Bank NotesSBA Simplifies Forgiveness for PPP loans of $50,000 or lessOctober 9, 2020 On October 8, 2020, the Small Business Administration (SBA) moved to simplify the forgiveness process for Paycheck Protection Program (PPP) loans of $50,000 or less. The SBA issued an interim final rule (ITF)1 and a new application, Form 3508S,2 and instructions.3 The relief does not constitute automatic forgiveness of a PPP loan. The ITF forgiveness relief applies to borrowers with PPP loans of… PPP Loans and Change of OwnershipOctober 6, 2020 Transactions involving changing the ownership of borrowers with outstanding Paycheck Protection Program (PPP) loans will be subject to new requirements under a procedural notice (Notice) issued by the Small Business Administration (SBA) on October 2, 2020.1 The Notice addresses the circumstances under which lenders may approve a change of ownership, when and how SBA approval must be obtained, and… Opportunities and Risks of Banking Hemp Producers in KentuckyAugust 3, 2020 Serving customers engaged in growing, cultivating, handling, or processing industrial hemp presents significant opportunities. But it presents heightened risks that require special care. A banker considering these opportunities must be aware of legal authority, Bank Secrecy Act (BSA), and credit risks associated with a new and rapidly expanding industry. The cultivation, processing, and sale of… Key Considerations for Banking Hemp Producers in West VirginiaAugust 3, 2020 Serving customers engaged in growing, cultivating, handling or processing industrial hemp present significant opportunities. As a banker considering pursuit of these opportunities, you should consider legal authority, Bank Secrecy Act (BSA), and credit risks associated with a new and rapidly expanding industry. Cultivation, processing and sale of industrial hemp and its byproducts has grown… CDC COVID-19 Guidance for Banks - Simplifying the Process for Lowering RiskJuly 24, 2020 It has been over four months since the COVID-19 pandemic emergency was declared. During that time, banks have been tasked with crafting solutions to address COVID-19 safety issues while assessing requirements of state executive orders, guidance from the Occupational Safety and Health Administration (OSHA), recommendations from state health agencies, and guidance from the Centers for Disease… COVID-19: The time to discuss your strategic directionJune 19, 2020 In times of substantial economic disruption, the natural tendency is to address short-term concerns and put off consideration of longer term strategy until the disruption passes and the picture becomes clearer. Delaying consideration of strategic direction in this fashion forgoes timely consideration of strategic opportunities and evaluation of risks presented by the disruption. Examining your… A first step on the road to clarity: CFPB Abusive Acts or Practices Statement of PolicyMay 29, 2020 On January 24, 2020, the Consumer Financial Protection Bureau (CFPB) published “Statement of policy regarding prohibition on abusive acts or practices” (Statement).1 The CFPB’s intention in publishing the Statement was “To convey and foster greater certainty about the meaning of abusiveness”. The Statement provides little to immediately clarify the definition of abusiveness. It does create a… Bankers Between a Rock and a Hard Place: PPP Forgiveness Advice to CustomersApril 30, 2020 Many banks have participated in providing loans under the Paycheck Protection Program (PPP). A key feature of PPP loans for most borrowers is the prospect of having the debt forgiven. Bankers are currently in a difficult position in responding to customer requests for guidance on forgiveness. Understandably, PPP borrowers wish to clearly understand the conditions that must be met to receive loan… Provides Options For Savings Accounts: Revision to Reg. DApril 27, 2020 On April 24, 2020, the Federal Reserve made significant changes to Regulation D (Reg D)1 treatment of “Savings Accounts”. The changes provide options for banks to reduce administrative burdens related to offering savings accounts while preserving the “reservation of right” provisions of Reg. D. Regulation D relates to reserve requirements imposed on depository institutions for the purpose of… The US Chamber of Commerce Foundation “Save Small Business” Grant ProgramApril 20, 2020 The Save Small Business Fund is a grant initiative administered by the U.S. Chamber of Commerce Foundation offering short-term relief for eligible small employers in the US and its territories. Eligible small business can apply to receive a $5,000 grant to be applied to business expenses. TO QUALIFY YOU MUST
Harmonizing Reg. O with SBA rules for making PPP loans to Directors and Principal ShareholdersApril 20, 2020 The Federal Reserve brought Regulation O1 (Reg. O) into substantial harmony with the Small Business Administration (SBA) Interim Final Rule2 authorizing SBA lenders to extend Payroll Protection Program (PPP) loans to businesses owned or controlled by a lender’s directors and shareholders holding a less than 30 percent equity interest in the lender. (SBA Interim Rule). On April 17, 2020, the… Set-off in the time of PPP: Managing litigation and reputation riskApril 16, 2020 For at least the next several months, you will be funding Payroll Protection Program (PPP) loans for your customers. At the same time, you may be dealing with loan defaults. You will attempt to accommodate your financially stressed borrowers. But, you will continue to have the obligation to make sound credit risk decisions to preserve the bank’s ability to recoup its principal and interest from… |
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