cares
ASSISTANCE FOR SMALL BUSINESSES
The Paycheck Protection Program prioritizes millions of Americans employed by small businesses by authorizing up to $349 billion toward job retention and certain other expenses.
Small businesses and eligible nonprofit organizations, Veterans organizations, and Tribal businesses described in the Small Business Act, as well as individuals who are self-employed or are independent contractors, are eligible if they also meet program size standards.
- For a top-line overview of the program CLICK HERE
- If you’re a lender, more information can be found HERE
- If you’re a borrower, more information can be found HERE
- The application for borrowers can be found HERE
Secretary Steve Mnuchin Memorandum on Financial Services Sector Essential Critical Infrastructure Workers: CLICK HERE.
ASSOCIATE MEMBER RESOURCES & UPDATES
From Accume Partners
Join us on April 2nd at 12:00pm EST for a round table to discuss approaches to staying secure in a work from home environment.
Some topics we’ll discuss are:
- The Ground Floor – Baseline standards for user or company-issued computers
- Mind the Gap – All of the risks involved with connecting a remote system to your corporate data
- Pitfalls – Common (and uncommon) security misconfigurations that may expose your network.
Email firstname.lastname@example.org to register and to ask specific questions you’d like answered.
Your moderator for this Round Table is Robert Gaines, CISSP, CSFA and Director of Technology Risk, IT Audit and Cybersecurity (TRAC) at Accume Partners.
We are living in unprecedented times. With new information being released by the minute, Accume Partners wants to provide you with a comprehensive resource guide for relevant news. This guide is intended to keep you informed. The information and services provided by Accume are provided for general consultation purposes only and are not intended to constitute, and should not be construed as, legal advice on any subject matter. Accume will not perform any management functions, make any financial decisions, or act in a capacity equivalent to that of a member of management or an employee; Bank management must decide its course of action and is responsible for those decisions.
From Baker Tilly
The coronavirus (COVID-19) outbreak is affecting both individuals who get sick as well as organizations and industries worldwide. During this uncertain time, Baker Tilly is ready to help you with practical advice on informing and supporting your employees as well as keeping your business running.
Visit the Baker Tilly CORONAVIRUS PREPAREDNESS RESOURCE CENTER for a number of resources for community banks and small businesses.
From BKD LLP
BKD has created a COVID-19 Resource Center to help disseminate important information for our clients and friends as we evaluate ways to mitigate the inevitable financial effects. We’ll keep you up to date with relevant news, changing guidelines, new regulations and anything else we believe you need to know.
As part of our ongoing efforts to provide up-to-date guidance on the rapidly evolving COVID-19 pandemic, BKD is launching weekly webcasts every Thursday at 3pm eastern time, covering topics many businesses and individuals have been asking us. Visit BKD’s COVID-19 Resource Center for more information.
From Boenning & Scattergood
Please join us for an update call on COVID-19 and its impacts on the economy and markets this Monday, March 30 at 11AM EDT.
During this call, you’ll hear from Michael Mara, President of Boenning & Scattergood, Inc., and Craig Columbus, CEO of Columbus Macro, LLC, as they discuss the many impacts COVID-19 is having on the global economy and markets.
Mr. Mara is a financial industry veteran and accomplished senior executive with over 30 years of experience in the Brokerage, Wealth, Investment Management, Capital Markets, and Private Banking business. In addition, some of the funds for which Michael served as portfolio manager earned him numerous citations in The Wall Street Journal as “Category King” and a 5-star status from Morningstar.
Mr. Columbus, one of Wall Street’s most respected strategists and “big picture” thinkers, oversees investment decision-making and sets the strategic direction for Columbus Macro, LLC, a globally-focused boutique investment management firm headquartered outside of Pittsburgh. He is a popular speaker, known for identifying key macro trends and distilling complex analysis in an accessible manner. Craig frequently shares his insights across a variety of prominent media platforms. He became a recognizable figure on financial television during his tenure as market strategist for Primark Corp. and Thomson Financial.
Meeting Number (Access Code): 479 009 112
Meeting Password: 1914
COVID-19 and its Impacts on the Economy and Markets
Monday, March 30, 2020
From Burns White
As Burns White addresses the concerns raised by the pandemic, our office locations remain closed, but rest assured, your needs remain our top priority. Our team has mobilized—working remotely to continue to provide timely, high-quality legal counsel. Attorneys in all areas of the law are monitoring this dynamic situation closely to offer guidance on the frequent regulatory mandates and legal updates that may affect you and your business. If you are looking for information, COVID-19 updates are available on our homepage, and I encourage you to visit the page regularly to learn more about important legal changes. Please do not hesitate to contact us about any specific questions, concerns, or matters you may have.
