Wednesday, October 20, 2021

Week of Feb. 8

In This Issue…

ICYMI – thanks to the ABA/Alliance for providing this information

Last night, the Small Business Administration issued an updated procedural notice about the reporting process through which lenders report on Paycheck Protection Program loans and collect processing fees. The guidance addresses fees for new, first-draw PPP loans and second-draw PPP loans, and outlines reporting requirements for lenders.

For first-draw PPP loans made on or after Dec. 27, 2020, lenders will receive processing fees in the following amounts:

  • 50% or $2,500, whichever is less, for loans of not more than $50,000;
  • 5% for loans of more than $50,000 and not more than $350,000;
  • 3% for loans of more than $350,000 and less than $2 million; and
  • 1% for loans of at least $2 million.

For second-draw PPP loans, lenders will receive:

  • a 50% processing fee or $2,500, whichever is less, for loans of not more than $50,000;
  • a 5% processing fee for loans of more than $50,000 and not more than $350,000; and
  • a 3% processing fee for loans above $350,000.

Lenders are to use SBA Form 1502 to report fully disbursed loans to SBA within 10 calendar days after the disbursement of a PPP loan.

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SBA to begin sending EIDL advance reconciliation payments

Last night, the SBA also announced that it will begin remitting reconciliation payments beginning Feb. 9 through Feb. 19 for any with an SBA forgiveness payment that was reduced by the amount of an Economic Injury Disaster Loan advance.

Lenders must notify borrowers of the reconciliation payment, and that the borrower is responsible for re-amortizing the loan. Lenders must also notify the borrower of either the amount of the next payment due, or that the loan has been paid in full.

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Oppose NCUA field of membership proposal

Once again, our friends at the National Credit Union Administration (NCUA) have overstepped their authority to expand the “field of membership” more broadly than it already is.

The proposed rule would expand the definition of “service facility” and erase the distinction between service to select groups and service to under-served areas as delineated in the Federal Credit Union Act. This regulatory effort, if approved, would undermine congressional intent to demand a heightened standard of in-person service for under-served communities.

The OBA, the Alliance and the ABA are asking bankers to oppose this potential power grab by the NCUA. The proposal also considers counting a credit union website or mobile banking application as a “service facility,” paving the way for national online fields of membership. Comments on the proposal are due Feb. 10. ABA has provided a sample comment letter for bankers to easily complete and send through its grassroots platform, Secure American Opportunity. Take action now.

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Fed research paper flags climate change as source of financial risk

As if you don’t already have enough on your plate, federal regulators – including the Federal Reserve – are moving to incorporate climate risk assessments in their supervisory activities, according to a new research letter published yesterday by the Federal Reserve Bank of San Francisco.

The Fed’s Glenn Rudebusch noted the agency is approaching the management climate-related risk—including physical risk and transition risk as lower-carbon energy sources develop—from both a micro-prudential and macro-prudential perspective. Read the research letter.

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Review your bank’s information for OBA directory

The Oklahoma Bankers Association Directory of Banks is again being produced this year by NFR Communications (formerly BankNews Media). To best serve you, we want to include the most up-to-date and accurate information about your bank, your branches and your staff. However, we need your help.

To ensure we are using the most accurate information, please follow the instructions provided in the letter that was mailed to your bank last week by NFR Communications. Please review and revise as necessary the financial directory listing for your holding company, your main bank and your branches. You can also use the login information that was included in the letter to update your listing online or, if needed, download a new form.

Completed forms may be returned by email to or faxed to 913-261-7010. Please update the information no later than Feb. 10, 2021.

We appreciate your help in making the 2021 Edition of the Oklahoma Bankers Association Directory of Banks a success.

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Make your nominations for 50-Year Club

The OBA is proud to promote the recognition of bankers who have devoted 50 or more years of service to the banking industry. All eligible nominees will be honored at the 2021 OBA Convention, held May 24-26.

Click here to download a nomination form. If you have any questions, please contact Janis Reeser at 405-424-5252 or

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OBA Intern Program looking for participants

One education program, in particular, to be aware of is the OBA Intern Program. The Intern Program is active again for 2021 and we’re looking for participating banks! For more information on this IMPORTANT program, important not only to aspiring students, but also to participating banks.

Contact the OBA education department at (405) 424-5252 or click here for more information!

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OBA education corner …

The temperature is dropping in Oklahoma, and so are some new OBA education events! Check out the list below:

NOTE: Effective March 16, 2020, 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.

  • BSA Emerging Issues, webinar, Feb. 16 — What are the important issues facing the BSA Department in 2021?
  • Advanced TRID Compliance, webinar, Feb. 16 — Consider this webinar your “cheat sheet” to get you on the right track BEFORE your next examination.
  • ACH Rule Changes: What You Need To Know, webinar, Feb. 17 — Bring your 2021 ACH Rule Book and we’ll make sure you are comfortable with the changes. We’ll also take a look at what happened last year, as a refresher.
  • What To Do When A Customer Dies, webinar, Feb. 18 — We’ll walk you through the best practices when dealing with a customer’s death – both on the deposit side and the loan side, as well as unique issues that can arise when doing business with the decedent’s estate.
  • Responsibilities Of The Information Security Officer, webinar, Feb. 19 — We will review various regulatory guidance that outlines ISO responsibilities and reporting structures. Additionally, various educational paths that can help develop your skills in the future.
  • Letters of Credit, webinar, Feb. 24 — This webinar provides an essential understanding of letters of credit, including letter of credit terminology, structure and function. Whether your bank issues letters of credit, accepts letters of credit or takes liens on letter of credit rights, this program is for you.
  • HSA Accounts: Dealing with the Headaches, webinar, Feb. 25 — Over the last 15 years there have been many changes to HSAs so this annual update is a necessity when it comes to keeping up with the latest rules and regulations.
  • 2021 Hot Topics for Bank Directors: A Virtual Workshop, Feb. 25 — Informed and engaged bank directors are key for a community bank’s success. These sessions broach on compensation, evaluations, and strategic planning along with other timely issues facing bank managers and their boards. The workshop is designed to assist bank directors and executive management with carrying out their duties and responsibilities. The workshops will offer ample time for discussion.
  • Trouble Debt Restructuring, Feb. 26 — As the saying goes in accounting, “Once a TDR is always a TDR”. Attending this webinar will enable you to recognize a true TDR so that regulator reporting is accurate and to know how to manage them from an lending and accounting perspective.
  • 2021 Virtual Call Reports Seminar, March 9 — This seminar will cover general information on new accounting and regulatory matters addressed within the Call Report to include several final issued Accounting Standards Updates that impact the financial services industry and regulatory reporting changes currently impacting the Call Report as well as those regulatory changes that are proposed for the future. The impact of the CARES Act and related regulatory interim and final rules resulting from the COVID-19 crisis will also be discussed.

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