COVID-19 Roundtable –

Creating a COVID-19 Policy

April 29, 2020

PRESENTED BY:

JENNIFER CLIBER SMITH, CRCM, CLIBER

COMPLIANCE, LLC

GARY IORFIDO, JD, CCBCO, COMPLIANCE ANCHOR® CONSULTANT

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Note: This session is being recorded.4/29/2020 2

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4/29/2020 3

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4/29/2020 4

Our Presenter: Jennifer

Cliber Smith

Jennifer Cliber Smith has been in Banking Compliance for more than 20 years. Having worked in financial institutions of all sizes both as a staff member and as a consultant, she has a comprehensive knowledge of the industry. Jennifer has spoken at many events across the country including the Mid-Atlantic Regulatory Conference. She is a contributor and proofreader for the ABA CRCM Exam Manual and has worked as an instructor at the Mid Atlantic Bank Compliance Conference. As a life long learner, Jennifer’s commitment to education is clear, as she frequently attends webinar’s, seminar’s, and conferences to further her knowledge.

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Reg. D Transaction Limits Removed

The Federal Reserve also published a series of Q&A’s that addressed a number of topics as follows:• Institutions may suspend enforcement of the six-transfer

limit but are not required to do so

• Institutions may suspend enforcement of the six-transfer limit on a temporary basis

• Institutions are not required to change the name of any accounts or products that have the words “savings” or “savings deposit” in the name of the account or product

• The “reservation of right” continues to be a part of the definition of “savings deposit” under the interim final rule

• The interim final rule does not provide any guidance on amending account agreements for those institutions that choose to suspend the transfer limit

Reg. D FAQ's

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Reg. D Transaction Limits Removed

• The termination of the six-transfer limit doesn’t impact the policies or account agreements of institutions that charge fees to their customers for transfers and withdrawals in excess of the six-transfer limit

• Institutions may report these accounts as a “transaction account” on its FR 2900 reports or continue to report the account as a “savings deposit”

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Reg. D Things to Think About

Things to think about if you are going to eliminate the 6 transfer limit:• MMA generally have check writing ability, so they are now

able to function just like a checking account o Potential for substantial increase in check activity

• MMA’s and savings generally pay a higher rate of interesto Check Reg. DD disclosure or account agreement to see if they

have disclosed these as variable interest rate and how the rate is determined, how frequent can the rate change, etc.

• Will the elimination of the transfer limits be temporary or permanento Reg DD 30 day notice to reinstate the limit at a later time

• Will you waive fees on a case by case basis if you are not going to eliminate the limit

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Reg. D Things to Think About

Will you charge for transfers over a certain number if you eliminate the limit?• Remember: this would necessitate a 30 day notice

Will you continue to send the notices of limit violations even if you don’t lift the limit restrictions

Do you need to continue monitoring excess transactions?

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COVID-19 Policy Considerations

A single reference will eliminate the need for multiple policy revisions – and revisions if the policy is changed back

A single document provides a succinct reference to all actions taken in response to this national emergency

Actions requiring Board approval can be so-noted in the policy or reference to Board minutes made

Should the Board review all actions related to COVID-19? The COVID-19 Policy/document could be an Agenda item.

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COVID-19 Policy Considerations

List each cost center/area in the “COVID-19 Policy” to ensure all actions are documented. • List specific actions taken and associated dates.

Include related webinars, call information, trade group information, slide decks, etc. with dates.

Consider appointing someone to provide the details for each area.

Provide an outline to be completed now with revisions continually added. • Include in the outline compliance, customer service, local,

state and federal mandates, etc. – all considerations that entered into the decision.

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COVID-19 Policy Considerations

Include changes to decisions and why. If there was a decision made not to make a change, discuss the reasoning. Remember that many decisions had to be made for the moment due to new guidance being issued constantly.

Consider a time-line of events, regulatory issuances, etc.

Include all notices mailed, posted, on the website, via social media, etc.