As always, the people at Burns White are here to help you in any way we can. Together, we will weather this storm.
From Bybel Rutledge LLP
In a traditional in-person shareholder meeting, the board, management, and shareholders gather in a pre-determined location to conduct corporate business. A virtual meeting allows shareholders and company representatives to gather using virtual shareholder meeting services. No in-person attendance is available, but all the opportunities afforded to shareholder at a physical meeting are accessible virtually. A hybrid meeting involves a mixture of the traditional physical meeting and the new virtual meeting: shareholders and company representatives have the opportunity to attend either a physical meeting or a virtual one. A company must choose a virtual or hybrid meeting format that meets the respective exchange requirements, allows shareholders to exercise all the rights granted under the state of incorporation, and meets the requirements set forth by the company’s articles and bylaws. Bybel Rutledge LLP has released the following legal alert: Virtual and Hybrid Shareholder Meetings In Extraordinary Times.
From Community Bankers Webinar Network
WEBINAR • MONDAY, MARCH 30, 2020 • 3:00PM
The Families First Coronavirus Response Act is effective on April 1. Are you ready? Do you know the requirements? Learn what you need to know about complying with this latest consequence of the U.S. COVID-19 epidemic.
LEARN WHAT YOU NEED TO KNOW ABOUT:
- Covered entities
- Potential small employer exemption
- Breakdown of the new leave rules and benefit calculations
- Coordination with existing leave regulations
- Rules upon an employee’s return to work
- Employer financial relief
- Penalties for noncompliance
In addition to the changes to business strategies, operations, loan servicing guidelines, staffing models, and service delivery methods, you must also prepare for big changes in employee leave practices! On March 18, 2020, President Trump signed into law H.R. 6201, known as the Families First Coronavirus Response Act (the Act), in response to the COVID-19 crisis. It provides for employer-paid leave to employees from April 1, 2020, through the end of the year. The Act creates two distinct types of employee leave rights: emergency paid sick leave and public health emergency leave. You must understand the coverage details and eligibility requirements of both. The coverage afforded to employees could include up to 12 weeks of paid leave – in addition to any required paid sick, family, or medical leave under your state law.
The world is moving incredibly fast, and you need to stay ahead of the employment law compliance curve. Join us to learn the requirements for emergency paid sick leave and new family and medical leave provisions of the Act.
WHO SHOULD ATTEND?
This informative session is designed for senior executives, managers, supervisors, compliance staff, human resources personnel, and anyone involved with finance, payroll, or leave policies.
WEBINAR • THURSDAY, APRIL 9, 2020 • 3:00PM
Are your borrowers struggling? A recent interagency statement provides guidance for working with borrowers experiencing loan shortfalls due to the impact of COVID-19 – but outside the normal TDR structure. Learn the details and next steps.
AFTER THIS WEBINAR YOU’LL BE ABLE TO:
- Define a troubled debt restructuring (TDR)
- Understand when a loan modification related to COVID-19 is exempt from TDR reporting
- Identify when a coronavirus-related payment deferral does not need to be reported as past due
- Evaluate the best way to work with an affected borrower
- Determine the immediate proactive steps your financial institution should take
On March 22, 2020, federal and state regulators issued the Interagency Statement on Loan Modifications and Reporting for Financial Institutions Working with Customers Affected by the Coronavirus. This statement provides guidance about how to work with borrowers (both consumer and commercial) who are unable to meet their loan payment obligations due to the coronavirus situation. If handled correctly, loan modifications to assist borrowers who were current prior to the pandemic will not be characterized as a TDR, and payment deferrals will not be required to be reported as past due. With this webinar, you’ll learn to properly handle consumer and commercial loan modifications and payment deferrals in accordance with the Interagency Statement and how to document compliance. Discover the proactive steps that can assist your institution immediately.
WHO SHOULD ATTEND?
This informative session is designed for consumer and commercial loan personnel, including loan officers, loan operations staff, workout and special asset personnel, collectors, attorneys, auditors, compliance officers, and managers.
From Innovative Financing Solutions
Significant Relief for Small Businesses Affected by COVID-19 is Available
The Payroll Protection Program, part of the recently passed Coronavirus Aid, Relief, and Economic Security (CARES) Act, provides the Small Business Administration (SBA) with nearly $350 billion for American small businesses impacted by the Coronavirus.
