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Your guide to financial institution regulatory deadline extensions.
As a result of the impacts of COVID-19, financial institution regulators have been working to grant extensions to many of the regulatory deadlines that private financial institutions must meet. Below is a summary of these extensions and links to the underlying regulatory guidance. We suggest financial institutions work with their service providers to ensure all […]
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Paycheck Protection Program- Additional Help Available for Stressed Lenders
Because many financial institutions are experiencing strong interest from current borrowers as well as potential new borrowers to their institution, they are evaluating the need and benefit of seeking the assistance of agents to help ensure more accurate data submission, ensure program compliance, and improve timeliness of application submissions. CLA is here to help financial institutions through the PPP process.
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All Insured Depository Institutions Should Strongly Consider Becoming PPP Lenders
Based on documents released from the Treasury on March 31, 2020, we now believe that all insured depository institutions will not only be eligible to participate as lenders in the Paycheck Protection Program (“PPP”), but will be quickly accepted by the SBA with a very limited approval process. The process may be as simple as […]
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CECL and the CARES Act: What does it mean for your private financial institution?
Financial institutions are facing numerous challenges as the economy and society continue to react to the effects of COVID-19. When the CARES Act was passed last week, it created a need for interpretation and logical implementation. In section 4014, of title IV, most financial institutions took note of the temporary relief from current expected credit […]
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Our perspectives on 2020 interagency loan modification and TDR guidance
In the current environment, many institutions are seeking ways to assist borrowers impacted by the economic distress resulting from the COVID-19 pandemic. On March 22, 2020, Interagency Statement on Loan Modifications and Reporting for Financial Institutions Working with Customers Affected by the Coronavirus, was released. We noted this interagency statement seeks to provide relief from […]
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Health Check: Your Loan Portfolio and the Current Economic Environment
Whether you are a lender or employ lenders, you may be asking yourself “Where do I begin?” Start with these best practices, designed to help financial institutions manage loan portfolios during this difficult time.
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Amendment to Military Lending Act May Present New Opportunities
On February 28th, the Department of Defense (“DoD”) made an additional amendment to its interpretive rule for the Military Lending Act (the “MLA”). The MLA’s provisions have been challenging institutions since they originally went into effect in 2016 and have left many institutions struggling to make sense of the DoD’s guidance but the recent change presents new opportunities.
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HUD Provides 30-Day Extension for All Financial Statement Submissions
On March 13, 2020, the United States Department of Housing and Urban Development (HUD) issued approval for a 30-day extension for all financial statements having a due date of March 31, 2020 due to the business disruptions caused by the COVID-19 virus.
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Same Loans, Different Cycle: A Look at Agricultural Lending
As seen in 2019, challenges in the farm economy go deeper than farm income. Balance sheets indicate unfavorable trends such as higher debt and lower working capital. As such, the regulators have reiterated the importance of strong underwriting and credit administration practices for banks and other financial institutions lending to farmers and other agriculture interests.
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S Corporations Should Monitor and Track Shareholder Deaths
As shareholder groups continue to age, we are seeing more S Corporation banks encountering difficult to navigate issues involving shareholder deaths. S Corporations should remain vigilant to ensure that they don’t put their S Election at risk or cause headaches for the bank or its shareholders. Estates as Shareholders An estate is an eligible S […]