May 1, 2020

ABA Releases Customizable Matrix On Returning To Normal Operations

As states begin loosening or revoking stay-at-home orders and banks consider how and when to resume operations that may have been closed or modified because of the pandemic, the American Bankers Association has prepared a customizable matrix (requires MBA password) to guide banks’ planning.

The matrix provides a comprehensive list of potential mitigation measures banks may take related to their facilities, customer interactions and workforce management, including the use of sneeze guards at teller windows, medical screening of employees, cleaning procedures and the use of personal protective equipment.

It also lists any general federal guidance that applies to each reopening factor, such as that issued by the Centers for Disease Control and Prevention, Equal Employment Opportunity Commission, Occupational Safety and Health Administration and other federal agencies, and it indicates where state and local authorities should be consulted for more specific requirements.

Fed Expands PPP Liquidity Facility’s Eligible Participants, Collateral

The Federal Reserve expanded access to its PPP Liquidity Facility to nonbank lenders and expanded the range of collateral that can be pledged to the PPPLF. Eligible borrowers will now be able to pledge whole PPP loans that they have purchased.

All lenders approved by SBA to make PPP loans are now eligible to pledge collateral to the PPPLF. Eligible nondepository institutions include nonbank community development financial institutions, Farm Credit System lenders, small business lending companies licensed by SBA and some fintech firms, the Fed said.

Division Of Finance Temporarily Waives Notary Requirements

The Missouri Division of Finance is temporarily waiving notary requirements for some documents submitted to the division. This waiver, effective until June 15, affects certain provisions of statutes and regulations that require a notarized signature on a document that must be submitted to the division by a financial institution or licensee. All other duties and obligations of the financial institution or licensee and the division shall remain in force. All such documents included with the division’s request must continue to be signed before filing with DOF, which will then follow its established procedures for review and compliance. In the interim, the filing of “unnotarized” yet otherwise properly completed documents shall be deemed in compliance with the law.