IBANYS Weekly E-Newsletter
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Visit our website at
www.ibanys.net
for all you educational needs. See dates and registration information (if available) for our live programs and be sure to check out our webinar offerings. Watch for IBANYS' monthly marketing newsletter for additional features and updates.
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The President's Message:
IBANYS News and Updates
By John Witkowski, President & CEO
So, Here's Where We Are. . .
As New Yorkers and all Americans continue to cope with the continuing coronavirus covid-19 crisis, New York's community banks are on the front lines, working to provide essential services, reassurance, liquidity and continued support to our consumer and commercial customers and our communities. IBANYS has worked hard to serve as a conduit of information for community banks by holding regular conference calls with small groups of bankers on a regional basis, staying in frequent contact with the New York
We have provided New York community bankers with daily -- and often twice or three times daily -- updates on the latest developments and activities, including information culled from the NYS DFS, Governor Cuomo's office, the OCC, FDIC, Federal Reserve, Federal Home Loan Bank of New York, Small Business Administration, FASB, New York Congressional Delegation, Pursuit, the Empire State Development Corporation and many others, including outside legal firms and expert advisors. We will continue to do so as the crisis evolves. Hopefully, you have been receiving these regular IBANYS updates. If not, please let us know. The updates will soon be available on IBANYS' website at www.ibanys.net.
As you know, we are dealing with a two-pronged crisis
.
- New York State has nearly ten times as many cases as the next highest state. Particularly in New York City (and other downstate areas), the emergency threatens to overwhelm hospitals and health care workers, and impact nearly every aspect of society and business. and the economic/financial situation.Throughout the state, New Yorkers are dealing in various degrees with social distancing, self-quarantining, staying at home, sheltering in place, and working remotely. This is certainly true among community banks themselves, and by the very nature of our position in our local communities, we are also seeing these difficulties manifest themselves among our customers.
- Meanwhile, the impact of the virus and our responses have resulted in a financial and economic challenge greater than any since the 2008-09 great recession. Many businesses (especially small businesses) face the prospect of closures, layoffs, payroll restrictions, a liquidity squeeze and an uncertain future. Mortgage loans, auto and consumer loans, commercial loans. . .forbearance issues and policies, fee waivers. . .all these, and more, are the focus of federal and state government and present challenges to our industry.
The U.S. Senate and the White House have reached agreement on the a massive $2 trillion stimulus deal
--
see detailed analysis below in Washington section of newsletter
. As more details become available, we will share them with New York community bankers.
The Small Business Administration (SBA) has "ramped up" (including on 7(a) loans, etc.), and encouraged financial institutions to work with them to help small businesses. Treasury Secretary has urged federal banking regulatory agencies to not apply "pre-coronavirus standards" and not to indulge in harmful "nitpicking" practices regarding financial institutions, but instead to expect them to demonstrate "good faith."
In any case, community banks will be at the forefront in leading the economic revitalization. . .and IBANYS will continue to work hard on your behalf to make your needs and concerns known, and provide you with the very latest updates and information.
# # # # #
. .
.It's annual meeting time.
Luse Gorman PC has provided some guidance on
whether banks can hold their upcoming shareholder or member annual meetings virtually
in light of health concerns of COVID-19.
This alert
addresses the legal and practical considerations for holding a virtual meeting.
Or, click on link below:
https://www.luselaw.com/wp-content/uploads/2020/03/Alert-Virtual-Annual-Meetings-in-Response-to-COVID-19-5.pdf
# . # . # . # . #
NOTE:
As of today, all IBANYS and ICBA meetings through June1, 2020 for have been POSTPONED.
IBANYS 46th Annual Convention -
The Roaring 20s - Another Decade of Growth and Prosperity for Community Banks
June 15-17, 2020 - Turning Stone Resort & Casino, Verona, NY
(details and registration information will be emailed this week)
A block of rooms has been reserved for this event. Tower Rooms: $164; Tower Junior Suites: $244; Lodges Suites: $269. To receive the room block rate you must call 1-800-771-7711. Book your room today. Our room block will sell out.
