April 22, 2020
IBANYS Weekly E-Newsletter
  • Visit our website at www.ibanys.net to review all our daily updates on COVID-19 beginning on March 16.
  • All in person IBANYS meetings including the annual convention have been postponed.
  • However, our webinars are still being offered; many address COVID-19 information for community banks. See information below regarding webinar offerings.
IBANYS wants to ensure we have the correct contact information on file for all community banks. We need your help and ask that you please complete the attached fillable form and return it to Linda Gregware lindag@ibanys.net. Thank you. Bank update request

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

I n order to keep New York community banks fully informed, IBANYS continues to work with a wide array of sources every day as additional details, programs, initiatives and updates become available. We talk consistently with the State Department of Financial Services, the SBA, OCC, FDIC, the Federal Reserve, Members of our New York Congressional Delegation & State Legislature, our partners at ICBA and a number of our fellow state community banking trade groups around the country. We will continue to keep you informed as more information becomes available. . . watch for our daily updates, and check our website for previous ones.

Since March 16, IBANYS has sent out daily (and often, more than once daily) updates to New York community banks with information on the impact coronavirus (COVID-19) is having on New York community banks -- including important legislative and regulatory developments and timely updates on the SBA's PPP. 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/

  • Yesterday, the U.S. Senate passed a nearly half-trillion dollar "stimulus 3.5" package that includes $310 billion to refill the coffers of the SBA's Paycheck Protection Program (PPP), and, it includes a $60 billion stasis for community banks: $30 billion for banks with assets under $10 billion, and another $30 billion for banks with assets of between $10 billion - $50 billion. The House is expected to pass the package tomorrow, and the president will sign it immediately.
  • Governor Cuomo is frustrated that the latest stimulus package left out direct federal assistance to state and local governments, and is warning that without federal aid the state will face significant cuts to such vital areas as education. He also has decided that the state will "reopen" its economy on a regional basis, depending on each area's specific circumstances.

Meanwhile, during these challenging times, IBANYS is also working hard to bring you suggestions on other revenue and income generating programs , products and services. We have sent out information on some, and in today's newsletter (see below) we also discuss options we hope you will take the time to consider.

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

I dentifying Alternative Program & Revenue Opportunities

Over the coming days and weeks, IBANYS will be working to provide a look at some alternative revenue generating and educational opportunities for community banks. We will be sharing information soon on a number of ideas and concepts we are currently discussing.

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Meanwhile, f or those of you who are seeking to fulfull their CPE credits, please note IBANYS offers an outstanding slate of webinars. Click here for the complete listing of topics and series including webinars on COVID-19. https://financialedinc.com/a/ibanys/category/live . Furthermore, we also are considering providing the opportunity for New York Community banks' CEOs and senior management teams to participate in online forums to share information, experiences and best practices during these times, and as we emerge from them. A number of other state trade groups have been utilizing the expertise of KPN Consulting, an organization we have used in our educational conferences throughout the years. KPN provides a platform to present educational programs and other forums to C- Suite level bankers. We'll keep you posted on these and a number of other possibilities that we are explorings.

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Interagency Webinar On PPP -- Thursday, April 23 At 11:00 AM
The federal financial institution regulatory agencies will host an interagency webinar on Join Small Business Administration (SBA) officials for an overview of how to apply to become a Paycheck Protection Program (PPP) lender. This presentation is for federally insured lenders, credit unions, and other lenders as defined by the CARES Act and will help you understand key milestones in the process such as:
  • What to expect as you apply
  • Receiving approval to become a lender 
  • Accessing SBA loan systems 
  • Originating loans
  • Entering applications into SBA systems
  • Important items to remember and where to find additional guidance as the Paycheck Protection Program evolves 
This webinar is primarily for lenders who are not currently SBA lenders but may have an interest in becoming a PPP lender.  However, there will be discussion on how the process functions and where to find additional guidance on the program .  There will be a brief Q&A session. Please note this webinar will provide an overview and not answer detailed policy considerations. To accommodate the participation of as many financial institutions as possible,  we ask each institution register no more than two representatives to attend the live session . We strongly encourage participants to use the webinar audio on their computer for the best experience. 