While the program has been passed into law, the SBA has yet to finalize its approval, closing and funding procedures as well as documentation requirements and forms.
While these requirements can and likely will be adjusted to some extent when SBA regulatory guidance is issued, Borrower applicants can prepare to make a formal loan application by following the steps below:
- Register to ensure you are notified to make a formal application with one of our Lending Partners as soon as the program becomes available. You will also be invited to an optional webinar with additional information.
- Review the Payroll Protection Program Summary Guidelines
- Calculate your estimated loan amount utilizing our Paycheck Protection Calculator.
- Assemble required documentation to prepare for an application.
The Senate has officially passed the CARES Act which includes significant relief to small businesses with a generous array of SBA program changes known as the Paycheck Protection Program. The House is expected to vote today or tomorrow and the President is ready to sign into law immediately. We’re optimistic SBA will quickly implement policies to facilitate application processing and we are working tirelessly to prepare for accepting applications by our Lender and Small Business Clients. The following is a high level summary of key details, however; the Small Business Investor Alliance provided an excellent detailed summary and a link to the actual bill.
As mentioned in our previous correspondence, be careful to weigh the benefits of the Paycheck Protection Program which will be administered by the SBA under the 7(a) Loan Guaranty Program versus the SBA Economic Injury Disaster Loan Program as Borrowers can only accept one.
During events such as the COVID-19, or Coronavirus, pandemic, there is often an increase of criminal activity online. Preying on fear and panic, cyber criminals are now sending various scams related to COVID-19 and taking advantage of increasing vulnerabilities resulting from unusual working situations. It is critical that you and your institution’s employees exercise caution during this time.
PACB members are invited to CSI’s Crisis Management Roundtable Webinar. During this webinar CSI Subject Matter experts from every division will be providing guidance and answering questions related to the COVID-19 Crisis. This webinar is free to all participants. More information including the registration link is below.
When: Thursday April 2nd at 3pm Eastern
COVID-19 Crisis Management Roundtable
Is your organization addressing all the challenges presented by the Coronavirus (COVID-19) pandemic? Join CSI for a virtual crisis management roundtable during which a panel of CSI experts will provide guidance and answer your questions on best practices related to COVID-19 and your business, including:
- Fraud and Financial Crime Threats During the Crisis
- Connecting Digitally with Financial Institution Customers
- Cybersecurity and Securing Remote Workforces
- Business Continuity and Strategic Planning
Email your questions now to COVIDquestions@csiweb.com or submit them live during the roundtable.
Speakers: Keith Monson, Chief Risk Officer, CSI; Shane Ferrell, Vice President of Digital Strategy, CSI; Sean Martin, Product Manager, CSI; Beckie LaPorte, Director, Global Risk and Compliance, CSI Regulatory Compliance
As you continue efforts to meet the needs your customers during these challenging conditions, your focus may turn to loan payment options—specifically, the ability to accept debit card payments.
Fitech, a preferred provider of the PACB Services, Inc, can give your institution the ability to process these payments over the phone and via your website—and they can have you fully functioning in as fast as one day.
This virtual banking solution benefits provides your bank with the ability to:
- Securely accept payments over the phone or via your website
- Establish recurring payments
- Lower costs of collection/collecting payments
- Get customized, online reporting
Fitech is the leading merchant services provider committed to helping community banks be competitive and relevant in today’s market. For more than a decade, they have been investing in payment technology to meet the evolving needs of customers, and they have a proven track record of superior customer service that complements their innovative solutions. Contact Matt Mingenback, Vice President of Sales at Fitech, today at email@example.com or 316-518-8850.
From ICBA Securities
Vining Sparks, ICBA Securities’ exclusive broker, can assist your community bank in producing very attractive fixed rate funding strategies. Below is a very recent “playbook” that explains the strategy and the hedge accounting. For more information, you can contact your Vining Sparks account rep, or Jim Reber, ICBA Securities President, at 800-422-6442 or firstname.lastname@example.org.
From The Kafafian Group
Performance Measurement is a proprietary and true software as a service (SaaS) profitability measurement solution of The Kafafian Group (TKG), a community financial institution consulting firm that is an affiliate member of PACB. It provides line of business, branch, and product profitability reporting to financial institutions on an outsourced basis. Performance Measurement also feeds customer profitability into an institution’s CRM or MCIF solutions. The service is an outsourced service, meaning that costing, transfer pricing, and processing is done by TKG on a tailored institution by institution basis. TKG is waiving set-up fees through June 30. This savings depends on institution size, but for a $1 billion institution, savings would be $20,000. For institutions with less than $500 million in assets, TKG is waiving set-up fees for the Performance Insight SaaS product that helps banks make smarter, more confident decisions that drive profitability.
