November 12, 2020
IBANYS Weekly E-Newsletter
  • Visit our website at to review all our daily updates on COVID-19 beginning on March 16.
Thank you for your service!
Yesterday was Veterans Day, when together we honored and thanked all U.S. military veterans — all those who have served, are serving and have made the ultimate sacrifice to keep our country free and safe. We must never forget that we are the land of the free because of the brave.

On behalf of IBANYS, thank you!
The President's Message
By John Witkowski, President & CEO

The post-election period continues, and we still have uncertainty on a number of important races at both the state and federal level. We do know that the NYS Senate and Assembly will continue to be under Democratic control by significant margins -- perhaps at "supermajority" veto-proof margins, though that appears less likely in the Senate. We know that our 27-seat New York congressional delegation will remain heavily Democratic, but that Republicans have apparently gained two seats, increasing their total to eight seats. Plus, we know that some current and former New York congressional Representatives are reportedly under consideration for positions in the incoming Biden administration if and when that race is certified.
Take a look at today's newsletter for important information on next week's FDIC Directors Session for New Directors. . .the latest column from Jim Reber, President & CEO of ICBA Securities. . .and a special welcome to our newest IBANYS member bank: Quontic Bank, headquartered in Manhattan.

Please note: Bank membership dues invoices have been mailed. If you have not received your invoice please contact Linda Gregware at or 518.436-4646.
IBANYS Welcomes our Newest Member Bank
Quontic is a U.S.-based bank headquartered in Manhattan, New York City. Quontic has additional locations in Astoria, New York; Melville, New York; Flushing, New York; and Miami, Florida. Though the bank offers traditional branch, in-person banking, it has gained media attention for its mobile banking app, home loans and reverse mortgages.

FDIC Directors Session for New Directors
Thursday, November 19
The role of a community bank director is one that is always changing and has never been more critical to the success of your bank.
An informal discussion with Brian T. Rosenberg, Supervisory Examiner with the FDIC will share with directors the examination process and their roles/responsibilities as a director.
This discussion is intended to for new (less than 5 years) directors.

IBANYS Preferred Partners & Associate Members
AG Lending Summit
Look who's joining us November 17-18, 2020 (9am-Noon CST) for the Ag Lending Summit. Make sure you don't miss this opportunity to help grow your bank and customers...

Sporting Clay Tournament at Vernon National Shooting Preserve  
December 3
Bankers only are invited to participate in a Sporting Clay Tournament sponsored by Strategic Resource Management and co-hosted by IBANYS. Please click the link below to see the flyer for the complete details. Space is limited and will be on be on a first come/first serve basis.

It may be a little chilly, but it will be a good time.

Things You Never Thought You’d Say
COVID-19 has created a lot of first-ever conversations.
By Jim Reber
It may be a gross oversimplification to say this, but in many ways, community banks deal with their favorite broker the same way you deal with your dry cleaner. For one thing, there’s repeat business; we’re not a durable goods vendor that you visit every three years. For another, fixed-income brokers sell a set of relatively fungible products. For another, since there are plenty of us out there, we’re obliged to stay pretty much on-market with our prices.

IBANYS Webinars

Are you participating in IBANYS webinars? Now is the time! IBANYS webinars provide timely, important information on subjects of interest to New York community bankers including human resources, business development, investment, compliance and security and much more. They are valuable not only for their content, but for their convenience and low-cost. Take part from the comfort and privacy of your office, without leaving the bank. 
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Albany Update

Governor Cuomo this week discussed the state’s multibillion-dollar budget gap that has been exacerbated by the pandemic. The deficit is now at least $14 billion in the current budget year. Cuomo has pushed the federal government (unsuccessfully, to date) to include more relief in its stimulus packages. A Biden administration may be more favorably inclined, but the U.S. Senate remains under GOP control now, and may stay that way in 2021 depending upon the two Georgia runoff elections January 5.  Senate Republicans have so far been reluctant to provide more stimulus money to state and local governments.

