Industry Update Call
Round Two of the Tour de Texas was replaced with an Industry Update call webinar that took place on March 24, 2020. The slides from the call are available for download. The full call can be viewed below.
IBAT Produced Resources
The following resources were developed by the IBAT Compliance team to help community bankers navigate the COVID-19 situation most efficiently:
- IBAT Statement on the Safety and Soundness of the Banking System During COVID-19
- COVID-19 FAQs
- Credit Consultation Hotline
- COVID-19 Forum
- COVID War Room
- Idustry Update Call Recording
- Karen Neeley's What's Keeping Me Up on Coronavirus
- Karen Neeley's What's Keeping Me Up on Branch Closings
- Karen Neeley's What's Keeping Me Up on Triage
- Karen Neeley's What's Keeping Me Up on Online Banking Options
- Preparing for Potential Credit Quality Issues
- March 2020 Capitol Comments
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.
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 email@example.com. 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.
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.
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.
Proactive Staff Credentials May Be Needed
- 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.
Other Resources for Your Bank
The following resources were gathered/developed by the IBAT Compliance team to help community bankers navigate the COVID-19 situation most efficiently:
- Identifying Critical Infrastructure During COVID-19 (CISA)
- Business Continuity Management (FFIEC)
- ICBA: Crisis Response and Preparedness Toolkit
- ICBA Webinar Recording: COVID-19
- BKD: Summry of Tax-Related Provisions Found in HR 6201
- Business Recovery Loan Program (GEDP)
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
- Regulator Portals: FDIC | OCC | Fed | CFPB
- U.S. Department of Homeland Security Identifies ATM Servicing and Technology Support of Key Retailers as Essential to the Economic Security
- White House Guidelines for Slowing the Spread
- FDIC Financial Institution Letter on Working with Customers
- FDIC Bulletin: Potential Scams
- Pandemic Planning: Working With Customers Affected by Coronavirus and Regulatory Assistance
- Agency Statement on Meeting Customers' Financial Needs
- Interagency Statement on Pandemic Planning
- US Department of State Travel Advisory
- Interagency Supervisory Examiner Guidance for Institutions Affected by a Major Disaster
- FFIEC IT Examination Handbook: Business Continuity Management Booklet
- Ready.gov Pandemic Planning
- DHS CISA Insights: Risk Management for Novel Coronavirus
CDC And World Health Organization Information
- CDC Situational Summary
- CDC Interim Guidance for Businesses and Employers
- CDC Travel Advisory
- CDC Facts about COVID-19
- COVID-19 Resources for Your Bank
- Get Your Workplace Ready for Pandemic Flu