For more information, please contact Gregg Wagner at email@example.com or 973-299-0300 x114
The Kafafian Group (TKG) is dedicated to helping financial institutions build strategies and perform better for a successful, long-term future. To add value to our relationship during these unprecedented times, our team is developing short, five minute videos on very specific topics for you and your colleagues to use, share, and keep everyone focused during this unusual time so you emerge stronger than ever.
Is there a specific subject you would like us to cover in a future Banking Short? Please e-mail firstname.lastname@example.org and let us know. If we are not subject matter experts on a topic, perhaps we can marshal other industry experts to deliver valuable insights to you.
TKG is here for whatever you may need. Enjoy, be safe, and be healthy.
From Kilpatrick Townsend
Kilpatrick Townsend’s COVID-19 Task Force is closely monitoring developments with regard to the Coronavirus (COVID-19) as well as the recommendations of federal, state, and local authorities. We will continue to make information regarding specific known legal issues available here, on our YouTube channel, and via updates to our clients who regularly receive legal alerts and related information. If you are interested in discussing an area of specific concern, we recommend that you reach out to your primary Kilpatrick Townsend point of contact. General questions may be submitted via email to: #COVID-19KTSTaskForce@kilpatricktownsend.com.
From Locke Lord LLP
The safety and well-being of our clients, personnel and families are paramount, and we continue to monitor the overall impact of the COVID-19 coronavirus (COVID-19) outbreak closely. Our preparedness plans have been evaluated and activated to ensure we continue serving our clients with little to no disruption during these unprecedented times.
We’ve also mobilized across disciplines to create a COVID-19 Task Force that provides a coordinated response to our clients’ range of needs. This includes an FAQ section covering a host of issues, as well as links to recent QuickStudies.
We encourage you to regularly visit OUR COVID-19 CORONAVIRUS RESOURCE CENTER for the most up-to-date information. You will also find access to key contacts at Locke Lord who can put you in touch with appropriate team members.
From Luse Gorman
On March 27, 2020, the President signed the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) into law. It provides over $2 trillion to combat the coronavirus (COVID-19) and stimulate the economy. The CARES Act also contains provisions that can assist financial institutions in preserving capital and easing operations. Our Alert, which summarizes these provisions, is available here.
Due to the increasing restrictions placed by federal, state and local governments on the size of in- person gatherings and public movement to reduce the health risks associated with COVID-19, many companies are evaluating whether to change their upcoming annual shareholder meetings, which are traditionally held-in person, to either a meeting held exclusively online (a “virtual meeting”) or a meeting held at a physical location that would allow shareholder or member participation via the Internet or other forms of remote communication (a “hybrid meeting”). For companies contemplating holding a virtual or hybrid annual meeting, Luse Gorman has released the following legal update: Virtual Annual Meetings in Response to COVID-19.
Additionally, in light of the impact of the coronavirus (COVID-19) pandemic on public reporting companies, on March 25, 2020, the Securities and Exchange Commission issued an order allowing public companies, subject to certain conditions, a 45-day extension to file certain periodic reports that would otherwise have been due between March 1 and July 1, 2020. On the same date, the SEC’s Division of Corporation Finance issued guidance regarding its views on disclosure and other securities law obligations that companies should consider with respect to the impact of COVID-19.
Our Alert, which summarizes the steps required for companies to avail themselves of the delayed filing deadline and the SEC’s guidance on disclosure related to the COVID-19 pandemic and related business and market disruptions, is available here.
From Mosteller & Associates
Make sure you are in compliance with the latest COVID-19 requirements concerning employee postings. The Department of Labor (DOL) has released a required employment poster “Employee Rights – Paid Sick Leave and Expanded Family and Medical Leave Under the Families First Coronavirus Response Act.”
This applies to employers with fewer than 500 employeesPlease download, print, and post immediately in the same location(s) as your other required employee postings. It is also recommended to share this information electronically with your employees currently teleworking. Click here to download the Employee Rights Poster
Please contact us with any questions:(610) 779-3870 or Scott Smith at Scott@mostellerhr.com
Remember Your Employee’s Health is Vital to Your OrganizationPractice Social Distancing
Mosteller & Associates is closely following the ever-changing issues under the COVID-19 pandemic relative to organizations and their employees. We are in unchartered territory and are committed to supporting the business community and the employees of our friends and clients. How we lead, manage, and treat people (our most valuable asset) through turbulent times will serve to define who the organization is perceived to be by employees, when the crisis subsides.