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COVID-19 Policy Considerations

Deposit Area• Waiving of Fees – requiring Reg DD 30-day notice to

reinstate if waived for all vs. case-by-case, justification for case-by-case, OD/NSF, Daily OD, Foreign ATM, Service Charges

• Reg D Elimination of Reserves and Savings Limits• New Products• Stimulus Check direct deposits – offsetting overdrafts,

mobile deposit, debit card• Stimulus Check cashing – deceased payees, noncustomers

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COVID-19 Policy Considerations

HR• Leave procedures, FMLA, Families First Coronavirus

Response Act, • Employee testing, Positive result procedures, Memos,

Notices, • Employee protection Devices required/provided

Marketing

• Signs, Website, Letters, Notices, Research

Sanitizing Protocol, Masks, Social DistancingBranch Hours and Accommodations• Each location’s hours for lobbies, Drive-Up, appointments

for new accounts, loans, etc., other accommodations for new accounts, loans, etc.

• Re-opening will need to be addressed.

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COVID-19 POLICY CONSIDERATIONS

BSA CIP• Identifying customers wearing masks• Opening accounts not-in-person• Remote notary, electronic signature without E-Sign, wet-

signature verification • PPP loans & accounts for noncustomers, BO for PPP for

existing customers• Cashing checks for noncustomers• Suspicious Activity Red Flags re: COVID-19, stimulus checks• PPP, Fraud Alerts, SAR filings with COVID-19 coding• NO SAR Needed file related to COVID-19• States extending ID expiration dates, other expired ID

treatment• CIP exception documentation and review• Delayed reporting

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COVID-19 Policy Considerations

Payment Deferrals – Each product in each area• Reg B - How offered (mailing, upon request only, upon

request and when past due, other)• Deferral program options, underwriting vs. attestation,

request documentation, Balloon payment vs extension vs Refinance

• HMDA• Appraisals• Flood re-certs and Notices• What happens to deferred P&I and Escrow; Escrow analysis

shortfall

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COVID-19 Policy Considerations

Payment Deferrals – Each product in each area (Cont.)• Notice prior to Balloon/end of deferral period and RESPA

LLM Notices – what if there is a balloon at the end of the deferral?

• TDR• Open End Lines – Frozen?• Products ceased to be offered explanation; underwriting

changes

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COVID-19 Policy Considerations

PPP• Broker vs Lender• Order of taking, processing, verifying, confirming, submitting,

and funding applications, continuing to take applications when funding ran out, continuing to process and confirm applications while waiting for additional funding

• PPP loan disbursement – opening accounts for this purpose not-in-person, ongoing guidance

• Notices, Forgiveness determination, calculation, and documentation

• Reg O, Approval authority• Staffing responsibilities, Hours, Checklist versions• Calculators, Volume - $, #, industries/businesses, business

size, # of employees, ranges, minority-owned businesses & in LTM CT, nonprofit details, etc., CRA

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COVID-19 Policy Considerations

New Loans• Appraisal Requirement changes• Underwriting changes• Short Term Small Loan New Products• Stimulus Payment advances• RESPA Servicing• Overdraft Line increases (?)• Credit Card increases (?)

ComplaintsFed Funding Loans with NFIP flood insurance policies with expiration dates between 2-13-2020 and 6-30-2020 - how will the extended grace period affect notices and force-placement

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COVID-19 Policy Considerations

Internal Audit • CIP, Payment Deferral and Modifications on system• PPP & unforgiven loans, CRA• Reg DD,• Appraisals• Reg B timing and equal treatment• RESPA• TDR

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COVID-19 Policy Q&A

There has been a lot of discussion about a COVID 19 policy. Why wouldn’t we just use our Pandemic policy and update that where it’s needed instead of a whole new policy?• Due to the specific nature and dates of some of the policy

and procedure changes (PPP, masks) the decisions made need to reflect the reasoning, implementation and ending dates, etc. A Pandemic Policy should not get that specific. However, the issues raised may trigger expanded topics in the broader Policy.

