March 27, 2020 


MBA Conference Call With Luetkemeyer, Wagner Now Available

MBA hosted a conference call today with Congressman Blaine Luetkemeyer and Congresswoman Ann Wagner about the CARES Act and the provisions in the legislation affecting banks and their customers. A recording of that call is available on MBA’s website. To access the recording online requires a password to MBA’s website.

MBA Encourages Bankers To Carry 'Essential Employee' Documents

Because Missouri’s “stay at home” and/or “shelter in place” orders are being determined on a county-by-county basis, please become familiar with the exact wording of the order you are subject to in your community (if applicable). Encourage your staff to carry these documents (that can be modified for your bank) with them, along with anything that shows their relationship with the bank relationship – ID badge, business card, etc. – for employment verification. These documents, posted on MBA's website, require a password to access.

ABA Publishes Executive Summary of Coronavirus Relief Bill

The American Bankers Association has prepared an executive summary of the CARES Act — the $2 trillion stimulus package to provide relief to American consumers and businesses struggling as a result of the coronavirus pandemic. The bill was passed unanimously by the Senate late Wednesday night. The House passed the bill this afternoon, and it now moves to the president for his signature.

The bill includes several provisions ABA actively advocated for in conversations with policymakers over the last several days, including:
  • significant enhancements to the Small Business Administration’s lending programs
  • temporary relief from troubled debt restructurings
  • an optional CECL delay
  • an 8% community bank leverage ratio
The executive summary highlights these and other major provisions that are most relevant to the banking industry. MBA has posted the summary on its website, and a password is required to access it.

ABA Webinar On SBA Programs Now Available For Download

The American Bankers Association’s recent webinar to help banks learn more about Small Business Administration programs they can employ to help customers affected by the coronavirus pandemic is now available for ABA members to download. The webinar, featured experts from the SBA Office of Capital Access and Office of Disaster Assistance who discussed the agency’s preparations for implementing the special SBA funding provisions in the CARES Act. They also discussed other loan programs that banks can use to help customers in response to COVID-19. 

Regulators Grant Extensions For Certain Required Filings

Acknowledging the significant burdens that banks are currently facing as they aid customers during the coronavirus pandemic, the Federal Financial Institutions Examination Council announced a 30-day extension for institutions for the Call Report due Tuesday, March 31. Banks anticipating a delayed filing should notify their primary regulator in advance, FFIEC said.

The Federal Reserve also issued its own statement confirming it would not take action against banks with $5 billion or less in assets for submitting the March 31 FR Y-9C or FR Y-11 after the official filing deadline, provided the forms are submitted within 30 days of the original filing deadline. Institutions should contact their reserve bank if they anticipate a late filing.
In related news, the Securities and Exchange Commission also announced temporary relief for companies affected by the coronavirus pandemic to file required Exchange Act reports. The SEC will grant a 45-day grace period to file forms 10-K and 10-Q that were due on or before July 1, 2020. Registrants may file Form 12b-25 and use the grace period provided by Rule 12b-25 if they are unable to meet the extended due date.
In order to take the temporary relief, companies must file a Form 8-K or 6-K by the original report deadline that includes a summary of why the relief is needed for each report that is delayed, SEC said.

CFPB To Postpone Certain Data Collections Due To Coronavirus

To help banks focus on responding to their customers’ needs during the coronavirus pandemic, the Consumer Financial Protection Bureau announced it will postpone certain data collections for CFPB-related rules. This includes data required to be submitted under the Home Mortgage Disclosure Act and Regulation C, the Truth in Lending Act, Regulation Z and Regulation E.

In two separate policy statements issued with the announcement, the CFPB said it would delay quarterly HMDA reporting, annual submissions concerning agreements between credit card issuers and institutions of higher education, quarterly submission of consumer credit card agreements, collection of certain credit card price and availability information and submission of prepaid card account agreements.

The CFPB confirmed that it “does not intend to cite in an examination or initiate an enforcement action against any institution” that fails to submit these data according to the established reporting schedules, but added that institutions should continue gathering the data in anticipation of making future submissions. The CFPB said it would provide more information later about resuming regular reporting.

Finally, the bureau said it would work with institutions to schedule examinations and other supervisory activities in a manner that would minimize disruption and burden. When issuing enforcement actions, the CFPB will “take into account current staffing and related resource challenges confronting financial institutions and their counsel.”

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