Mosteller & Associates is combing government and health agency websites and newsfeeds daily and updating the guide below. As we see significant changes, we will provide a “What’s New” follow-up document. Included in the following guide are items such as an Employer Checklist, suggestions on handling employee issues concerning their health and the ability to work, plus the day-to-day changing regulatory environment with the just passed federal legislation as well as actions we are seeing from area employers. If you need more detailed guidance assistance with developing the right approach, please contact us directly at 610-779-3870.
COVID-19 is having a dramatic effect on our lives, our businesses, and our economy. Many financial institutions are asking the same questions: What will this mean for the economy as a whole? What will this mean for our main funding source of deposits? How will credit risk affect our existing loan portfolio in the short and long term, and what inadvertent effects will this have on my institution? Here at nCino, we take the success of our customers and prospective customers very seriously, and will thus be holding a series of webinars in the coming weeks to address these questions.
nCino in offering a webinar addressing the effects the current economic climate will have on deposits. We will show how an institution can use their current data for analyzing maturity dates, monitoring concentrations, predicting deposit volume behavior, and modeling cash flows.
Before making rash decisions, join us to better understand how your data can forecast fluctuations, as well as show the changes you can make to mitigate your risk and keep your main funding source in a healthy position.
Attendees can register for this free, CPE-approved educational webinar here. It will be held on Thursday, March 26th at 3 PM eastern.
This is a volatile time, but we can get through this together! Please allow us to help you with a few key techniques that can help stabilize the stress currently hitting the market.
Ncontracts will be offering a COMPLIMENTARY “Managing Coronavirus Operational Risk Department-by-Department: What You Need to Do Today” webinar on Tuesday, March 24th at 1 pm EST time. This call will focus on the departments within the community bank most affected by the disruption created by COVID-19. As they are very involved in BCP, this is timely and appropriate.
As the coronavirus spreads across the globe, bankers must assess the risks of the pandemic and what it could mean for their institutions. From sick staff and IT systems to fluctuating financial markets and the need to maintain critical functions, banks need to consider how COVID-19 will impact each major department and business line.
During this webinar, experts will discuss how to assess the operational risks coronavirus poses to your institution. From risk management to mitigation controls, the webinar will cover:
- A department-by-department breakdown of risks to evaluate, including HR, IT, finance, and the front line
- Forecasting changes in banking behavior and customer needs
- What regulators have to say about pandemic preparation and testing
- Determining if your existing BCP plan is adequate
- How to conduct a pandemic risk assessment
Q&A will follow the expert presentations.
Click here for the complimentary registration for this important webinar.
From OnCourse Learning
As the number of global cases of COVID-19 nears 100,000, and the number of US infections rises, it’s time for financial institutions to dust off their Pandemic Preparedness Plans and revisit our plans for operating with a reduced staff. Pandemic Preparedness, which falls under the umbrella of Business Continuity Management, was all but removed from the updated FFIEC Business Continuity Management booklet in November of 2019, but we’ve quickly remembered that doesn’t mean that the threat of a global pandemic isn’t real.
OnCourse Learning is offering an OnDemand Recorded seminar covering the current state of the COVID-19 – the Wuhan Coronavirus – and what financial institutions need to do from a Pandemic Preparedness and Business Continuity Perspective.
From RKL LLP
RKL LLP has created a resource center to help employers cut through the deluge of information and identify what your organization needs to do in both the short and long-term. You’ll find our latest updates, action items and webinar recordings. And we want to hear from you. Please use the form found on their website to submit your questions, needs and challenges. This feedback will help inform future webinars and the guidance we’re working hard to deliver during this critical time.
Please visit RKL LLP’s CORONAVIRUS EMPLOYER RESOURCE CENTER for more information.
From S&P Global
Coronavirus: The Global Impact
Subscribe to our coronavirus newsletter today. Stay up to date with the latest news and insight from S&P Global Market Intelligence, on public health, the global economy, its sectors, and commodity markets. This newsletter will be sent every Thursday.
From S.R. Snodgrass, P.C.
At S.R. Snodgrass, we’ve been working diligently to keep our community bank clients informed during this uncertain time. We’ve added new resources to our website, which are available for download, including a white paper on loan modifications and other guidance related to COVID-19. Please click here if you would like to receive our future resources via email. We encourage you to reach out to us by phone or email with questions or concerns that you have.