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PPP Loans Extended

An additional $320 billion was appropriated for PPP loans:• A minimum of $30 billion will be set aside for community

development financial institutions, banks and credit unions with less than $10 billion in assets

• Another $30 billion at least will go to banks and credit unions with assets between $10 billion and $50 billion

• Additional $60 billion was added to the EIDL program

The SBA also:• Instituted a maximum dollar amount at 10 percent PPP

funding authority that any lending institution will be able to originate, exclusive of the additional $60 billion preserved for smaller lenders

• Pacing the number of loans processed in the E-Tran system, and will work to ensure that lenders access PPP funds based on asset size and applications are considered on a first-come, first-serve basis

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PPP Loan Applications

The SBA resumed accepting PPP loan applications at 10:30 a.m. (Eastern time) on Monday, April 27th

PPP applications received prior to April 25th can be processed based on guidance in effect prior to that date• Applications received after that date must comply with

new Treasury Department and SBA guidance

This guidance is consistent with question No. 17 in Treasury's frequently asked questions document, which states that borrowers and lenders may rely on the laws, rules, and guidance available at the time of the relevant application

4/29/2020 23

SBA Guidance

The SBA has posted the following additional guidance:• The FAQ’s were updated adding questions 32-36 clarifying

that:o Housing allowances count toward payroll costs

o Lenders may use IRS regulations to determine whether an employee's principal place of residence is in the U.S

o Farmers, ranchers, other agricultural producers and ag and other forms of cooperatives are eligible for PPP loans, provided they meet the other eligibility requirements

o Calculating the total number of employees for determining eligibility and loan forgivenessFAQ’s

• The "How to Calculate Maximum Loan Amounts - By Business Type“ guidance was updated with detailed loan amount instructions for self-employed, farmers, S corporations, C corporations, LLCs, and nonprofits

Maximum Loans by Business Type

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SBA Guidance

• An interim final rule clarifying several issues around borrower eligibility for the PPP as well as incorporating several previously issued FAQs

• This rule states:o A business that is otherwise eligible for a PPP Loan is not

rendered ineligible due to its receipt of legal gaming revenues

o Hedge funds and private equity firms are ineligible for PPP loans, and SBA affiliation rules apply to companies held in private equity portfolios

• This interim final rule supplements the interim final rules previously posted on April 3, 2020 and April 14, 2020

Interim Final Rule

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SBA Guidance

• Paycheck Protection Program –Additional Criterion for Seasonal Employers

Seasonal Employees

• SBA issued a notice with procedural guidance for PPP participation sales

Guidance on Participation Sales

• XML File Submission Process for Paycheck Protection Program (PPP)

XML File Submission

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PPP Loans and FHLB Loans

The Federal Housing Finance Agency has announced that Federal Home Loan Banks can accept Paycheck Protection Program loans as collateral when making advances to their members

FHLBanks can accept PPP loans guaranteed by the Small Business Administration provided the FHLBanks comply with certain safety and soundness requirements

FHFA Guidance

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FDIC

The FDIC has posted a series of Frequently Asked Questions (FAQs) on the Small Business Administration’s Paycheck Protection Program – as of April 25, 2020

FDIC's FAQ's

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OCC and CRA

The OCC issued Bulletin 2020-45 to clarify its statement in OCC Bulletin 2020-44• Bulletin 2020-44 has been rescinded

While not requiring banks to obtain or maintain information beyond what exists in the ordinary course of business: • The OCC is encouraging banks providing loans under the

SBA PPP to prudently document their implementation and lending decisions

• Additionally, banks are encouraged to identify and track the PPP loans made to small business borrowers that have annual revenues of $1 million or less and are located in low-to moderate-income areas

Bulletin 2020-45

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AICPA

The AICPA has recommended that an accountant for a small business applying for a PPP loan “contact the lender prior to offering assistance and performing advisory work to the client. This will ensure the lender has agreed to compensate the CPA firm for its service.”

AICPA also recommended that should the lender agree to pay an agency fee to the CPA firm, as allowed for by the CARES Act, that the relationship be documented and disclosed to the applicant. “• Documentation could take the form of a letter, sent by the

CPA to his/her client, that describes the services to be performed by the CPA firm to assist and advise the client on the appropriate completion of the application,” AICPA said.

