The SBA issued to lenders a letter and instructions on the agency's "loan necessity" questionnaire for Paycheck Protection Program loans of $2 million or more.
The instruction guide details how lenders receive notice of a questionnaire, what to do after being notified, what to do with borrower responses, and how to submit the questionnaires. The SBA letter says requests to complete the questionnaire do not mean the SBA is challenging a borrower’s certification.
Lenders are required to upload the completed form and supporting documents via the SBA's lender platform and to separately input borrower responses to each question, though they aren't required to re-enter narrative comments from the questionnaire.
Further, lenders are not required to verify or validate borrower responses, though they should confirm that all required responses, supporting documents, signatures, and certifications have been received.
ICBA has raised questions about the questionnaire among policymakers. In a recent ICBA letter to congressional leaders and separate joint letters to lawmakers and agency heads, ICBA called on the SBA to suspend the questionnaires while the agency addresses lender and borrower concerns.
The letters note that the questionnaire has led many borrowers to justifiably fear that the SBA is altering PPP loan eligibility criteria after funds have already been disbursed.
The instruction guide details how lenders receive notice of a questionnaire, what to do after being notified, what to do with borrower responses, and how to submit the questionnaires. The SBA letter says requests to complete the questionnaire do not mean the SBA is challenging a borrower’s certification.
Lenders are required to upload the completed form and supporting documents via the SBA's lender platform and to separately input borrower responses to each question, though they aren't required to re-enter narrative comments from the questionnaire.
Further, lenders are not required to verify or validate borrower responses, though they should confirm that all required responses, supporting documents, signatures, and certifications have been received.
ICBA has raised questions about the questionnaire among policymakers. In a recent ICBA letter to congressional leaders and separate joint letters to lawmakers and agency heads, ICBA called on the SBA to suspend the questionnaires while the agency addresses lender and borrower concerns.
The letters note that the questionnaire has led many borrowers to justifiably fear that the SBA is altering PPP loan eligibility criteria after funds have already been disbursed.
CBA’s Legislative Team: John McNair, Tyler Eck, Lori Godfrey
CBA Welcomes Tyler Eck
Tyler Eck has joined CBA as Government and Regulatory Relations Associate. Prior to joining CBA, Tyler worked as an aide for Congressman Drew Ferguson where he oversaw SBA, USDA, Treasury, and IRS issues for constituents and businesses during the COVID-19 pandemic. Tyler previously worked in local government, the justice system, IT, and customer service.
“Under the direction of Lori Godfrey, CBA has become one of the leading lobbying associations in Georgia. CBA’s passage of SB157 made clear the value of having a single voice for community banks. As a result, CBA’s Board of Directors directed me to further expand the association’s advocacy efforts,” stated John McNair, President & CEO. “CBA has a very aggressive advocacy plan and Tyler’s unique blend of advocacy experience and knowledge of community banking issues will enable him to effectively communicate with legislators, regulators, and administration officials. We are grateful to Congressman Ferguson for referring Tyler to us and look forward to his strong representation of Georgia’s community banks.”
Tyler Eck has joined CBA as Government and Regulatory Relations Associate. Prior to joining CBA, Tyler worked as an aide for Congressman Drew Ferguson where he oversaw SBA, USDA, Treasury, and IRS issues for constituents and businesses during the COVID-19 pandemic. Tyler previously worked in local government, the justice system, IT, and customer service.
“Under the direction of Lori Godfrey, CBA has become one of the leading lobbying associations in Georgia. CBA’s passage of SB157 made clear the value of having a single voice for community banks. As a result, CBA’s Board of Directors directed me to further expand the association’s advocacy efforts,” stated John McNair, President & CEO. “CBA has a very aggressive advocacy plan and Tyler’s unique blend of advocacy experience and knowledge of community banking issues will enable him to effectively communicate with legislators, regulators, and administration officials. We are grateful to Congressman Ferguson for referring Tyler to us and look forward to his strong representation of Georgia’s community banks.”
