In This Issue…
- SBA offers clarity for PPP borrowers on attempting to rehire employees, nonprofit hospitals
- Survey on banks’ reopening procedures available
- Check out OBA’s strategic members COVID-19 Resource page
- OBA education corner …
SBA offers clarity for PPP borrowers on attempting to rehire employees, nonprofit hospitals
The Small Business Administration and Treasury Department confirmed that loan forgiveness amounts will not be reduced for PPP borrowers who attempt to rehire laid-off employees, if those employees decline the offer to work.
In updates to the PPP FAQs late Sunday night, SBA and Treasury said they would issue an interim final rule in the coming days codifying that a borrower must have documented that they made a good faith, written offer of rehire to the employee for the same wages and number of hours. In addition, if the employee rejects, borrowers must document this rejection.
The updated FAQs provide clarification about the treatment of nonprofit hospitals under the CARES Act. A nonprofit hospital may qualify for PPP funding if it “reasonably determines” and maintains documentation that it meets the criteria of a 501(c)(3) under the Internal Revenue Code and is therefore tax exempt under section 501(a), SBA and Treasury noted. They added that these entities should also review all other applicable eligibility criteria.
The FAQs provide additional guidance for seasonal employers making borrower certifications to obtain PPP funding.
Survey on banks’ reopening procedures available
The OBA is collecting information on how Oklahoma banks are planning to address reopening their lobbies and offices.
We would appreciate if the president or CEO of each bank would take (or assign) this short (less than two-minute) survey on this subject — we only need one response per bank.
Click here to take the survey.
Check out OBA’s strategic members COVID-19 Resource Page
To help our member banks have access to as many resources as possible during the COVID-19 pandemic, the OBA is collecting information from our strategic members and other affiliated businesses that are providing important information and help.
These resources include work-at-home solutions, personal protective gear and cleaning supplies provided by Deluxe.
OBA education corner …
While live events and seminars are currently on hold, the OBA’s education department has plenty of webinars lined up:
NOTE: Effective March 16, and until further notice, TTS (our webinar provider) has extended the OnDemand access period for all ‘Live Plus Five (Days)’ registrants to 60 days (versus five business days). Also, they are waiving the $75 per location fee for additional locations.
- Understanding Commercial Real Estate Loan Documents, May 12, webinar — This webinar was developed by a lawyer who has been teaching loan documentation for more than 25 years. Taught at a basic level (for bankers, not lawyers), the instructor will lead participants through all sections of the various required real estate loan documents. The purpose is to create a deeper understanding of why certain documents are required, plus the significance of various sections and verbose language (often referred to as “boilerplate”).
- FCRA Compliance: E-Oscar and Metro2, May 12, webinar — During this informative ninety (90) minute webinar the basics of proper credit reporting will be discussed along with a more in-depth conversation regarding specific pitfalls and challenges that creditors and other data furnishers encounter.
- Basic Bankruptcy for Bankers, May 13, webinar — This webinar will introduce you to the world of bankruptcy. It is designed for lenders and support staff with the goal of educating them on the fundamentals of both consumer and commercial bankruptcy law, including the new Small Business Reorganization Act of 2019, which went into effect February 19, 2020 and the temporary changes to the Bankruptcy Code under the COVID-19 stimulus package to expand relief to small businesses and individual debtors.
- Deposit Regulation Update and Review, May 14, webinar — This webinar will cover changes to IRAs under the SECURE Act, nonresident alien interest reporting, a peek at the Illicit Cash Act, and much more.
- Loan Modifications – What are the Compliance Issues?, May 18, webinar — This webinar will deal with the ins and outs of making changes to loans of all types. We’ll discuss the compliance and legal requirements, operational challenges, and impacts to borrowers, guarantors, and other parties to the loan. We’ll also deal with the threshold question: should the lender grant the borrower’s request in the first place (and if so, what accommodations or changes should be made)?
- Opening Fiduciary Accounts, May 19, webinar — During this program we will review the set-up, documentation and legal issues involved in these high- risk accounts. You will learn how to style these accounts and get the signature card perfect every time.
- Staff Training: Human Smuggling, Trafficking, Elder Fraud and ID Theft, May 20, webinar — During this program we will conduct staff training to detect and prevent four big crimes against your customer. We will look at the red flags and scenarios for Elder Abuse, Identity Theft, Business Email Compromise Schemes and Human Trafficking.
- BSA: MSBs, MRBs, TPPPs, NGOs and All the High Risk Customers, May 21, webinar — We will cover the high risk customers and services listed in the BSA exam manual and begin to see their impact into our AML program. We will look at what makes a customer or service high risk. What extra due diligence is required when the customer is high risk? And can the high risk customers and services impact your bank’s BSA risk rating?
- Critical Cybersecurity Focus Areas for 2020, May 27, webinar — Join us for this one-day, streaming Cybersecurity session to discuss four important and relevant cybersecurity topics, along with a ton of great risk-mitigating takeaways to consider implementing at your institution.