  • The Governor still believes a federal stimulus package for the state could happen before the end of 2020, and noted under Biden “there is going to be a state and local package and we know that will go a long way to handling New York's economic problem. We don't know how far, but it's a matter of time now."

  • However, he noted that if the gap cannot be closed with federal money, the state is looking at tax increases, layoffs, borrowing and early retirements. Cuomo has pushed back on plans to raise state taxes on the wealthy because it would not raise as much money as the state needs and could drive more New Yorkers to leave the state and seek residence in states with lower taxes -- which could further damage the tax base. The Governor instead says there should be a federal tax hike on the wealthiest.

IBANYS continues to monitor whether the State Legislature will reconvene in a "lame-duck" post-election session that would likely focus on the state's financial and fiscal situation -- and, that could also include additional forbearance legislation for residential investment properties and commercial retail space mortgage payments. IBANYS opposes the legislation, and is working with the Legislature and the NYS DFS. To access the legislation, and IBANYS' Memo in Opposition: Click here to read the legislation. Click here to read IBANYS Memo in Opposition.
The New York State Department of Financial Services (DFS) advised New York-Regulated financial institutions to integrate financial risks from climate change into their governance frameworks, risk management processes, and business strategies. The guidance issued by Superintendent Lacewell follows a similar guidance to New York-Regulated Insurers. Read a full copy of the letter on the DFS website. To read the DFS press release on the guidance:
Washington Update

  • Senate Banking Committee Chairman Crapo (R-ID) urged banking regulators to continue using their discretion to alleviate burdens caused by emergency recovery programs. At an oversight hearing, Crapo repeated his calls for the agencies to extend CARES Act relief and to adjust community bank regulatory asset thresholds to mitigate costs from their Paycheck Protection Program leadership. ICBA this week called on congressional leaders to ensure any pandemic relief package includes community bank priorities, such as simplified PPP forgiveness, full Economic Injury Disaster Loan Advance forgiveness, and excluding PPP loans from regulatory asset thresholds. Community bankers can continue the push for these key policy priorities with a customizable message to Congress on ICBA's Be Heard grassroots action center. The regulators will be back on Capitol Hill today for a follow-up House Financial Services Committee hearing.

  • President-elect Biden named Ronald Klain as his White House chief of staff. Klain served as Biden's chief of staff when he was vice president, and subsequently lead the U.S. response to the Ebola outbreak. 

  • President-elect Biden is reportedly eyeing a bipartisan list of 30 members of Congress known for working across the aisle for key administration posts, including five New Yorkers: Democrats Anthony Brindisi and Antonio Delgado, and Republicans Tom Reed, John Katko and the retiring Peter King.

