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New tool for small businesses from SBA

On Friday the SBA announced the launch of a free dedicated online tool for small businesses and non-profits to be matched with Community Development Financial Institutions, Minority Depository Institutions, Certified Development Companies, Farm Credit System lenders, Microlenders, as well as traditional smaller asset size lenders in the Paycheck Protection Program (PPP).

The SBA Lender Match tool is an additional resource for pandemic-affected small businesses who have not applied for or received an approved PPP loan to connect with lenders. Within two business days after entering their information into the Lender Match platform, a borrower receives an email from lenders who have been matched with them. The borrower can see lenders’ requests for them to begin an application. Borrowers are then able to begin the application process directly from the email they receive. Lender Match does not accept Economic Injury Disaster Loan applications.


FDIC Enforcement Actions Manual updated

The FDIC has issued FIL-61-2020 announcing the update of its Formal and Informal Enforcement Actions Manual for the assessment of mandatory civil money penalties (CMPs) for certain pattern and practice violations of the National Flood Insurance Act of 1968. The manual provides direction for FDIC staff related to the work needed to pursue formal and informal enforcement actions. It is also intended to support the work of field office, regional office, and Washington office staff involved in processing and monitoring enforcement actions.


June 2020 SCOOS

The Federal Reserve has posted the June 2020 Senior Credit Officer Opinion Survey on Dealer Financing Terms (SCOOS), a quarterly survey providing information about the availability and terms of credit in securities financing and over-the counter derivatives markets. The SCOOS is modeled after the long-established Senior Loan Officer Opinion Survey on Bank Lending Practices, which provides qualitative information about changes in supply and demand for loans to households and businesses at commercial banks.


OFAC targets sanctions evasion network

Yesterday, OFAC designated three individuals and eight foreign entities, and identified two vessels as blocked property for their activities in or associated with a network attempting to evade United States sanctions on Venezuela’s oil sector.

For identification of those targeted by OFAC, see BankersOnline's OFAC Update.


FEMA suspending communities from flood program today

In what appears to be another "catch-up" on required publication of community suspensions from the National Flood Insurance Program, FEMA has published at 85 FR 37019 in today's Federal Register a notice it has scheduled suspensions of communities in Idaho, Iowa, Michigan, North Carolina, Texas, Utah, and Washington today, June 19, 2020, for noncompliance with the floodplain management requirements of the program:

  • Idaho: Garden City, Meridian, and unincorporated areas of Ada County
  • Iowa: Charles City, Floyd, Leland, Nora Springs, Rockford, Russ, Scarville, Thompson, and unincorporated areas of Floyd and Winnebago Counties
  • Michigan: Bedford, Berlin, Erie, Estral Beach, Frenchtown, LaSalle, Luna Pier, and Monroe
  • North Carolina: Alliance, Bath, Bayboro, Bridgeton, Chocowinity, Emerald Isle, Greenville, Grimesland, Havelock, Kill Devil Hills, Mesic, Minnesott Beach, Nags Head, New Bern, North Topsail Beach, Oriental, River Bend, Southern Shores, Stonewall, Swansboro, Washington, and unincorporated areas of Carteret, Craven, Currituck, Hyde, Pamlico, and Washington Counties
  • Texas: Unincorporated areas of Denton County
  • Utah: Alpine, American Fork, Bluffdale, Genola, Lehi, Orem, Payson, Salem, Saratoga Springs, Spanish Fork, Springville, and unincorporated areas of Utah County
  • Washington: Bothell, Brier, Bucoda, Darrington, Edmonds, Everett, Gold Bar, Index, Lake Stevens, Lynwood, Marysville, Mill Creek, Monroe, Mountlake Terrace, Mukilteo, Stanwood, Sultan, Tenino, and unincorporated areas of Snohomish and Thurston Counties

If a designated community completed the steps to return to compliance with the floodplain requirements before today, it will not be suspended. Lenders should verify the status of any of the listed communities in which they may be taking real estate as security for a loan before proceeding with the transaction.


OCC: Banks' response to COVID-19 governed by federal standards

OCC Bulletin 2020-62 reminds national banks, federal savings associations, and federal branches and agencies of foreign banks that, even though federal, state, and local governments have taken many actions to respond to the economic disruption caused by the spread of COVID-19, OCC-supervised institutions are governed primarily by uniform federal standards that preempt state law. The Bulletin lists types of state laws and regulations that do not apply to OCC-supervised institutions:

  • State law limitations on terms of credit, disbursements and repayments; and processing, origination, and servicing mortgages
  • State law and regulations on interest and non-interest fees
  • State actions limiting banks' ability to foreclose on defaulted loans and take possession of collateral beyond what is provided for in the CARES Act
  • Attempts to require banks to report to state and local officials

The OCC recommends that banks it supervises should consult with legal counsel to determine the applicability of any particular state or local law. Banks and their counsel may also contact the OCC with questions.


OCC explains how to use LTD ratios

The OCC has issued Bulletin 2020-61 to inform national banks about how the host loan-to-deposit (LTD) ratios issued by the OCC, Fed, and the FDIC on June 2, 2020, are used to determine compliance with section 109 of the Riegle–Neal Interstate Banking and Branching Efficiency Act of 1994 (IBBEA).


PPP forgiveness application updates

The Small Business Administration has posted a revised, borrower-friendly Paycheck Protection Program loan forgiveness application to implement the PPP Flexibility Act. The SBA also released a new EZ version of the application for borrowers who:

  • Are self-employed and have no employees; OR
  • Did not reduce the salaries or wages of their employees by more than 25%, and did not reduce the number or hours of their employees; OR
  • Experienced reductions in business activity as a result of health directives related to COVID-19, and did not reduce the salaries or wages of their employees by more than 25%.

Both applications give borrowers the option of using the original 8-week covered period (if their loan was made before June 5, 2020) or an extended 24-week covered period.


Enterprises extend foreclosure/eviction moratorium

Fannie Mae and Freddie Mac will extend their single-family moratorium on foreclosures and evictions until at least August 31, 2020, according to an announcement from the Federal Housing Finance Agency. The moratorium, which was set to expire at the end of June, applies to Enterprise-backed, single-family mortgages only.


$40M in housing counseling grants awarded

The Department of Housing and Urban Development has announced the award of nearly $40 million in housing counseling grants to help over one million individuals and families access HUD-approved housing counseling to help them avoid foreclosure and make more informed homebuying and rental choices. The grants will directly support the housing counseling services provided by 204 HUD-approved local housing counseling agencies, national and regional organizations, and state housing finance agencies (SHFAs). Recipients of these grants competed through the Department's two-year (FY 2019 and 2020) Comprehensive Housing Counseling Grant Program Notice of Funding Availability (NOFA) published May 24, 2019.


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