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Stimulus Payments - Checks

The Secret Service released a notice with tips for identifying a legitimate, government-issued check

The notice pointed out several markings and security features—including the Treasury seal, the use of bleeding ink, ultraviolet overprinting, microprinting and the location of the words “Economic Impact Payment President Donald J. Trump”—that signal that a check is legitimate

The notice also directs individuals, banks and others to report suspected check fraud to local law enforcement, a Secret Service Field Office, the Treasury Department, the Internet Crime Complaint Center and others

Secret Service Notice

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Stimulus Payments

Treasury and the IRS have announced significant enhancements to the "Get My Payment" app. to ensure more Americans can get their money fast and track its delivery

Press Release

The IRS also published a series of frequently asked question on a range of topics on the stimulus payments including eligibility, how to request an EIP, how EIPs are calculated, receiving payments and more

FAQ’s

The ABA created a new webpage where consumers can find a partial list of institutions offering accounts that can be opened online and funded with an EIP

ABA Webpage

4/29/2020 32

FHFA – Repayment Terms

The Federal Housing Finance Agency (FHFA) has reiterated that borrowers in forbearance with a Fannie Mae or Freddie Mac (the Enterprises)-backed mortgage are not required to repay the missed payments in one lump sum

While today's statement only covers Fannie Mae and Freddie Mac mortgages, FHFA Director Mark Calabria encouraged all mortgage lenders to adopt a similar approach

FHFA Release

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CFPB-Mortgage Servicing

The CFPB has added information to its "Guide to coronavirus mortgage relief options" article, including updated mortgage relief forbearance options

Guide

The CFPB also outlined practices in new Bulletin 2020-02 to provide mortgage servicers clarity, facilitate compliance, and prevent harm to consumers during the transfer of residential mortgages

The Bureau stated that, because consumers do not have a choice with respect to the transfer of servicing, compliance with regulatory requirements is especially important in risk mitigation and preventing consumer harm

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CFPB-Mortgage Servicing

Examples of practices that servicers may consider as contributing to compliance include:• Developing a servicing transfer plan that includes a

communications plan, testing plan (for system conversion), a timeline with key milestones and an escalation plan for potential problems

• Engaging in quality control work after a transfer of preliminary data to validate that the data on the transferee's system matches the data submitted by the transferor

• Determining servicing responsibilities for legacy accounts including tax reporting, credit bureau reporting and other questions that may arise

• Conducting a post-transfer review or de-brief to determine effectiveness of the transfer plan and whether any gaps have arisen that require resolution

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CFPB-Mortgage Servicing

• Monitoring consumer complaints and loss mitigation performance metrics. The CFPB emphasizes the importance of post-transfer monitoring to ensure that transferred data is complete, accurate and functional for the transferee

• Identifying any loans in default, active foreclosure and bankruptcy or any forbearance agreements entered in with the borrower. Where applicable include loss mitigation activity for each loan, including status and notes pertaining to the loss mitigation action

Bulletin 2020-02

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NCUA

The NCUA Board approved:• A final rule to increase the residential appraisal threshold

from $250,000 to $400,000

• An interim final rule to temporarily allow credit unions to defer appraisals and written estimates of market value for up to 120 days after the closing of a loano This flexibility will expire on December 31, 2020.

Both rules will become effective upon publication in the Federal Register

Rules

The NCUA also updated Letter 20-CU-06 with additional with additional information from the SBA on how to become a PPP Lender

20-CU-06

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ABA

Two recent ABA podcasts on COVID-19 contamination:• A podcast on managing COVID-19 transmission risk in a

banking environment

• An analysis by ABA's Paul Benda of surface contamination risks from COVID-19

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POLLS

How many institutions will be temporarily suspending the six transfer limit?

If suspending temporarily, for how long?

If a customer tells you that they are not comfortable removing their masks, what will you do?

How will you verify the identify of a customer wearing a mask?