Community Banks Reported a 10 Percent Increase in Net Income Year-Over-Year
Reports from 4,590 FDIC-insured community banks reflect annual net income growth of $659.7 million despite a 116.6 percent increase in provision expense and continued net interest margin compression. Nearly half of community banks (48 percent) reported higher quarterly net income. Higher revenue from the sale of loans (up $1.9 billion or 154.2 percent) drove the improvement in quarterly net income year-over-year. The net interest margin for community banks compressed 41 basis points year over year to 3.27 percent, as the decline in average earning asset yields continued to outpace the decline in average funding costs. “The banking industry exhibited operational resiliency in the third quarter, with improvements in profitability despite continued headwinds and economic uncertainties resulting from the effects of the COVID-19 pandemic,” stated FDIC Chairman Jelena McWilliams. Click here to read FDIC Third Quarter Banking Profile.
Reports from 4,590 FDIC-insured community banks reflect annual net income growth of $659.7 million despite a 116.6 percent increase in provision expense and continued net interest margin compression. Nearly half of community banks (48 percent) reported higher quarterly net income. Higher revenue from the sale of loans (up $1.9 billion or 154.2 percent) drove the improvement in quarterly net income year-over-year. The net interest margin for community banks compressed 41 basis points year over year to 3.27 percent, as the decline in average earning asset yields continued to outpace the decline in average funding costs. “The banking industry exhibited operational resiliency in the third quarter, with improvements in profitability despite continued headwinds and economic uncertainties resulting from the effects of the COVID-19 pandemic,” stated FDIC Chairman Jelena McWilliams. Click here to read FDIC Third Quarter Banking Profile.
CBA Preferred Service Provider Spotlight –
Danny Capitel, IntraFi Network
Take a moment to get to know Danny Capitel, Managing Director, IntraFi Network, formerly Promontory Interfinancial Network. CBA invited Danny to participate in a Q & A so you can learn more about this Gold Level Preferred Service Provider and a little more about Danny. Learn how several banks enhanced their capital ratios and profitability while retaining valued customer deposits. Click here for article.
Danny Capitel, IntraFi Network
Take a moment to get to know Danny Capitel, Managing Director, IntraFi Network, formerly Promontory Interfinancial Network. CBA invited Danny to participate in a Q & A so you can learn more about this Gold Level Preferred Service Provider and a little more about Danny. Learn how several banks enhanced their capital ratios and profitability while retaining valued customer deposits. Click here for article.
Training Need Survey – Would you participate in a PPP Loan Forgiveness Professional Development Class?
Please take a moment to complete the short survey – your input helps CBA develop programs to fit your needs. Thank you!
Please take a moment to complete the short survey – your input helps CBA develop programs to fit your needs. Thank you!
Georgia’s community bankers do great things in their communities every day. Here is the latest on community outreach and news from CBA Members:
- CBA CEO John McNair shared his thankfulness for Georgia's community bankers in the Atlanta Business Chronicle’s “Atlanta Gives Thanks” feature. Click here for the article.
- Peach State Bank & Trust, Gainesville, held a “No Shave November” for the men in the bank and in return collected $2,715.00 to help in the fight to eradicate cancer. Employees made donations to Emory Winship Cancer Institute in Atlanta.
Doug Keipper, MBA, CAMS, has joined BankSouth, Greensboro, as Vice President, BSA/AML Officer.
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2021 Media Kit Now Available
Attention potential advertisers! CBA’s 2021 Media Kit is now available. Visit our advertising page to learn more about opportunities to advertise in CBA’s bi-monthly magazine, weekly e-newsletter, 2021 member directory, website and more. The Media Kit includes rates, a 2021 editorial calendar and other details as you plan for maximum exposure in the coming year! Contact Lindsay Greene for more information.
Attention potential advertisers! CBA’s 2021 Media Kit is now available. Visit our advertising page to learn more about opportunities to advertise in CBA’s bi-monthly magazine, weekly e-newsletter, 2021 member directory, website and more. The Media Kit includes rates, a 2021 editorial calendar and other details as you plan for maximum exposure in the coming year! Contact Lindsay Greene for more information.