This webinar is scheduled for Thursday, April 23, 2020, at 11:00 a.m. ET. Registration is now open at  https://www.webcaster4.com/Webcast/Page/583/34462 . We encourage participants to submit questions in advance via email at  asktheregulators@stls.frb.org  . Webinar materials will be archived for future viewing.
IBANYS Preferred Partners & Associate Members
Additional COVID-19 Resources
Thursday | April 23rd | 2:00PM - 3:00PM EST
We will also be hosting a BSA/Security Discussion to see how you are handling various scenarios on the BSA and Security side. As COVID-19 restrictions are in place and may soon be partially lifted, how are you going to handle security concerns in your institutions? How are you handling suspicious transactions related to COVID-19 and what types of suspicious activity are you seeing?
Security Officers and BSA Officers will share their concerns, insights and what they are doing in their financial institutions. We will also have the FBI on the call. This is not a presentation, but a discussion. Please come prepared to discuss your thoughts, ideas and concerns!
Please send your questions and discussion topics to Nancy Lake at nlake@comlianceanchor.com as soon as possible! See you there !

Our bank leaders are faced with the immense task of planning for and managing safe branch lobby and office re-openings, all while pondering what the future may hold for branch banking after the pandemic. La Macchia Group has prepared 2 resources to help with both near and long-term decisions, giving you immediate ideas and solutions to consider in a succinct and visual  Branch Re-Opening Guide  and suggestions for strategic positioning and operational adaptations backed by consumer research in their  Thriving After COVID-19 Whitepaper
Freed Maxick, a Preferred Partner of IBANYS has a COVID-19 Response Center for banks and has provided for the following link for resources that banks may utilize during the pandemic.
COVID-19 Response Center

COVID-19 Free Marketing Resources
We have crafted several informational blogs for you to be able to share with your members to navigate these unfamiliar times. Find information regarding relief programs to help account holders, how to support small businesses through this time, and what account holders want to hear most right now.  More to come here, so keep checking in with us.  

With limited time and resources to dedicate to crafting communications, our team has compiled an array of digital assets. These include sample social post copy, downloadable images to utilize on various social media platforms or on your website, and helpful tips and resource links. The   Resource Center   is designed to help take one thing off their plate and aid financial institutions in communicating with account holders during this time. Share the  Resource Center  w ith your members today for access to free downloadable assets!

Albany Update

New York State Attorney General Letitia James announced last weekend that New York banks, creditors and debt collectors cannot garnish stimulus payments from the CARES Act during the coronavirus crisis, and that any institutions that did so would face "swift legal action" from her office. IBANYS has pointed out that many people have already received payment through NYS banks, and inquired how banks are supposed to follow guidelines that were placed 4 days after stimulus payments were received? ICBA has informed us that it is participating in a Joint Trades Working Group that meets twice a week, and the group is reviewing the AG’s guidance. ICBA also sent to Senators Brown (D-OH) and Warren (D-MA) on EIP funds and garnishment, as well as a letter signed by several other trade groups on the same. Here is the Attorney General's announcement:

Governor Cuomo announced that New York State will reopen its economy on a regional basis, guided by specific circumstances in each area . He said Lt. Gov. Hochul will oversee the transition in Western New York/Erie County region, and former Lt. Gov. Duffy will coordinate plans in the Rochester area.

 A new report by State Comptroller DiNapoli says the economic crisis created by the coronavirus pandemic will take a multi-year toll on New York’s finances , with delayed tax payments this month alone costing the state as much as $10 billion. The report projects aftershocks stretching in to the next fiscal years. The state’s “rainy day” fund of cash reserves has been strengthened in recent years, with $678 million added. DiNapoli warned against steep borrowing to offset the loss of revenue. “Tax revenues will be substantially lower in the near term because of the pandemic, and likely well beyond,” he said. “The state should minimize long-term costs from any new debt and commit to building up our rainy day reserves. The road ahead is a challenging one and will require a long-term strategy.” The Governor strongly urged the federal government to provide direct relief to states during the pandemic, and was frustrated the newest federal stimulus bill passed by the Senate left out direct funding to the state. “They again say, ‘Don’t worry, next bill is going to have state funding,’ Cuomo said about New York’s federal delegation. "I can’t do a budget on don’t worry next time especially after that promise has been made and repeatedly broken.” He warned without the aid, the state will need to make major cuts to the budget, including funding to schools, local governments and health care.
Washington Update
Independent Community Bankers of America (ICBA) President and CEO Rebeca Romero Rainey released the following statement after the Senate passed bipartisan legislation that includes an additional $310 billion to restart the Paycheck Protection Program and an ICBA-advocated allocation for community banks.

