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Perspectives on Recently Released SBA Review Procedures and Related PPP Lender Responsibilities
This blog is being posted on behalf of my colleague, Todd Sprang, principal in CLA’s financial institutions practice. On May 22, 2020, SBA and Treasury posted an interim final rule (“IFR”) to inform borrowers and lenders of SBA’s process for reviewing Paycheck Protection Program (“PPP”) loan applications and loan forgiveness applications. This IFR also provides […]
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Form 1502 Guidance Reveals Additional Clawbacks
This blog is being posted on behalf of my colleagues, Susan Sabo and Todd Sprang, principals in CLA’s financial institutions practice. On May 21, 2020, the SBA issued more guidance to lenders about the Paycheck Protection Program (PPP) Lender Processing Fee Payment and 1502 Reporting Process. Within the eight-page document, the SBA reiterates aspects of […]
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COVID-19 Related Loan Modifications
This blog is being posted on behalf of my colleagues, Susan Sabo and A.J. Eschle, principals in CLA’s financial institutions practice. As we enter the middle of May, many financial institutions are facing their next set of challenges in the COVID-19 environment – loan modifications. Financial institutions are now documenting the various types of COVID-19 related […]
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Financial Institutions Will Likely Not Qualify for Employee Retention Credit
The CARES Act includes an Employee Retention Credit designed to encourage businesses affected by the COVID-19 crisis to keep employees on their payroll by offering a refundable payroll tax credit of up to $5,000 per employee to help offset salary costs if certain criteria are met. The initial guidance about this new credit was limited, […]
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Savings Transaction Limitations Suspended
This blog is posted on behalf of Lyle Kolosik, Regulatory Compliance Manager. The Federal Reserve Board announced on Friday April 24th an interim final rule to amend Regulation D (Reserve Requirements of Depository Institutions) to delete the six-per-month limit on convenient transfers from the “savings deposit” definition. The interim final rule permits depository institutions to […]
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Stress Testing During a Stressful Pandemic? How Stress Testing Can Help
This blog is being posted on behalf of my colleague, Erica Crain, leader of CLA’s national credit risk services. It is no surprise stress testing would move to the top of the list during a global pandemic and economic crisis. If there is one thing present in most people and in most places right now, […]
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Video: Insights on the Main Street Lending Program
In today’s video, Todd Sprang, Susan Sabo, and Charlie Cameron from the CLA Financial Institution team discuss their insights into the Main Street Lending programs. Their discussion includes: How should financial institutions account for PPP loans? What are the impacts to capital from PPP Loans or the Liquidity Facility? What are the key aspects of the Main Street […]
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Accounting considerations for Financial Institutions that funded Payroll Protection Program (PPP) loans
Many lenders are participating in the PPP and loans are currently being disbursed to borrowers across the country. These loans contain complex accounting considerations such as deferred fees, guarantees, and loan forgiveness. Our summary of the primary accounting considerations financial institutions should consider over the life of the PPP loans is included below. Record the […]
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Federal Banking Agencies Provide Appraisal and Evaluation Deferrals to Expedite Lending
Federal banking agencies issued an interim final rule this week to temporarily defer real estate related appraisals and evaluations under the agencies’ interagency appraisal regulations. The rule provides temporary relief to allow regulated institutions to extend financing to creditworthy households and businesses quickly during the national emergency declared in connection with COVID-19.
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Regulatory Compliance Relief for Mortgage Servicing Loosens Timeframes but Doesn’t Eliminate Requirements
As COVID-19 continues to impact local economies, financial institutions are faced with the challenge of maintaining a consistent level of compliance with federal and state regulatory guidelines while helping their community and customers through this time of crisis. Though national regulators have offered flexibility in serving customers during this challenging time, the actions taken to date provide limited relief to institutions from a compliance perspective.
