On May 28, 2020, the U.S. House of Representatives passed legislation that, if adopted by the Senate and signed into law by the President, would provide considerable relief to borrowers under the Paycheck Protection Program (PPP). The bill, known as the Paycheck Protection Program Flexibility Act of 2020 (PPPFA), amends the original Coronavirus Aid, Relief, and Economic Security (CARES) Act to loosen restrictions placed on PPP loans, making them more favorable for borrowers.…

The 21st Century Banker

SBA Announces Procedure for PPP Lenders to Collect Loan Processing Fees

By James M. Kane, James W. Morrissey, Daniel C. McKay, II, Jennifer Durham King, Juan M. Arciniegas & Mark C. Svalina

May 22, 2020

On May 21, 2020, the U.S. Small Business Administration (“SBA”) released a notice informing lenders of how they may collect loan processing fees for eligible loans issued under the Paycheck Protection Program (“PPP”). Pursuant to the CARES Act and the Interim Rule, issued by the SBA on April 2, 2020, the SBA will pay fees to lenders for processing eligible PPP loans at the following rates, based on the balance of the loan outstanding at…

The 21st Century Banker

Paycheck Protection Program Loans May Be Excluded from a Bank’s Regulatory Capital Ratios

By James M. Kane, Daniel C. McKay, II, James W. Morrissey, Jennifer Durham King, Juan M. Arciniegas & Mark C. Svalina

April 9, 2020

On April 9, 2020, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), and the Office of the Comptroller of the Currency (collectively, the “federal banking agencies”) issued an interim rule that permits banks to neutralize the regulatory capital effects of participating in the Federal Reserve’s Paycheck Protection Program Lending Facility (the “PPPL Facility”).…

The 21st Century Banker

Temporary Regulatory Relief: Community Bank Leverage Ratio Set At 8%

By James M. Kane, Daniel C. McKay, II, James W. Morrissey, Jennifer Durham King, Juan M. Arciniegas & Mark C. Svalina

April 7, 2020

On April 6, 2020, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation and the Board of Governors of the Federal Reserve System (collectively, the “federal banking agencies”) announced the issuance of two interim final rules to provide temporary relief to community banks. The federal banking agencies acted to implement Section 4012 of the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), which requires the federal banking agencies to…

The 21st Century Banker

Federal Reserve Suspends Regulatory Examination Activity for Banks with Total Consolidated Assets Under $100 Billion

By James M. Kane, Daniel C. McKay, II, James W. Morrissey, Jennifer Durham King, Juan M. Arciniegas & Mark C. Svalina

March 25, 2020

On March 24, 2020, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued a statement on its supervisory activities (“Statement”) during the unprecedented COVID-19 pandemic. As part of that Statement, the Federal Reserve indicated that “to minimize disruption and burden on financial institutions, the Federal Reserve is reducing its focus on examinations and inspections at this time.” In its effort to minimize the regulatory burdens placed on financial institutions, the Federal…

The 21st Century Banker

Coronavirus Update: Strategies and Considerations for Financial Institutions

By James M. Kane, Daniel C. McKay, II, James W. Morrissey, Jennifer Durham King, Juan M. Arciniegas & Mark C. Svalina

March 19, 2020

Over the past two weeks, we have received numerous inquiries from financial institutions on what actions should be taken or considered to address the COVID-19/Coronavirus pandemic. While every bank is different and the current situation is evolving each day, we have engaged in numerous discussions with banks on various strategies and considerations that are being reviewed or implemented during this uncertain time.…

The 21st Century Banker

Congress Acts to Protect Employees Affected by COVID-19

By Philip L. Mowery

March 17, 2020

On March 14, 2020, the U.S. House of Representatives, with the support of the President, overwhelmingly approved a bill known as the Families First Coronavirus Response Act (H.R. 6201). The legislation is scheduled to be taken up by the U.S. Senate during the week of March 16th, and is expected to be signed into law promptly by the President once the legislation is finalized. This bulletin focuses on those aspects of the legislation approved by…

The 21st Century Banker

Coronavirus: Considerations for Financial Institutions

By James M. Kane, Daniel C. McKay, II, James W. Morrissey, Jennifer Durham King, Juan M. Arciniegas & Mark C. Svalina

March 5, 2020

Over the past two weeks, the international markets have been roiling under news that the COVID-19 virus, commonly referred to as the coronavirus, may be spreading. The Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency and the Consumer Financial Protection Bureau (collectively, the “Federal Bank Regulators”) have not issued specific guidance or released public…

The 21st Century Banker

Federal Banking Agencies Issue Community Bank Leverage Ratio Compliance Guide

By Juan M. Arciniegas, James M. Kane, Jennifer Durham King, Daniel C. McKay, II, James W. Morrissey & Mark C. Svalina

October 31, 2019

On October 29, 2019, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (the “Federal Banking Agencies”) issued a joint press release announcing a final rule which provides qualifying community banking organizations the ability to opt-in to a new community bank leverage ratio (“CBLR”) framework. As part of its announcement, the Federal Banking Agencies issued a CBLR compliance guide. To review the CBLR…

The 21st Century Banker

CECL Implementation Delayed for Qualifying Entities

By Juan M. Arciniegas, Thomas P. Desmond, James M. Kane, Jennifer Durham King, Daniel C. McKay, II, James W. Morrissey & Mark C. Svalina

October 18, 2019

On October 16, 2019, the Financial Accounting Standards Board (“FASB”) extended the implementation deadline for the current expected credit loss standard (“CECL”) for qualifying entities. The new implementation deadlines are as follows:…

The 21st Century Banker

Reliable and trusted news, commentary and industry updates for financial institutions.

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UPDATE: U.S. House of Representatives Seeks to Amend the CARES Act to Provide Borrower’s Relief under the PPP

SBA Announces Procedure for PPP Lenders to Collect Loan Processing Fees

Paycheck Protection Program Loans May Be Excluded from a Bank’s Regulatory Capital Ratios

Temporary Regulatory Relief: Community Bank Leverage Ratio Set At 8%

Federal Reserve Suspends Regulatory Examination Activity for Banks with Total Consolidated Assets Under $100 Billion

Coronavirus Update: Strategies and Considerations for Financial Institutions

Congress Acts to Protect Employees Affected by COVID-19

Coronavirus: Considerations for Financial Institutions

Federal Banking Agencies Issue Community Bank Leverage Ratio Compliance Guide

CECL Implementation Delayed for Qualifying Entities

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