October 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…
August 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…
August 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…
July 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…
June 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…
May 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…
April 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…
April 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…
April 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
April 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…
April 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…
April 9, 2020
In this time of mandatory social distancing, the normally routine act of a notary witnessing and attesting to the validity of the signature is complicated. Many transactions depend on the ability of the parties to ensure valid signatures on legally binding documents. However, now notaries often cannot witness signatures in person.
There are two solutions available in Kentucky for many types of…
October 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…
August 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…
August 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…
July 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…
June 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…
May 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…
April 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…
April 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…
April 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
April 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…
April 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…
April 9, 2020
In this time of mandatory social distancing, the normally routine act of a notary witnessing and attesting to the validity of the signature is complicated. Many transactions depend on the ability of the parties to ensure valid signatures on legally binding documents. However, now notaries often cannot witness signatures in person.
There are two solutions available in Kentucky for many types of…