4/29/2020 39

Regulators

Regulators General Covid-19 Information Pages• OCC Information Page

• FDIC Information Page

• FDIC Information for Small Business Lenders

• Federal Reserve Information Page

• Federal Reserve Services• NCUA Information Page

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SBA GuidanceSBA Guidance – Coronavirus (COVID-19): Small Business Guidance & Loan Resources• Form 3506

• PPP Borrower Application

• SBA FAQ’s

• SBA faith-based organization FAQ

• Guidance on affiliation rules

• SBA Note

• Lender Portal

• Interim Final Rule: Business Loan Program Temporary Changes; Paycheck Protection Program

• Interim Final Rule: Business Loan Program Temporary Changes; Paycheck Protection Program – Additional Eligibility Criteria and Requirements for Certain Pledges of Loans

4/29/2020 41

SBA Guidance

• Maximum Loans by Business Type

• Interim Final Rule - Business Loan Program Temporary Changes; Paycheck Protection Program

• Procedural Guidance for PPP participation sales

• XML File Submission Process for Paycheck Protection Program (PPP)

4/29/2020 42

Treasury and CDIA Guidance

Treasury Cares• Treasury’s information on Assistance for Small Businesses

• Treasury PPP Q&A

• Treasury Paycheck Protection Program (PPP) Information Sheet – Lenders

• Paycheck Protection Program – Additional Criterion for Seasonal Employers

CDIA Resources• FAQ 44 Deferred Loans

• FAQ 45 Accounts in Forbearance

• FQ 58 Account Affected by a Natural or Declared Disaster

4/29/2020 43

Federal Issuances

April 27, 2020 OCC PPP Loans and CRA

April 24, 2020 CFPB Compliance Bulletin and Policy Guidance: Handling of Information and

April 25, 2020 FDIC FDIC (FAQs) on SBA Paycheck Protection Program

April 23, 2020 FHFA PPP Loans as Collateral for FHLBank Advances

April 20, 2020 Secret Service

Tips for identifying a legitimate, government-issued check

April 14, 2020 Joint Agencies

Interim Final Rule - Real Estate AppraisalsInteragency Statement On Appraisals and Evaluations

April 14, 2020 NCUA20-RISK-01

Cybersecurity Considerations for Remote Work

April 13, 2020 CFPB Treatment of Pandemic Relief Payments Under Regulation E

4/29/2020 44

Federal Issuances

April 8, 2020 NCUALetter

20-CU-07

Summary of the CARES Act

April 7, 2020 joint Revised Interagency Statement on Loan Modifications by Financial Institutions Working with Customers Affected by the Coronavirus (FDIC Moved FIL-22-2020 to inactive status)

April 3, 2020 Joint Joint Statement on Supervisory and Enforcement Practices Regarding the Mortgage

April 3, 2020 CFPB The Bureau’s Mortgage Servicing Rules

April 2, 2020 OCC2020-31FDIC FIL–33-2020

Small Business Administration Lending: New Programs for Small Business Relief

April 1, 2020 CFPB Statement on Supervisory and Enforcement Practices Regarding the FCRA

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Federal Issuances

March 2020 NCUA Letter

20-CU-06

SBA Loan Programs to Help Small Businesses and Members (UPDATED)

Updated March 31, 2020

OCC Coronavirus Disease 2019 (COVID-19) Frequently Asked Questions for National Banks and Federal Savings Associations

March 29,2020 FEMA FEMA Extends Grace Period

March 27, 2020 FDICFIL-29-2020

FDIC employees in all FDIC facilities areengaging in mandatory telework through at least April 12

Updated March 27, 2020

CFPB CFPB Resources for Consumers

March 27, 2020 FDICFIL-30-2020

Additional information and guidance to insured depository institutions subject to part 363 Annual Reports

March 2020 NCUA Offsite Examination and Supervision Approach

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Federal Issuances

March 26, 2020 Fed. Federal Reserve offers regulatory reporting relief to small financial institutions affected by the coronavirus

March 26, 2020 FDICFIL-27-2020

Temporary alternative procedures for sending supervision-related mail and email to FDIC

March 26, 2020 CFPB The CFPB postpones some data collections from on Bureau-related rules

March 26, 2020 Joint Statement encouraging financial institutions to offer responsible small-dollar loans to consumers and small businesses

March 25, 2020 Joint 30-day extension for institutions for the Call Report due on March 31

