IBANYS Weekly E-Newsletter |
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Visit our website at www.ibanys.net to review all our daily updates on COVID-19 beginning on March 16.
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The President's Message:
IBANYS News and Updates
By John Witkowski, President & CEO
Hope everyone is staying safe, healthy and doing well.
Our weekly newsletter provides important information on many different topics from a variety of subject matter experts. Our partners provide guidance, advice and help educate us on the changes that are taking place every day. There are so many disruptive changes to banks and many of their customers that it is difficult to keep it all organized.
IBANYS provides a daily summary on important COVID updates, and on a weekly basis through this newsletter.
Please take the time to read the articles in this newsletter from our important partners, i.e., Luse Gorman on alternate revenue streams, Qwickrate provides a peer bank comparison and ICBA continues to work closely with the administration on important issues and asks for community banks to help with grass roots alerts.
IBANYS is focused on, works with and advocates for NYS community banks only. It's important that our State Assembly and Senate know the important role community banks play in supporting their communities. Community banks were the catalyst in helping small businesses during the PPP.
If you would like to learn more about IBANYS, please contact me at johnw@ibanys.net or call the office at 518.436.4646.
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Check out our Washington and Albany sections for the latest updates.
Congress and the White House were unable to reach agreement on the next coronavirus relief and recovery package. The President signed four executive orders related to evictions, a payroll tax cut suspension, relief for student borrowers and $400 a week for unemployed people. (They did not include a mandatory ban on evictions and would also require states to provide 25% of the unemployment benefits.)
- The executive orders also do not add funding for small businesses, schools, or state and local governments, or a second round of stimulus checks.
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Governor Cuomo criticized the executive orders and warned New York faces historic budget cuts without federal assistance. Trump administration officials and Democratic congressional leaders urged each other to return to the negotiating table to craft a broad coronavirus package.
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ICBA and IBANYS are urging community bankers to use ICBA's Be Heard grassroots action center to urge Congress to advance PPP reforms as well as capital, accounting, and tax relief.
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IBANYS is very excited to be moving forward with our 2020 Virtual Annual Convention September 30 - October 2. In the midst of the continuing changes brought about by the pandemic, it's a way for IBANYS to continue to provide important and timely educational programming to New York community bankers. Today's newsletter includes the latest updates on the program, speakers, sponsorships and the opportunity for banks to make the virtual convention available to all bank employees.
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IBANYS VIRTUAL CONVENTION |
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SAVE THE DATES
September 30 - October 1-2, 2020
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NEW INFORMATION: IBANYS is adapting to the new normal brought about by the pandemic including switching our 2020 Annual Convention to a “Virtual” Convention this fall. The 2020 IBANYS “Virtual” Annual Convention is scheduled for Wednesday, September 30 – Friday October 2, 2020. Banks can register for one price, and the event will be open for all bank employees. As we finish "fine tuning" the agenda, here is a sneak speak at a couple of the confirmed speakers. Watch your weekly newsletter and your email for more details and registration information coming soon.
We would also like to thank our all of our generous sponsors of this event and their continued support of IBANYS and all community banks. Please take a moment to click on the company logo below to learn more about each sponsor and how they help the community banks.
If you would like to be a sponsor, please contact me at johnw@ibanys.net or 518-436-4646 for details.
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Scott Hildenbrand, Managing Director, Head of Balance Sheet Analysis & Strategy Financial Services - Piper Sandler (click for here for bio)
Balance Sheet Management: Strategies vs. Tactics for Earnings, Liquidity, Capital, and ALM
There are effective tactics worth examining and executing in today’s rate environment and economic landscape. But don’t get comfortable that you have set a strategy simply by executing tactics. Scott Hildenbrand, Head of Balance Sheet Analysis and Strategy, will cover a series of current themes including liquidity, balance sheet efficiency, securities, derivatives, and capital. The discussion will focus on advantageous tactics and longer term strategy while highlighting the asset/liability sensitivity and impact to quality or quantity of earnings.
