The President's Message:
IBANYS News and Updates
By John Witkowski, President & CEO

Beginning March 16, IBANYS has sent out daily (often, twice daily) updates to New York community banks to provide information and developments regarding the impact that coronavirus (COVID-19) is having on New York community banks. If you have missed any of these communications, or would like to refer back to them, each is included on our website. Click the link : https://ibanys.net/covid-19/

IBANYS continues to work with a wide array of resources to provide information to New York community banks as additional details, programs, initiatives and updates become available. We are in contact with the New York State Department of Financial Services, OCC, FDIC, the Federal Reserve, Members of our New York Congressional Delegation & State Legislature, our partners at ICBA, the SBA and a number of our fellow state community banking trade groups around the country.

While progress is being made with the SBA's PPP process, there are still questions that need to be addressed, including:
  • Are bank directors eligible for PPP from their own bank?
  • Do FDIC-insured, non SBA banks need authorization codes to submit apps on new SBA portal?

Meanwhile, These FAQs HAVE now been answered and added to the Treasury PPP FAQs:  
 
Q: Do lenders have to use a promissory note provided by SBA or may they use their own?
 
A:  Lenders may use their own promissory note or an SBA form of promissory note.     
 
Q:  The amount of forgiveness of a PPP loan depends on the borrower’s payroll costs over an eight-week period; when does that eight-week period begin?
 
A:  The eight-week period begins on the date the lender makes the first disbursement of the PPP loan to the borrower. The lender must make the first disbursement of the loan no later than ten calendar days from the date of loan approval.  
 
Here is the link to the Treasury's FAQs:

We are working with a number of resources to try to get answers, and will get information out to you as soon as possible. Meanwhile, with all of this, the Fed has temporarily altered its 2018 growth restriction on Wells Fargo so the bank can make additional loans to small and mid-size business who need funding.

 We will continue to keep you informed as more information becomes available. . .watch for our daily updates, and check our website for previous ones.

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Annual Meeting Time:
Luse Gorman PC has provided some guidance on whether banks can hold their shareholder or member annual meetings virtually in light of health concerns of COVID-19. 
This alert addresses the legal and practical considerations for holding a virtual meeting. Or, click on link below:

NOTE:
All IBANYS meetings through July 1, 2020 have been POSTPONED.