March 25, 2020 NCUA Frequently Asked Questions Regarding COVID-19, NCUA and Credit Union Operations

March 20, 2020 NCUA NCUA Announces Annual Meeting Flexibility

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Federal Issuances

March 19, 2020 Fed., OCC & FDIC

Joint Statement on CRA Consideration for Activities in Response to the COVID-19

March 18, 2020 FDIC The FDIC has provided two sets of frequently asked questions, one for financial institutions and one for consumers

March 16, 2020 NCUA Letter

20-CU-02

NCUA Actions Related to COVID-19

March 15, 2020 FED. Elimination of Reserve Requirements - FAQ's

March 13, 2020 OCC2020-15

Pandemic Planning: Working With Customers Affected by Coronavirus and Regulatory Assistance

March 9, 2020 Joint Agencies Encourage Financial Institutions to Meet Financial Needs of Customers and Members Affected by Coronavirus

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Fannie Freddie

Updated April 14, 2020

Fannie LL-2020-04

Temporary guidance on appraisal requirements and completion reports

Updated April 8, 2020

FannieLL-2020-02

Freddie2020-04

Credit reporting requirementsForbearance plansLoan modificationsForeclosure sale moratorium

April 8, 2020 Freddie 2020-05

Temporary Servicing Guidance Related to COVID-19

April 1, 2020 Mortgagee letter

2020-06

FHA’s Loss Mitigation Options for Single Family Borrowers Affected by the COVID-19 National Emergency

4/29/2020 49

Fannie Freddie

Updated March 31,

2020

FannieLL-2020-03

Provides reminders and temporary guidance on these loan origination policies: • Verbal verification of employment• Continuity of income• Notes, electronic records, and signatures• Title insurance• Seller/servicer business continuity and

submission of financial statements

March 23, 2020

Freddie 2020-05

Temporary guidance related to credit underwriting and property valuation requirementsExpansion of the automated collateral evaluation eligibilityAn extension to the deadline for certain annual reporting requirements

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States

March 30, 2020

Maryland Notaries

Maryland’s guidance on the use of technologies that permit the notary to see and hear the person signing a document in real time

March 25, 2020

PA Notaries Pennsylvania’s limited suspension of in-person requirements for Notaries

March 24, 2020

Emergency Relief Reg.

The NYDFS emergency regulations which require in response to Executive order 202.9

March 21, 2020

Executive Order 202.9

It is an unsafe and unsound business practice if a bank subject to the jurisdiction of the NYDFS does not grant a forbearance those suffering a financial hardship as a result of the COVID-19

March 27, 2020

940 CMR 35:00

Massachusetts AG emergency regulation prohibits certain collection activity by both creditors and debt collectors

4/29/2020 51

Trade Groups

ICBA Free Webinar: COVID-19 Update & Impact On Community Banking

ICBA Free Webinar: ICBA Community Bank Briefing Q1: COVID-19 Pandemic

ABA An alphabetical list of publicly announced steps taken by banks of all sizes to respond to the crisis

ABA A page containing a range of resources to assist banks

ABA A frequently asked questions document FAQ's

ABA The Coronavirus Response Network, discussion group for bankers to engage directly with one another

ABA (members only)

ABA detailed summary of the CARES act

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Trade Groups

ABA (members only)

Webinar - operational challenges posted by the pandemic, provides an updated on the current situation and highlights business continuity planning practices for banks

ABA (members only)

Webinar - focuses on managing the operational risk posed by the pandemic, department by department

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Our Resource Centers

We have added a link to the Roundtable recordings and materials that have been distributed:

Compliance Anchor Resource Center

ACBB has also created a resource center:ACBB Resource Center

4/29/2020 54

Contact Information

Nancy Lake, CAMS-Audit, CAMS-FCI – nlake@complianceanchor.com

• Director of Compliance Anchor

• 717-303-7854

• BSA/AML

Gary Iorfido, JD, CCBCO –giorfido@complianceanchor.com

• Compliance Consultant

• 717-580-1192

• Consumer Compliance

Kelvin Reyes –kreyes@complianceanchor.com

• Client Engagement Specialist

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