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
By John Witkowski, President & CEO
I want to thank IBANYS board member Anders Tomson, President & CEO of Chemung Canal Trust Company, who testified earlier today on behalf of IBANYS at a Joint Public Hearing by the State Senate Committees on Banks and Commerce, Economic Development and Small Business regarding "Access to Capital for Small Businesses" during the Covid-19 Pandemic. Anders did a great job representing New York community banks' success helping clients, customers and small businesses during PPP!
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IBANYS continues to work to provide important programming for New York community bankers in this challenging year. While our scheduled Directors Conference was canceled earlier in the year due to the pandemic, we realize the importance of ensuring that your board members remain fully informed and up to speed on the many developments and trends facing the industry -- particularly as they relate to the role and responsibilities of directors. So, we arranged to work with the FDIC to present a Directors Conference virtually today.
The program covered effective board governance in these uncertain times, and the crucial part that directors play in establishing and maintaining the governance framework at the bank. Among the topics we examined was the problem loan oversight, including loan modifications, performance assessment, internal risk ratings and fair lending. Members of the FDIC's management team discussed emerging issues and engaged in a dialogue and q. and a. session with community bankers.
Whether through online and virtual presentations, webinars or other new and innovative delivery options, IBANYS will continue to meet our banks' educational needs.
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IBANYS is sad to inform you longtime New York community banker and former IBANYS Chairman Tom Hales passed away on October 8. He was the former Chairman, President & CEO of U.S.B. Holding Company and its wholly owned subsidiary, Union State Bank, and chaired IBANYS in 1988-89.
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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
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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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Barret Crisis Leadership Virtual Training |
Take your bank to the next level, Crisis Leadership gives you the tools to help your institution in creating a culture equipped to handle ANY crisis.... be it biological, economic, or weather related.
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In recent weeks, several questions were raised about the FedNow Pilot Program. Please see the release below issued today by the Federal Reserve.
There are links in the release that provide additional information. Please note, the deadline to submit the Expression of Interest Form is November 16th.
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WEBINAR: Smarter Loan Reviews – NOW
Choose your date and time that works best for you.
Tuesday, October 20th at 2:00pm EDT
Duration: 45 minutes
Cost: Free
Webinar description:
COVID-19 has skewed traditional credit risk management, including fewer and delayed loan reviews. The current economic stress dictates, and regulators and bankers know, Now is NOT the time to forego loan reviews. Why? Combined temporary stimulus and regulatory relief programs have effectively masked actual portfolio credit risk. Banks must now begin the hard work of determining loan-by-loan credit risk profiles. Join our webinar to see a new approach to efficiently address all the backed-up loan reviews that have been delayed due to COVID-19. We’ll show how you can use technology to simplify the entire loan review process — with a powerful diagnostic engine — whether performed internally or externally. Don’t rely on a business model that hasn’t changed in 30+ years to do what’s needed now. Attend this webinar to learn more.
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As we await word whether and when the NYS legislative session may reconvene, IBANYS continues to closely monitor and engage in the legislative process in Albany on behalf of community banks. As noted above in the President's Message, the most recent example is at today's Joint Public Hearing by the NYS Senate Committees on Banks and on Commerce, Economic Development and Small Business to examine "Access to Capital for Small Businesses During the COVID-19 Pandemic." IBANYS' board member Anders Tomson, President & CEO of Chemung Canal Trust Company, testified on behalf of IBANYS and the industry and did an outstanding job!
We anticipate the State Legislature will reconvene, most likely in a "lame duck session" after the election. Lawmakers likely plan to consider additional forbearance legislation for residential investment properties and commercial retail space mortgage payments -- which were strongly opposed by IBANYS in original form. IBANYS opposes the legislation, and is working with the Legislature and the NYS DFS. The legislation, and IBANYS' Memo in Opposition, may be accessed in the links below.
The legislative agenda will certainly focus on the state's financial and fiscal situation. Governor Cuomo continues to hope for eventual federal assistance, but has reportedly amassed enough money to avoid major cuts to this year’s $177 billion spending plan. The Legislature may consider other options to raise revenue, such as eliminating the rebates the state currently provides on stock transfers; enacting higher income taxes on those with more than $1 million in annual income, and creating a new tax on super wealthy people with more than $1 billion in assets. There is also talk of the “pied-à-terre” property tax surcharge on qualifying non-primary residences within the state. https://www.natlawreview.com/article/covid-19-real-estate-revival-new-york-pied-terre-tax;
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Negotiations between House Speaker Pelosi and Treasury Secretary Mnuchin regarding another coronavirus relief/recovery package remain at an impasse. Senate Majority Leader McConnell has indicated the Senate will take up a "narrow" package next week that would provide about $500 billion for hospitals, schools, and an extension of enhanced unemployment insurance benefits and PPP funding. However, the President appeared to criticize the effort and urged Congress to "go big or go home" on the initiative.
ICBA urged policymakers to advance the economic recovery despite the stalled negotiations, noting bipartisan "Paycheck Protection Small Business Forgiveness Act (H.R. 7777/S. 4117) to simplify PPP loan forgiveness will help small businesses dedicate more of their resources to paying workers and supporting local economies. ICBA (and IBANYS) have urged Congress to pass legislation to simplify forgiveness for loans of $150,000 or less. (The SBA recently announced a simplified process for loans of $50,000 or less.)
Community bankers are urged to call their members of Congress and enlist the support of small-business contacts on behalf of a standalone PPP forgiveness reform bill. ICBA's "Be Heard" grassroots action center includes call alerts for small-business owners and community bankers on behalf of legislation to forgive PPP loans of $150,000 or less.
IBANYS has previously urged New York Congressional Delegation To Support PPP Changes. As the stalemate between Congress and the Trump administration regarding the next coronavirus legislative package continues, IBANYS has written to the New York Congressional Delegation (and shared the letter with members of the NYS Legislature as an FYI) urging support of a number of important changes ICBA has suggested be made to the Paycheck Protection Program. Read IBANYS' letter to Congress. Read IBANYS letter
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Bulletin | OCC 2020-88 October 9, 2020
To: Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties
Summary
The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the National Credit Union Administration (collectively, the agencies), with the concurrence of the Financial Crimes Enforcement Network (FinCEN), today issued a revised order granting an exemption from the requirements of the customer identification program rules implementing section 326 of the USA PATRIOT Act for certain loans. The affected loans are those extended by banks1 and their subsidiaries under the jurisdiction of the agencies to customers to facilitate purchases of property and casualty insurance policies referred to as insurance premium finance lending or premium finance loans. This revised order extends the customer identification program exemption for premium finance loans to all customers of banks.
Rescission
This bulletin replaces OCC Bulletin 2018-35, “Bank Secrecy Act/Anti-Money Laundering: Order Granting Exemption from Customer Identification Program Requirements for Premium Finance Lending.” The order conveyed under OCC Bulletin 2018-35 limited the exemption to commercial customers.
Note for Community Banks
The revised order applies to community banks.
Highlights
The agencies have determined, and FinCEN has concurred, that granting this exemption from the requirements of the customer identification program rules is consistent with
1. the purposes of the Bank Secrecy Act.
2. safe and sound banking practices.
Further Information
Please contact James Vivenzio, Acting Director for BSA/AML Compliance Policy, at (202) 649-5470.
Grovetta N. Gardineer
Senior Deputy Comptroller for Bank Supervision Policy
Related Link
1 For the OCC, “banks” refers collectively to national banks, federal savings associations, covered savings associations, and federal branches and agencies of foreign banking organizations.
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