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Important Upcoming Webinars On Covid-19 & Impact On Community Banks
COVID-19: The Insurance Implications for Banks and Their Customers
Thursday, March 26 | 11 a.m. (Eastern)
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.
The federal financial institution regulatory agencies and the state banking regulators, will host an interagency webinar on Friday, March 27, 2020, at 2 p.m. EST.
This interagency Ask the Regulators session is designed to help clarify the
interagency statement issued on March 22, 2020
, which encourages financial institutions to work constructively with borrowers affected by COVID-19 and provides additional information regarding loan modifications, including when such modifications would not result in accounting for troubled debt restructuring designation. This webinar is scheduled for Friday, March 27, 2020, from 2:00-2:45 p.m. EDT. Registration is now open at
https://www.webcaster4.com/Webcast/Page/583/33856
.
OCC encourages participants to submit questions in advance via email at
rapid@stls.frb.org
. Webinar materials will be archived for future viewing. With questions, please contact Rafael (Ralph) E. DeLeon, Director for Banking Relations/National Bank Examiner, Office of the Comptroller of the Currency: (202) 649-6736 office; (202) 359-0096 cell;
ralph.deleon@occ.treas.gov
ICBA Webinar: Federal Legislative & Regulatory Update On
ICBA will host an important webinar this
Friday, March 27
that will include comprehensive summary from its legislative and regulatory staff on the most up-to-date federal developments and activities.
To register, please click on the link provided below.
ICBA encourages early registration, as their system can only accommodate a finite number of calls.
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As many of you know, IBANYS has been in contact with the New York State Department of Financial Services (DFS) over the past few days, seeking additional clarification regarding Governor Cuomo's Executive Order 202.9 regarding mortgage and fee relief. Tuesday afternoon, DFS
issued Emergency Regulations pursuant to that Executive Order
, and we wanted to share this updated information with you.
Click on the link below to read the emergency regs:
The regs are also available on the DFS website at https://www.dfs.ny.gov under "News and Views"
Please let us know if you have questions, comments after reviewing the document.
This morning, Governor Cuomo, DFS Superintendent Lacewell and Deputy Superintendent for Banks Shirin Emami issued the following New York State DFS Update to the Guidance to New York State Regulated Institutions and Request for Assurance of Operational Preparedness Relating to the Outbreak of the Novel Coronavirus:
"To the Chief Executive Officers or the Equivalents of New York State Regulated Institutions:
This is an update to the “Guidance to New York State Regulated Institutions and Request for Assurance of Operational Preparedness Relating to the Outbreak of the Novel Coronavirus” (the Industry Letter) issued by the New York State Department of Financial Services (the Department) on March 10, 2020. The Industry Letter requested a response within 30 days from the date of the Letter, which is April 9, 2020.
The Department has received various requests to extend the time to respond to the Industry Letter due to the impact of COVID-19. The Department recognizes and appreciates that many institutions are currently experiencing resource and other constraints during this challenging time. To that end, the Department hereby extends the deadline for responding to the Industry Letter to May 25, 2020.
Latest On State Legislature, Budget Process, Projected Revenue Shortfall
The State Legislature is not now expected to return to Albany this week. The State is now looking at a revenue shortfall of up to $15 billion -- much of it due to the inability to collect taxes as usual with the April 15 deadline extended to July 15. The Legislature is now expected to return next week to hopefully approve a state budget, but there is an effort to modify the process to allow changes to be made along the way as the situation evolves.The Cuomo administration believes the state budget deficit can only be ameliorated by a massive influx of federal aid. With Congress on the brink of passing another round of federal aid to help states deal with the virus and its associated effect on the economy, the Governor may not get what he wants from the federal government on the funding front. That could have major implications for the state budget process and plans to cut spending in the state Medicaid program.
The New York State Department of Financial Services
(DFS) has issued
four industry letters for state regulated banks regarding the coronavirus.
