October 21, 2020-...------------------------------------------------------------------------------------------------No copyright infringement intended
Vendor * Spotlight
New Summary on Recent PPP Guidance
 
ICBA released a summary of recent Paycheck Protection Program guidance, including a simplified forgiveness process and guidelines on Economic Injury Disaster Loan advances.
 
The document details:
  • The simplified Form 3508S application and instructions for borrowers with PPP loans of $50,000 or less.
  • An SBA update to its frequently asked questions on the extended deferral period for borrower payments on PPP loans.
  • SBA's announcement that lenders can now see if the agency will deduct an EIDL advance from final forgiveness payments.
 
ICBA continues to offer a guide on SBA lien requirements related to EIDLs and additional information on the federal pandemic response on its COVID-19 frequently asked questions.

Source: Independent Community Bankers of America
SBA Offers EIDL Info on PPP Platform

Information on Economic Injury Disaster Loan advances is now available on the Paycheck Protection Program Forgiveness Platform for submitted decisions, the SBA said in a letter to lenders with several updates on processing forgiveness payments.
 
According to the letter, lenders can see if the SBA will deduct an EIDL advance from final forgiveness payments.
 
While borrowers may receive up to a $10,000 advance payment under the EIDL program, those funds will be deducted from PPP loan forgiveness, leaving some borrowers with a substantial unforgiven balance that must be repaid.
 
The arrangement is proving to be a surprise for many given previous SBA guidance indicating EIDL advances do not have to be repaid, but not spelling out the impact on PPP forgiveness.

Source: Small Business Administration 
Ransomware Mitigation Tool
 
State financial regulators, joined by the Bankers Electronic Crimes Task Force and the U.S. Secret Service, issued a self-assessment tool to banks they supervise in an effort to help mitigate ransomware attacks.
 
Incidents of ransomware across industries have been on the rise and appear to be spreading. One global cyber insurer reported 775 ransomware incidents for its U.S. customers in 2019, representing a 131% increase from the year prior. Eleven percent of those customers were financial institutions. 

Using the ransomware tool, a bank can assess its efforts to control and mitigate risks associated with the threat of ransomware and identify gaps that require increased security. 

Source: Bankers Electronic Crimes Task Force
Bank Merger Antitrust Guidelines Should Be Updated
 
State regulators support the U.S. Department of Justice Antitrust Division’s efforts to modernize bank merger competitive guidelines and offered recommendations in a comment letter sent earlier this month. 

The letter responds to the DOJ’s request for information on the 1995 Bank Merger Competitive Review Guidelines. Antitrust issues are a significant issue for state regulators, who charter and supervise 79% of the nation’s banks, which accounts for approximately 4,008 banks with $7.1 trillion in assets. 

Any changes to the guidelines should reflect the changing landscape of the marketplace and needs of community banks to serve their communities, the letter said. 

CSBS asked that the DOJ: 
  • Reevaluate how the Herfindahl-Hirschman Index is calculated due to the evolving banking practices and market competition.
  • Consider adopting an appropriately tailored approach to preserve the viability of community banks and creating a de minimis exception for certain transactions. 
  • Explore ways to create greater alignment and consistency with the federal and state banking agencies. 
  • Recognize and incorporate the role and interests of states in the bank merger review process. 

Source: Conference of State Bank Supervisors 
Human Trafficking Advisory Issued

The Financial Crimes Enforcement Network issued a supplemental advisory to help financial institutions identify and report human trafficking. The advisory encourages financial institutions to understand trafficking methodologies and behavioral indicators to support their detection and reporting of suspicious transactions.

 Source: Financial Crimes Enforcement Network
Call Report Materials Released

The FDIC released call report materials for the Sept. 30 report date, which are due Friday, Oct. 30. The call report includes revisions for institutions subject to the advanced capital adequacy framework.

Source: Federal Deposit Insurance Corporation 
Nacha Extends Relief From Certain Operating Rules

Nacha issued an update on relief from various Operating Rules requirements due to the coronavirus pandemic. Relief from certain records deadlines, signature requirements, and more have been extended. The bulletin also includes information on upcoming effective dates.


Source: National Automated Clearing House Association 
Banks Healthy Amid Pandemic

U.S. banks have remained financially healthy throughout the coronavirus pandemic even while combatting the economic downturn, Fed Vice Chair for Supervision Randal Quarles said. Quarles said that while bank leadership on Paycheck Protection Program lending and loan forbearance has put a strain on balance-sheet capacity, most banks remain profitable and are adding substantially to their loan-loss reserves to remain resilient.

Source: Federal Reserve Board
Ag Program Enrollment Begins

Agricultural producers can now make elections and enroll in the Agriculture Risk Coverage and Price Loss Coverage safety-net programs for the 2021 crop year, the USDA announced. Enrollment for the 2021 crop year closes March 15, 2021.

Source: US Department of Agriculture