Learning Objectives
#1 Understand the difference between a tactic and a strategy and why planning for both will benefit your institution
#2 Evaluate the benefits of quality vs. quantity of earnings and how to tell the difference
#3 Learn how to protect against rate moves and position your institution for success in different rate environments
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Scenario Analysis for Navigating Through the Storm
The unprecedented severity and uncertainty of the Great Lockdown recession has made imperative the application of scenario analysis for portfolio management within banks. This presentation will help community bankers to: (i) understand how to develop relevant and coherent scenarios that take into account the various fiscal stimulus programs; (ii) identify problem areas in the portfolios as the crisis unfolds by segmenting the portfolios into key CRE property types and C&I industry categories and applying the scenarios on the income and collateral value of those borrowers; (iii) assess the adequacy of the loss reserves by portfolio as the various forbearance programs expire; (iv) benchmark the provisions of their bank under different scenarios; and (v) apply stress testing to identify dangerous vulnerabilities and potential capital shortfall in their portfolios.
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Our Sponsors
Click the logos to learn more
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IBANYS Webinars
Are you participating in IBANYS webinars? Now is the time! IBANYS webinars provide timely, important information on subjects of interest to New York community bankers including human resources, business development, investment, compliance and security and much more. They are valuable not only for their content, but for their convenience and low-cost. Take part from the comfort and privacy of your office, without leaving the bank.
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Subscription Tokens
The More You Buy, The More You Save
How does it work:
Tokens can be used to purchase live or recorded webinars anytime, with no expiration! Tokens for both live and recorded webinars are available for an additional fee. (What’s the difference? Click here for the full description.)
Once you have your Subscription Token code, you can immediately register for webinars by using the code at checkout! (Subscription tokens not applicable for full series registrations, or other specials.)
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IBANYS Preferred Partners & Associate Members |
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Main Street, Inc. Acquires Marketing Technology Software Provider Onovative |
We have acquired a marketing technology software provider, Onovative. This purchase further enhances Main Street’s marketing services solutions.
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Reimagine the Traditional Banking Business Mode - Fee-Generating Business Acquisitions |
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NYS Qtr. 2 Performance Report |
QwickAnalytics Community Bank Index (QCBI)
State Performance Trends
Key industry trends for the "true" community bank
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2020 Bank Compensation and Benefits Survey
Don't miss out! Survey participants get a copy of the 2020 Crowe Financial Institutions Compensation and Benefits Report at a significant discount.
The survey includes critical information:
- Salary trends and incentive payouts
- Employee turnover and staffing levels
- Benefit trends
- Generations in banking
- Board of directors’ compensation
This year's survey has information specific to the COVID-19 pandemic:
- Work-from-home arrangements
- Layoffs
- PPE requirements
Participating in the 2020 survey is the first step to accessing valuable bank compensation benchmarks and trends across 273 jobs. Participating banks will receive a significant discount on the published report. Deadline to participate is Friday, August 14.
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The NextGen Scholarship is Back!
The LEAD FWD Summit is Sept. 21-22 and offered in virtual format
Due to the success of last year's NextGen scholarship program, we are excited to announce that ICBA is once again offering this exciting scholarship opportunity for our state association friends.
With the ICBA 2020 NextGen Scholarship you have an opportunity to award one community banker from your membership a fully-paid scholarship to ICBA's virtual leadership conference, the 2020 LEAD FWD Summit (Sept. 21-22).
This is your scholarship to award to a deserving community banker in your state! We’re thrilled to assist you in further engaging the future of our industry and we’re delighted to partner on this NextGen Scholarship opportunity. For more details, including how to participate, please refer to this informational brief and our ICBA State and Regional Partner web page where you will find customizable promotional tools and assets.
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ICBA Offers New Guide On SBA Lien Requirements EIDLs
ICBA posted a new guide to Small Business Administration lien requirements on Economic Injury Disaster Loans after seeking SBA input on its treatment of EIDLs. The guide notes that EIDL loans over $25,000 require a blanket Universal Commercial Code lien allowing the SBA to take an interest in the assets of the business. It also says the SBA does not prohibit lenders with a superior lien position to the UCC-1 lien to continue advancing additional funds under existing borrowing arrangements. The guide also provides SBA contact information for borrowers and lenders seeking consent for subordination, and it links to additional EIDL resources from SBA. Additional information on the federal pandemic response are available in ICBA's frequently asked questions on COVID-19. View the EIDL guide.
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From The NYS DFS: New Part 7 Proposal (36.10 Waiver) for Comment
The new Part 7 would allow regulated entities to disclose confidential supervisory information to external legal counsel and independent auditors without prior approval as long as certain conditions are met. State Administrative Procedure Act § 202-b(6) was recently enacted and now requires an agency that files a notice of proposed rulemaking that affects small businesses or local governments to ensure that the agency conducts outreach to small businesses and local governments “affected by the proposed rule or organizations representing the interests of such entities.” Therefore, DFS seeks comments on the new Part 7 from institutions that employ less than 100 people. Please disseminate to applicable institutions for comment. Comments may be submitted through our website until August 14, 2020. If you send a comment, please send a courtesy copy to George Bogdan at George.bogdan@dfs.ny.gov.