From Sterling Compliance LLC
As you are all working in good faith with your borrowers who are seeking payment relief during this unprecedented, difficult time, there are many uncertainties about various aspects of the accommodations being made. We wanted to assist with a couple of compliance and other considerations you want to keep in mind.
Modification or Refinance: Because payment deferrals do not constitute a new obligation, even if you capitalize interest, you are not required to issue new disclosures related to Reg Z, RESPA. However, be sure your documentation of the payment deferral is a modification and not a refinancing. Refinancings would require all new disclosures. Be sure your payment deferral or extension agreements are clear about the impact on the loan term – whether the loan balance will reamortize to pay off by original maturity once payments resume, or a balloon payment will be created, or whether the maturity is extended for the number of months of deferral. Are you extending only the principal portion, or including interest and escrow? Consumers need to be clearly informed to make appropriate decisions.
Flood Insurance: You can use a prior flood determination for modifications, increases, renewals and extensions (MIRE), as long as you’re not making a new loan, under the following conditions:
- The previous determination is not more than 7 years old.
- No new or revised flood map has been issued in the interim.
- The determination was recorded on the SFHDF.
Additionally, capitalizing interest increases the loan balance and could require an increase in the amount of flood insurance required if the property is located in a SFHA. The regulatory agencies have not issued any reprieve to this point on flood insurance requirements for modifications related to COVID-19 payment relief.
Escrow: If your payment deferrals also include deferment of escrow payments, make sure the modification agreement addresses the potential future shortfall and how that would be handled, since the bank would still be making those tax and insurance payments as scheduled on the borrower’s behalf.
Negative Reporting to Credit Bureaus: Payment deferrals generally prevent the loan from being considered past due. You may want to evaluate whether to suspend reporting of negative information to credit bureaus more broadly during this time. You are not required by law to report to credit bureaus, but are required by law to report information accurately if you do.
Classifications of Loans with Payment Accommodations: The supervisory agencies continue to publish joint statements to help clarify matters for financial institutions making payment accommodations to borrowers due to COVID-19. We encourage you to go to the link periodically to view these helpful statements.
A statement issued March 22 reminds institutions that not all modifications of loan terms result in a TDR. Short-term modifications made on a good faith basis in response to COVID-19 to borrowers who were current prior to any relief are not TDRs. This includes short-term — for example, six months — modifications such as payment deferrals, fee waivers, extensions of repayment terms, or other delays in payment that are insignificant.
The agencies’ examiners will exercise judgment in reviewing loan modifications, including TDRs, and will not automatically adversely risk rate credits that are affected, including those considered TDRs. Regardless of whether modifications are considered TDRs or are adversely classified, agency examiners will not criticize prudent efforts to modify terms on existing loans for affected customers.
Foreclosures: President Trump on Saturday ordered foreclosures and evictions to cease for 60 days across the U.S. in response to the coronavirus pandemic. Freddie Mac and Fannie Mae have also said they would allow forbearance options up to 12 months to borrowers affected by the pandemic.
Fannie|Freddie Appraisal Flexibility: Appraisal Flexibility
Possible CRA Credit: You may get CRA credit for the payment deferrals and other accommodations to borrowers under financial distress due to COVID-19. See Joint Statement on CRA Consideration for Activities in Response to COVID-19
As the pandemic situation and its impacts continue to evolve daily, Sterling Compliance remains committed to our clients and will help in any way we can. We have received many, many questions, reviewed documents and messaging published by clients in response to the pandemic, and continue to monitor numerous sources for updates and information to help you through it.
We look forward to being able to resume travel and bank visits soon so we can see all of you in person, who we consider more than just clients, but dear friends!! Stay well!
From Stradley Ronon
Stradley attorneys are providing briefings that discuss the impact of COVID-19 on a wide range of businesses. We are regularly monitoring federal, state and local government guidance and will provide regular updates to guide you through the changing business climate. Please click here if you would like to sign up to receive our briefings via email.
Please visit Stradley Ronon’s COVID-19 RESOURCE CENTER for more information.
We are committing to having our small business lending platform launched in 7 days for any banks that need it at no cost.
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From URL Insurance Group
How will the Coronavirus (COVID-19) stimulus package benefit employers and employees?
Available On Demand – 30 minutes
Take a look at the provisions within the Coronavirus COVID-19 stimulus package and how they may provide relief.
YHB CPAs & Consultants
As the United States economy and daily life is being reshaped by COVID-19, maintaining “normal” business functions during these times is a challenge.
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