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
- Colson Services Guidance (particularly for issues related to forgiveness and loan reporting using SBA Form 1502)
The following resources were developed by the IBAT team to help community bankers navigate the COVID-19 situation most efficiently:
- Board Resolution Supporting Full FDIC Coverage
- Branch Reopening Survey Results
- Comments on Treasury's and SBA's PPP Loan Forgiveness Requirements
- Business Continuity Planning Considerations
- Credit Consultation Hotline
- COVID-19 FAQs
- COVID-19 Forum
- COVID War Room
- Cybersecurity Readiness Guide
- IBAT Statement on the Safety and Soundness of the Banking System During COVID-19
- Industry Update Call Recording
- Loan Modifications and Reporting
- Paycheck Protection Program - IFR on Loan Increases Summary (full IFR vailable here)
- Paycheck Protection Program Note Considerations: PDF | Word
- Preparing for Potential Credit Quality Issues
March 2020 Capitol Comments
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.
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.
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:
- ACH Network Rules Pandemic-Related FAQs (Nacha)
- BKD: Summry of Tax-Related Provisions Found in HR 6201
- Business Continuity Management (FFIEC)
- Business Recovery Loan Program (GEDP)
- ICBA: Crisis Response and Preparedness Toolkit
- ICBA Webinar Recording: COVID-19
- Identifying Critical Infrastructure During COVID-19 (CISA)
- Texas Supreme Order Regarding Garnishments
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
- Agency Statement on Meeting Customers' Financial Needs
- CARES Act (H.R. 748) Full Text
- CFPB FAQs on Adverse Action Notices for PPP Loans
- CFPB Guidance on Remittance Transfers During COVID-19 Pandemic (Final Rule)
- CFPB Outlines Responsibilities of Financial Firms During Pandemic
- CFPB Paves Way for Consumers Facing Financial Emergencies to Obtain Access to Mortgage Credit More Quickly
- Chair Jerome H. Powell Testimony on Coronavirus and CARES Act
- Department of Labor Families First Coronavirus Response Act: Employer Paid Leave Requirements
- Department of Labor Coronavirus-Related Paid Leave for Workers and Tax Credits for Small and Midsize Businesses
- Department of Labor Guidance on Paid Sick Leave, Family and Medical Leave Benefits (updated March 27)
- Department of Labor Required Posters Effective April 1, 2020
- DHS (CISA) Insights: Risk Management for Novel Coronavirus
- DHS (CISA) Guidance on the Essential Critical Infrastructure Workforce (updated March 28)
- Economic Impact Payment Disbursements: Information for Financial Institutions (Treasury)
- FDIC Bulletin: Potential Scams
- FDIC Consumer News: COVID-19 and Your Financial Health
- FDIC Financial Institution Letter: New SBA and Treasury Programs Available for Small Business Relief
- FDIC Financial Institution Letter: Working with Customers
- Federal Reserve Board: Interim Final Rule on Reg D "Savings Deposit" Definition
- Federal Reserve Relief Initiatives
- FFIEC IT Examination Handbook: Business Continuity Management Booklet
- FinCEN Advisory on Medical Scams Related to the COVID-19
- FinCEN: Further Information to Financial Institutions in Response to the COVID-19 Pandemic
- Interagency Rules of Modification
- Interagency Statement on Appraisals and Evaluations Affected by the Coronavirus
- Interagency Statement on Pandemic Planning
- Interagency Supervisory Examiner Guidance for Institutions Affected by a Major Disaster
- IRS Coronavirus Tax Relief and Economic Impact Payments
- IRS COVID-19-Related Tax Credits for Required Paid Leave FAQs
- Joint Guidance on Home Equity Lending
- Main Street New Loan Facility
- Main Street Expanded Loan Facility
- Pandemic Planning: Working With Customers Affected by Coronavirus and Regulatory Assistance
- Paycheck Protection Program: Changes to the Regulatory Capital Rule to Accommodate the Program
- Paycheck Protection Program (PPP) Interim Final Rule
- Paycheck Protection Program (PPP) Interim Final Rule on Additional Eligibility Criteria and Requirements
- Paycheck Protection Program (PPP) Interim Final Rule on Loan Increases
- Paycheck Protection Program (PPP) Interim Final Rule on Promissory Notes, Authorizations, Affiliation and Eligibility
- Paycheck Protection Program (PPP) Lending Facility Term Sheet
- Paycheck Protection Program (PPP) FAQs: Treasury Version | FinCEN Version
- Ready.gov Pandemic Planning
- U.S. Department of Homeland Security Identifies ATM Servicing and Technology Support of Key Retailers as Essential to the Economic Security
- U.S. Department of State Travel Advisory
- U.S. House of Representatives Letter to Treasury and SBA on PPP Loan Forgiveness
- What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO Laws
- White House Guidelines for Slowing the Spread
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
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.
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.