Cuomo Criticizes President's Latest Executive Orders
Governor Cuomo said President Trump's executive orders won't help New York State out of its fiscal hole, and some of the requirements may be impossible for the state to meet. With New York facing a multibillion-dollar budget hole, the Governor has been pushing the federal government to provide funding for state and local governments. Cuomo noted the executive orders are "on shaky ground legally, but even to the executed executive orders, they aren't going to meet the demand." One of the presidential requirements would have state governments take up 25 percent of unemployment costs, a move the Governor said would cost New York $4 billion. He warned he state's budget hole could force cuts of up to 20% for schools, health care programs and local governments. "The federal action has to be resolved," Cuomo said.
DFS FAQ On Forbearance For Residential Mortgages Held In Portfolio By NYS Chartered Banks
The NYS Department of Financial Services (DFS) has issued the "Frequently Asked Questions (FAQ) document on the state's new Residential Mortgage Forbearance Law on forbearance for residential mortgages held in portfolio by NYS chartered banks. IBANYS would like to thank the DFS team for providing guidance through this document, which IBANYS had suggested.
The FAQ document may be accessed through the link below.
Legislature Prepares To Reconvene -- Forbearance Likely On Agenda
The Legislature is expected to reconvene soon and will likely take up additional forbearance legislation for residential and commercial investment property mortgage payments. That may well include. A.10532A, Bichotte (see link below). IBANYS opposes the legislation (see second link below), and is working with the Legislature and the NYS DFS.
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ICBA’s Romero Rainey To Policymakers: Streamline PPP Forgiveness Process
ICBA President and CEO Rebeca Romero Rainey writes in a new op-ed in "The Hill" that policymakers need to simplify the onerous forgiveness process for small businesses to ensure the Paycheck Protection Program fulfills its purpose to support the nation’s top job creators. Loans of $150,000 or less represent 86 percent of borrowers but less than 27 percent of loan dollars issued under the emergency program, Romero Rainey explained, noting ICBA’s support for congressional efforts to forgive such loans with a simple, one-page document. This would allow the smallest businesses to focus their time, energy and resources on their business and employees, instead of complex forgiveness forms, she wrote. “As the United States continues to grapple with the repercussions of the coronavirus pandemic, these business owners' time and resources would be better focused on getting the economy safely back up and running, not processing burdensome paperwork,” Romero Rainey wrote. To read the full op-ed:
https://thehill.com/blogs/congress-blog/politics/511349-how-to-keep-the-small-business-recovery-going?utm_campaign=NewsWatch%20Today&utm_medium=email&_hsmi=92989530&_hsenc=p2ANqtz-__XTPvLh1SdHlu1yxAoeklYs3eNZXUckYtiBx83NqmxYS5ienK8oM7d9NYSWqMJtts1qk_Zq3TZPY3VWHPJKz3ZfPyyw&utm_content=92988240&utm_source=hs_email
ICBA Seeks Clear Rules On PPP Agent Relationships
ICBA called on the Treasury Department and SBA to clarify rules on Paycheck Protection Program fees paid to agents that assist borrowers or lenders. In a letter to SBA and Treasury, ICBA said rules and guidance dictate that agents are to be paid from lender fees, though how the agency relationship is to be formed remains unclear. Common law requires contractual relationships to form agency relationships, as suggested by Treasury Secretary Steven Mnuchin in congressional testimony. ICBAasked Treasury and SBA to confirm that this is the case for PPP agency arrangements for agents to be entitled to compensation for their services. ICBA noted that the lack of clarity has led third parties to demand fees from PPP lenders—including via a growing number of lawsuits—simply because they communicated with the borrower in some manner.
SBA's Interim Final Rule On Appeals Of SBA PPP Loan Decisions
The SBA released an interim final rule on appeals of SBA loan review decisions under the Paycheck Protection Program that outlines the process for borrowers to appeal adverse SBA decisions regarding borrower eligibility, the loan amount received, improper use of the PPP loan proceeds, and/or the PPP loan forgiveness amount claimed by the borrower. The SBA also updated its frequently asked questions on the Paycheck Protection Program with guidance that payment or nonpayment of agent fees do not affect the SBA guarantee, and that vision and dental insurance costs are eligible payroll costs. The loan forgiveness FAQs are also updated to cover the deduction of Economic Injury Disaster Loans advances from forgiveness amounts. Additional guidance and resources are available on Treasury’s PPP webpage and ICBA's COVID-19 resource center.
