COVID-19 Response

Paycheck Protection Program (PPP)

PPP Updates by Date

IBAT is making it easier for you to keep track of all PPP updates by date on a new landing page we have developed for your convenience.

IBAT-Created Helpful Documents

Loan Reporting Guidance

Forms

IBAT-Produced Resources

The following resources were developed by the IBAT team to help community bankers navigate the COVID-19 situation most efficiently:

Karen Neeley's What's Keeping Me Up

Pandemic planning is the latest topic covered by Compliance Pathways, IBAT's new member service. All members are able to view the Compliance Pathways pandemic planning training free of charge.

Compliance Pathways offers a collection of practical tools, resources and training modules created by the best of the best in bank regulatory counsel to help your team overcome the daily burden of community bank compliance. Contact Kelly Goulart or Karen Neeley for more information about Compliance Pathways. 

Virtual War Room

IBAT has created a virtual War Room webinar to support Texas community bankers through both the economic and the operational crisis caused by the COVID-19 outbreak. The War Room will take place every Wednesday from noon to 1 p.m. and will feature IBAT's Karen Neeley, Christy Hester and Kelly Goulart. It will operate without a fixed agenda to give those who participate an opportunity to ask questions and share best practices with others facing the same unprecedented challenges. Register here.

Credit Consultation Hotline

As IBAT recently added an accomplished 30-year credit officer (Christy Hester) to our staff, beginning today we offer a Banker Hotline for members as they manage the current upheaval within our markets and communities.

Christy is available to answer questions, offer guidance and provide tools for portfolio analysis, loan grading, workout situations, regulatory examinations and a variety of other credit administration issues. She may be reached at 512-677-9248 during business hours.

COVID-19 Forum

The IBAT Compliance Forum now includes a COVID-19 section that allows Texas community bankers to share thoughts on the COVID-19 pandemic and its impact on bank operations. Click here to join the peer-to-peer conversation.

Fed Discount Window Borrowings

The Dallas Fed asked us to remind you that the Discount Window is available for short-term liquidity needs. We have been asked to emphasize that a bank coming to the Discount Window is not viewed as a sign of weakness, and banks are encouraged to consider this option as a part of their overall liquidity strategy. The primary credit rate has been reduced to 25 bps and term lending facilities are available for up to 90 days. If you have questions regarding this process, please call 877-682-3256 or find detailed information here.

U.S. Government and Financial Regulators

Best Practices

What are your peers doing? Primarily, we are hearing that bankers are protecting customers and staff by:

  • Posting Coronavirus notices on bank entrance doors. Download sample notice here.
  • Encouraging or requiring all staff who can work remotely to do so;
  • Reminding customers of their phone, ATM and digital banking options;
  • Providing relief to more severely affected customers (restauranteurs, hospitality companies, etc.) in the form of requiring interest-only payments on their borrowings for a period of time;
  • Providing employees who handle customer transactions the option of wearing gloves as they desire and encouraging regular breaks for handwashing and disinfecting transaction areas;
  • Propping open doors in common areas (not secure access doors) to prevent employees from touching door handles;
  • Limiting the number of customers allowed in the lobby at any time;
  • Limiting the number of people in elevators or other spaces where they would be in close contact with one another;
  • Closing branch lobbies and requiring all transactions be handled in the drive-through lanes;
  • Increasing cash orders and inventory in ATMs and vaults;
  • Offering fully paid time off to employees who are sick or caring for sick family members; and
  • Providing fully paid time off for two weeks if the employee is returning from spring break travel.

You may submit more ideas to clwilliston@ibat.org. Additionally, we have dedicated a portion of the IBAT Compliance Forum to COVID-19 best-practice sharing. Bankers are encouraged to post their internal and customer communications, ask questions, etc.

Proactive Staff Credentials May Be Needed

Those employees commuting between home and work at your bank offices may need some documentation in the unlikely event they encounter questions regarding the validity of their travel. While clearly a precautionary measure at this juncture, we feel compelled to recommend that each of these employees be provided with a signed letter on bank letterhead from the CEO or senior management of the bank stating something similar to this:
  
(Staff Name) is an employee of (Bank Name). He/she is part of our team designated for critical staffing during this time of restrictions on travel. As banks have been included in the exemptions as “critical infrastructure,” we appreciate your accommodation of our staff in this difficult time. If you have any questions or need additional information, please call me at xxx.xxx.xxxx. 
  
This related update was just received from Commissioner Cooper. On Sunday, March 22, 2020, the U.S. Treasury Department issued a memo stating that the financial services sector is identified as a Critical Infrastructure Sector by the Department of Homeland Security (DHS). The memo refers to guidance issued by DHS Cybersecurity and Infrastructure Security Agency (CISA) on Thursday, March 19, 2020 that lists essential workers for 16 critical industries. Hopefully, this should provide you some clarity as you work to provide service to your customers. Per the DHS guidance, critical financial services workers are:
  • Workers who are needed to process and maintain systems for processing financial transactions and services (e.g. payment, clearing, and settlement; wholesale funding; insurance services; and capital markets activities);
  • Workers who are needed to provide consumer access to banking and lending services, including ATMs, and to move currency and payments (e.g. armored cash carriers); and
  • Workers who support financial operations, such as those staffing data and security operations centers.

Messaging Regarding the Safety and Soundness of Your Bank

On Monday, Banking Commissioner Charles Cooper armed banks chartered by the State of Texas with the necessary discretionary tools to meet the needs and ensure the safety and health of both their customers and employees in the face of challenges tied to the COVID-19 pandemic. 

By declaring an emergency, the Texas Department of Banking has given its regulated banks the flexibility they need to offer services to their customers in a sustainable and protected manner as conditions related to the virus continue to evolve.  The Office of the Comptroller of the Currency has provided similar accommodations for national banks. 

Should such an extraordinary measure become necessary, rest assured that we at IBAT will work with both your banks and our federal and state regulatory agencies to make every effort to limit the disruption of banking services in Texas. In the meantime, we would encourage you to reassure your own customers by letting them know that:

  • [Your bank] is open for business!
  • At [your bank] we are committed to continuing to meet your financial needs during this time of uncertainty caused by COVID-19.
  • The state and federal banking regulators have granted banks flexibility in how we meet our customers' financial needs, and we are committed to making certain that your expectations are exceeded in all aspects of our service to you, your family and your business.
  • In the event a lobby is closed to protect the health and safety of both customers and employees, you can depend on us to meet all of your banking needs through one of our other locations or by utilizing technology, drive-through services and/or person-to-person telephone interaction.
  • Our high level of customer service remains a top priority as we work through these unprecedented challenges together.