They include:
- DFS Relief order
- Operation Risk Guidelines
- Financial Risk Guidelines
- Support for Business Guidelines
These letters and other updates are available on the DFS website:
www.dfs.ny.gov
.
- DFS also released an order that grants temporary relief to COVID-19 affected state regulated entities that includes clarification of the process for temporarily relocating branches and other authorized places of business; supervision guidance for working from home; utilizing telephonic or electronic meetings under the public meetings law, and deadline extensions for filing requirements.
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Fed To Suspend Exams For Banks Under $100B
The Federal Reserve announced it will temporarily stop all examination activity for banks with less than $100 billion of assets as it shifts supervisory priorities due to the coronavirus pandemic.
The Fed is shifting its supervisory focus to monitoring and outreach to “help financial institutions of all sizes understand the challenges and risks of the current environment,” and will be minimizing examination activities in order to do so, with the greatest reduction at smallest banks. For banks with more than $100 billion of assets, the Fed plans to defer a portion of planned examinations but will still conduct an exam when a financial stability or consumer protection issue has been flagged at a firm. “The Board recognizes that the current situation is significantly affecting areas of the country in different ways and will work with financial institutions to understand the specific issues they are facing,” the Fed said in a statement. Banks subject to the Comprehensive Capital Analysis and Review stress tests will still be required to submit capital plans to the Fed by April 6, but extra time will be granted for resolving non-critical existing supervisory findings in order to focus on “heightened risks in this current environment.” This year’s capital plans will “be used to monitor how firms are managing their capital in the current environment, planning for contingencies, and positioning themselves to continue lending to creditworthy households and businesses,” the Fed said. The temporary shift will last until at least the end of April, when the Fed will reassess whether conditions have changed.
Congress Addressing Crisis In $2 Trillion Stimulus Package
The White House and the U.S. Senate has reached agreement on a massive stimulus bill of up to $2 trillion to provide economic relief to individuals, businesses, unemployed Americans. Both the Senate and House now need to pass the legislation (the Senate is voting today). While the full language and details are not yet clear, the package is intended to keep liquidity in the system, to the benefit of consumers, businesses and including banks. ICBA reports that the stimulus bill includes policies that ICBA has fought to include on behalf of community banks. They include:
- Enhancing the Small Business Administration’s 7(a) loan program,
- Providing net-operating-loss tax relief,
- Ensuring robust FDIC deposit insurance coverage,
- Delaying implementation of the Current Expected Credit Losses accounting standard,
- Ensuring coronavirus-related loan modifications are not classified by regulators as troubled debt restructurings, and
- Reducing the Community Bank Leverage Ratio from 9 percent to 8 percent during the COVID-19 national emergency.
Governor Cuomo said the package does not include enough aid for New York, claiming it would only receive $3.8 billion for its efforts to combat the coronavirus pandemic: “$3.8 billion sounds like a lot of money (but) the response to this virus has probably already cost us $1 billion. It will probably cost us several billion dollars when we’re done.”
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Important ICBA Coronavirus Related Webinar!
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. Community bankers who have questions or need assistance can contact ICBA at
crisisresponse@icba.org
.
. . .Did you miss the ICBA Community Bank Briefing discussing the coronavirus pandemic, its effect on community banks, and resources your bank can use? There is a free
webinar recording
available. Visit www.icba.
ICBA To FASB: Suspend CECL Standard Until 2025
ICBA called on the Financial Accounting Standards Board to suspend implementation of the Current Expected Credit Losses accounting standard until 2025. ICBA said delaying implementation will better focus the financial system on responding to the coronavirus outbreak. FDIC Chairman Jelena McWilliams, members of Congress, and state regulators have also called for a CECL delay. ICBA strongly supports legislation introduced by Senate Banking Committee member Kevin Cramer (R-N.D.) to extend CECL implementation for community banks until 2025. Separate ICBA-supported legislation from House Subcommittee on Consumer Protection and Financial Institutions Ranking Member Blaine Luetkemeyer (R-Mo.) would exempt from CECL compliance for six months any entity affected by the coronavirus
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