  • “ICBA thanks the Senate for passing this critical legislation extending the Paycheck Protection Program and dedicating at least $60 billion of the funds to community financial institutions.Reflecting ICBA's repeated calls to ensure community bank access to the program, the legislation will allocate at least $30 billion for institutions under $10 billion in assets and another $30 billion for those with between $10 billion and $50 billion in assets. These funds are sorely needed by small-business customers in urban, suburban and rural communities.With the bill headed to the House for a final vote later this week, ICBA continues calling on Congress to immediately approve the additional PPP funding and community bank allocation. Meanwhile, ICBA strongly urges the Treasury Department and Small Business Administration to begin preparing to administer the community bank funding allocation as soon as possible so we can continue to deploy these funds to those who need it most. Community banks look forward to continuing to utilize the PPP as we stand hand in hand with the Main Street small businesses we serve.”

The focus in Washington will now move toward "what's next" in addressing the coronavirus economic stimulus and recovery effort under a "Phase Four" package.
  • Senate Majority Leader McConnell said he will not begin considering another phase of coronavirus stimulus until the Senate is back in session: "We need to see how things are working, see what needs to be corrected, and I do think that the next time we pass a coronavirus rescue bill we need to have everyone here and everyone engaged. . .We've allocated a stunning amount of money -- $2.2 trillion -- knowing full well that that probably wouldn't be enough. ... I think it's also time to begin to think about the amount of debt that we're adding to our country and the future impact of that."
  • Democrats have identified a number of funding priorities for the next package, including federal assistance for states and local governments, mail-in voting, hazard pay for health care workers and the Postal Service. Speaker Pelosi and Senate Minority Leader Schumer said: "We will advance CARES 2, which must be transformative and far-reaching." 
  • Secretary of Treasury Mnuchin have said a fourth stimulus bill will most likely be all the U.S. needs if economy reopens, and echoed the president's list of priorities in such legislation: Infrastructure (roads, bridges broadband), incentives for restaurants, sports, entertainment, payroll tax cut and funding for states.

  • IBANYS continues to reach out to state and federal legislators during the ongoing crisis. This week we once again participated in conference calls with Rep. Tom Reed (R-Western NY/Southern Tier), who serves on House Ways & Means and co-chairs the bipartisan "problem solvers" congressional coalition, and with House Financial Services Committee member (and chair of the Financial Services Subcommittee) Greg Meeks (D-Queens), who was also joined by NYS Senate Banks Committee Chairman James Sanders (D-Queens).
ICBA Updates
ICBA and other groups called on the Consumer Financial Protection Bureau to delay its upcoming Qualified Mortgage rulemaking and extend a policy exempting Fannie Mae and Freddie Mac mortgage loans from parts of the QM rule. ICBA asked for an extension of the government-sponsored enterprises' QM "patch" until the later of January 2022 or one year from the finalization of any proposed rule following an appropriate notice and comment period. In its letter, ICBA said the CFPB's proposed timeline for finalizing a new QM definition before January 2021 would introduce uncertainty into an already-stressed housing finance system and would distract from the response to the COVID-19 emergency.   https://www.icba.org/docs/default-source/icba/advocacy-documents/letters-to-regulators/20-04-20_jointletterqm.pdf?sfvrsn=259a2a17_0&utm_source=informz&utm_medium=email&utm_campaign=informz&_zs=njOgU&_zl=EWS42

For a complete list of webinars click the button.