  • Legislation introduced by Sen. Lee (R-Utah) would protect borrowers and lenders from regulatory penalties associated with the Paycheck Protection Program (PPP) after ICBA raised the issue with policymakers. The Protections for Good Faith PPP Borrowers and Lenders Act (S. 4875) would remove PPP loans from asset calculations to prevent lenders from crossing asset-size thresholds and incurring additional regulatory burdens. It also would protect lenders from various penalties and enforcement actions and remove PPP loans from the CFPB's purview. The Senate bill follows the release of ICBA-advocated House legislation directing regulators to exclude PPP loan balances from bank and bank holding company regulatory thresholds within 30 days. H.R. 8675 applies to community banks with $15 billion or less in total assets.
  • In an op-ed, ICBA Chairman Wilcox and a small business customer wrote that the conflict between the Paycheck Protection Program (PPP) and Economic Injury Disaster Loan (EIDL) advances is undermining the federal coronavirus response. In the joint op-ed on Medium, they note that small-business owners have been surprised to find that EIDL advances are reducing PPP loan forgiveness, leaving them with unexpected balances of up to $10,000. "In short, federal programs designed to help small businesses survive government-imposed closures are threatening to close their doors for good," they wrote. ICBA continues working with policymakers to strike the CARES Act provision requiring EIDL advance deductions and is calling on community bankers to urge Congress to address the issue in the next pandemic relief bill.
IBANYS previously urged New York Congressional Delegation To Support PPP Changes. As the stalemate between Congress and the Trump administration regarding the next coronavirus legislative package continues, IBANYS has written to the New York Congressional Delegation (and shared the letter with the NYS Legislature as an FYI) urging support of a number of important changes ICBA has suggested be made to the Paycheck Protection Program. Read IBANYS' letter to Congress. Read IBANYS letter
Additional Information
News Release | NR 2020-149 November 12, 2020
WASHINGTON—Acting Comptroller of the Currency Brian P. Brooks today testified during a hearing held by the U.S. House Committee on Financial Services.
The Acting Comptroller’s testimony discussed the agency’s efforts to ensure the federal banking system operates in a safe, sound, and fair manner, provides fair access to services and fair treatment of customers.
The Acting Comptroller’s testimony also provided an overview of the agency’s priorities and recent activities, including its response to COVID-19 and the Project REACh initiative to expand fair access to capital and credit.
Related Links

Bulletin | OCC 2020-99 November 9, 2020
Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches; Department and Division Heads; All Examining Personnel; and Other Interested Parties

The Office of the Comptroller of the Currency (OCC) published in the Federal Register on June 5, 2020, a final rule1 (June 2020 rule) that strengthens and modernizes the agency’s regulations under the Community Reinvestment Act (CRA). This bulletin summarizes key provisions of the June 2020 rule, which became effective October 1, 2020. This bulletin provides responses to frequently asked questions (FAQ) from bankers2 and examiners about how the OCC will administer and implement the June 2020 rule.

This bulletin rescinds OCC Bulletin 2020-3, “Community Reinvestment Act: Notice of Proposed Rulemaking,” and OCC Bulletin 2020-4, “Community Reinvestment Act: Request for Public Input.”

Note for Community Banks
This rule applies to community banks subject to the CRA.

The June 2020 rule preserves the important objective of encouraging banks to help meet the credit needs of their local communities, including low- and moderate-income neighborhoods, while responding to the significant changes and advancements in the banking industry since the CRA’s enactment in 1977 and the last comprehensive regulatory changes in 1995. The June 2020 rule provides new standards for evaluating bank performance and for collecting, maintaining, and reporting data used in the CRA evaluation process.


News Release | NR 2020-147 November 9, 2020
WASHINGTON — The Office of the Comptroller of the Currency (OCC) today reported the key issues facing the federal banking system and the effects of the COVID-19 pandemic on the federal banking industry in its Semiannual Risk Perspective for Fall 2020.
Banks remain in strong financial condition but profitability is stressed due to low interest rates and increasing levels of provisions for problem loans. The OCC reported credit, strategic, operational, and compliance risks, among the key risk themes in the report.
Highlights from the report include:
  • Credit risk is increasing as the economic downturn impacts customer ability to service debts.
  • Strategic risk is an emerging issue due to the historically low rate environment, potential credit stress and their effect on bank profitability.
  • Operational risk is elevated as financial institutions respond to altered work environments and an evolving and complex operating environment. Cybersecurity threats contribute as a key driver of the heightened operational risk environment.
  • Compliance risk is elevated due to a combination of altered work environments, and the requirement to quickly operationalize federal, state, and proprietary programs designed to support businesses and consumers. 
The report also highlights emerging trends in payment products and services as a special topic in emerging risks.
The report covers risks facing national banks and federal savings associations based on data as of June 30, 2020. The report presents information in four main areas: the operating environment, bank performance, special topics in emerging risk, and trends in key risks. It focuses on issues that pose threats to those financial institutions regulated by the OCC and is intended as a resource to the industry, examiners, and the public.

Related Link