What's Next For Coronavirus Package?
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In the aftermath of President Trump's executive orders following the inability of Congress and the administration to reach agreement on the next coronavirus legislative package, a U.S. Labor Department official acknowledged funding for a $300 weekly boost to federal unemployment benefits under President Trump's recent executive action could run dry in five to six weeks. The $44 billion in funds available will also take time to reach recipients, as states will have to update their systems, and states are not required to send another $100 a week to beneficiaries as prescribed by Trump's action to replace the expired $600 weekly benefits. Senior Trump administration aides also reportedly acknowledged the program provides less financial assistance for the unemployed than the president initially announced. Both the administration and congressional leadership have urged a return to the negotiating table to seek agreement on a package, but to date there is no progress.
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ICBA wants Congress to advance provisions in the Senate stimulus draft proposal to provide an intermediate forgiveness process for PPP loans under $2 million and streamlined forgiveness for loans under $150,000, an ICBA-advocated policy in bipartisan legislation (S. 4117/H.R. 7777) that Treasury Secretary Steven Mnuchin recently called on lawmakers to consider. As detailed in specific stimulus recommendations to Congress, ICBA and 42 state community banking associations are also advocating an online PPP loan-forgiveness calculator, liability protections from COVID-19-related lawsuits, and additional relief to help community banks support the economic recovery.
HUD sets aside funding to help low-income households amid COVID-19
The Department of Housing and Urban Development announced $472 million in CARES Act funding to help low-income families during the coronavirus pandemic. HUD made the funding available to Public Housing Authorities to help families utilizing the Housing Choice Vouchers and Mainstream vouchers.
The FAQs address loan-forgiveness applications, payroll and nonpayroll costs, owner-employee compensation, reductions in the forgiveness amount, and more, including new guidance on issues such as covered utility payments and eligible electricity supply charges. The SBA recently said its new platform for submitting PPP loan-forgiveness applications and decisions to the agency will go live this Monday, Aug. 10. Additional guidance and resources are available on Treasury’s PPP webpage and ICBA's COVID-19 resource center. Meanwhile, ICBA continues calling on community bankers to use its Be Heard grassroots action center to urge Congress to advance PPP reforms as well as capital, accounting, and tax relief.
ICBA Seeking ILC Grassroots Outreach
ICBA continues calling on community bankers to urge their senators to co-sponsor legislation to close the industrial loan company loophole. The customizable message on ICBA's Be Heard grassroots action center notes that ILCs pose a significant risk to the financial system and should be regulated like other banking institutions. The Eliminating Corporate Shadow Banking Act (S. 2839) would subject ILCs to the Bank Holding Company Act.
ICBA recently called on the FDIC to deny Rakuten Bank America’s resubmitted ILC application and urged the agency to strengthen its proposal to enhance oversight of ILC parent companies.
Through its "Wake Up" campaign, ICBA will continue encouraging policymakers to open their eyes to the risky practices, costly tax subsidies, and irresponsibly lax oversight of tax-exempt credit unions.
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SBA Data: Smaller Lenders Lead On PPP
Lenders under $10 billion in assets have made some 2.74 million Paycheck Protection Program loans worth more than $233 billion through both rounds of funding, the SBA reported. According to an SBA summary of loan approvals through Aug 8, lenders from $10 billion to $50 billion in assets made nearly 770,000 loans worth more than $100 billion. A total of 5.2 million PPP loans have been made, aggregating $525 billion.
Mortgage Updates:
The average contract interest rate for 30-year fixed-rate mortgages with conforming loan balances ($510,400 or less) decreased to 3.06% from 3.14%, with points falling to 0.33 from 0.39 (including the origination fee) for loans with a 20% down payment.
Mortgage applications to purchase a home rose 2% for the week and were a strong 22% higher than the same week one year ago.
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Bulletin | OCC 2020-73 August 7, 2020
Summary
This bulletin informs all national banks, federal savings associations, and federal branches and agencies of foreign banks (banks) of fees and assessments charged by the Office of the Comptroller of the Currency (OCC) for the remainder of calendar year 2020. The bulletin becomes effective September 7, 2020.
Note for Community Banks
This interim notice applies to all community banks.
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