Capital Accounting and Liquidity

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Latest Capital, Accounting and Liquidity FAQs

F07) Did the banking agencies extend the deadline for filing call reports for the first quarter of 2020?

Guidance released by the FFIEC on March 25, 2020 indicate that the federal banking agencies will not take action against any institution for submitting its March 31, 2020, Reports of Condition and Income (Call Report) after the respective filing deadline, as long as the report is submitted within 30 days of the official filing date. Institutions are encouraged to contact their primary federal regulator in advance of the official filing date if they anticipate a delayed submission.

In addition the Federal Reserve has indicated that it will not take action against a bank holding company with $5 billion or less in assets for submitting March 31, 2020, bank holding company reports (FR Y-9C or FR Y-11) after the filing deadline, as long as the report is submitted within 30 days of the filing date.

Institutions are encouraged to contact their Reserve Bank in advance of the normal filing deadline if they anticipate a delayed submission. Institutions anticipating difficulty submitting their reports within the 30 days following the official filing due date, or experiencing challenges in obtaining director attestations, should likewise contact their Reserve Bank.

L12) Can an employer that is deemed an “essential business” claim the employee retention tax credit?
- An “essential business” that fully or partially suspends operations is generally not eligible for the tax credit.
- An employer that operates an essential business is not considered to have a full or partial suspension of operations if the governmental order allows the employer’s operations to remain open. However, an employer that operates an essential business may be considered to have a partial suspension of operations if, under the facts and circumstances, more than a nominal portion of its business operations are suspended by a governmental order. In addition, an essential business that is permitted to continue its operations may, nonetheless, be considered to have a partial suspension of its operations if a governmental order requires the business to close for a period of time during normal working hours.

L13) Can a bank that has closed a branch or lobby and reduced staff hours claim the employee retention tax credit?
- Circumstances will vary for different banks and different legal jurisdictions. A bank that believes it may qualify for the credit should consult with its tax accountant.

L02) What happens to payroll tax deferral in 2021?
- An employer will resume payment of payroll taxes incurred after January 1, 2021. But payroll taxes deferred in 2020 are not yet due.
- 50 percent of deferred taxes are due December 31, 2021. The remaining 50 percent is due December 31, 2022.
- No interest accrues on deferred amounts.

Community Bankers, Tell Congress to Approve PPP Funding

ICBA is recommending to Congress enhancements to the Paycheck Protection Program that would facilitate small businesses' access to credit. But, to make these reforms a reality, you need to let your elected officials know.

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Small Business Owners, Tell Congress to Approve PPP Funding

The current funding of the Paycheck Protection Program has run out. In order for Congress to provide more, give you flexibility with how you spend it and ensure all small businesses have access, your elected officials need to hear from you.

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Industry Updates

ICBA advocacy push continues during lame-duck Congress

Nov 16, 2020

While the 116th Congress winds down in the coming weeks with its post-election "lame duck" session, ICBA's efforts to pass much-needed economic stimulus measures continue unabated.

Full story
Budgeting for a 2021 Innovation Agenda

Oct 02, 2020

With so many unknowns, budgeting is difficult, but there is a bright spot. With uncertainty comes the opportunity to look at what we do in a different light using the experiences of the pandemic to explore new ideas.

Full story

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04/09 FDIC, OCC, FRB - Interim Final Rule for PPP Facility

Federal Bank Regulators Issue Interim Final Rule for Paycheck Protection Program Facility
Interim final rule encourages lending to small businesses through the SBA's PPP. The rule modifies the agencies' capital rules to neutralize the regulatory capital effects of participating in the Federal Reserve's PPP facility because there is no credit or market risk in association with PPP loans pledged to the facility. The interim final rule also clarifies that a zero percent risk weight applies to loans covered by the PPP for capital purposes.
07/04 FDIC, OCC, FRB - Revised Interagency Statement on Loan Modifications

Agencies Issue Revised Interagency Statement on Loan Modifications by Financial Institutions Working with Customers Affected by the Coronavirus
Statement incorporates CARES Act provisions, permitting banks to suspend classification of loan modifications as TDRs. The revised statement also provides interpretations on past due and nonaccrual regulatory reporting of loan modification programs. Examiners will exercise judgment in reviewing loan modifications and will not automatically adversely risk rate credits that are affected by COVID-19.
04/06 FDIC, OCC, FRB - Agencies Announce Changes to the Leverage Ratio

Agencies Announce Changes to the Community Bank Leverage Ratio
Under the interim final rules, the community bank leverage ratio will be 8 percent beginning in the second quarter and for the remainder of calendar year 2020, 8.5 percent for calendar year 2021, and 9 percent thereafter. The interim final rules also maintain a two-quarter grace period for a qualifying community banking organization whose leverage ratio falls no more than 1 percent below the applicable community bank leverage ratio.

Follow all agency responses

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CAPITAL, ACCOUNTING AND LIQUIDITY

Latest News

Latest Capital, Accounting and Liquidity FAQs

F07) Did the banking agencies extend the deadline for filing call reports for the first quarter of 2020?

L12) Can an employer that is deemed an “essential business” claim the employee retention tax credit?

L13) Can a bank that has closed a branch or lobby and reduced staff hours claim the employee retention tax credit?

L02) What happens to payroll tax deferral in 2021?

Community Bankers, Tell Congress to Approve PPP Funding

Small Business Owners, Tell Congress to Approve PPP Funding

Industry Updates

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