Think CBA First for Your Professional Development Needs!
Be sure to think of CBA first when it comes to your training and Professional Development needs. Here are some upcoming CBA events:
Be sure to think of CBA first when it comes to your training and Professional Development needs. Here are some upcoming CBA events:
Quarter IV – Flood, Appraisals and Applications
In-Person or STREAM - Live Virtual Training: 12/1 - Duluth • 12/8 - Statesboro
In-Person: 12/9 - Tifton • 12/10 - Macon
Join us as we highlight the key issues in flood and hazard insurance compliance, including examiner hot buttons, private flood insurance and force placement. The appraisal final rules are coming – what it means to your policy, process and more, including best practices. Then, we will round out the day with the Uniform Residential Loan Application (URLA or 1003) – what it means for you and are you ready for it? Join us as we review the new requirements, the potential challenges and ways to address them.
In-Person or STREAM - Live Virtual Training: 12/1 - Duluth • 12/8 - Statesboro
In-Person: 12/9 - Tifton • 12/10 - Macon
Join us as we highlight the key issues in flood and hazard insurance compliance, including examiner hot buttons, private flood insurance and force placement. The appraisal final rules are coming – what it means to your policy, process and more, including best practices. Then, we will round out the day with the Uniform Residential Loan Application (URLA or 1003) – what it means for you and are you ready for it? Join us as we review the new requirements, the potential challenges and ways to address them.
This seminar is designed to provide insight into the who, what, where, when, how and why in complying with TRID, including any recent changes and clarifications. The comprehensive seminar manual serves as a detailed analysis of the TRID rules, including the amendments, and serves as a valuable reference tool. Register here.
HR & Talent Development RAP Session
Friday, December 11, 2020 | 10 am - 2 pm | Live Virtual STREAM
Sign ups Open for 2021 HR/TD League
Friday, December 11, 2020 | 10 am - 2 pm | Live Virtual STREAM
Sign ups Open for 2021 HR/TD League
Please join us for an interactive session for Information Security Officers and IT leaders on lessons learned from the Pandemic and its aftermath (fingers crossed!). We’ll explore the ISO’s role in helping your organization stay productive, secure and flexible regardless of circumstances. The session will include
presentation from industry experts in technology, policy and compliance and valuable takeaways from the pier discussion.
Register here.
presentation from industry experts in technology, policy and compliance and valuable takeaways from the pier discussion.
Register here.
2021 Business Lending: Why Wait and See Is Not A Strategy
Wednesday, December 9, 2020 | 2:00 pm ET
The best way to prepare for 2021 is by knowing ways to handle what's likely to come. The webinar will give you valuable clarity as industry experts Arne Monson of Holtmeyer & Monson and David Ruffin of IntelliCredit clarify where lending is headed. If you want to write your own script for the new year - and not wait for customers, regulators, and circumstances to do it for you - don't miss this discussion. Click here for more information and to register.
Wednesday, December 9, 2020 | 2:00 pm ET
The best way to prepare for 2021 is by knowing ways to handle what's likely to come. The webinar will give you valuable clarity as industry experts Arne Monson of Holtmeyer & Monson and David Ruffin of IntelliCredit clarify where lending is headed. If you want to write your own script for the new year - and not wait for customers, regulators, and circumstances to do it for you - don't miss this discussion. Click here for more information and to register.
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Founded and family-owned since 1980, Executive Insurance Agency provides comprehensive insurance solutions for financial institutions needing customized protection for collateralized loans and mortgages. These products include Blanket VSI, Collateral Protection, Flood, Guaranteed Asset Protection “GAP”, as well as both Blanket and Creditor Placed Mortgage.
To learn more, contact Ryan Sower at 770-474-2355 or visit their website. |
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Here are some of the latest news stories relevant to community banking and the financial services industry:
Additional Resources:
- Yellen nominated for Treasury secretary
- CFPB issues final policy on advisory opinions
- FHFA issues 2021 ratio for uniform security
- Kasasa Guest Article: How to get non-interest income now
Additional Resources:
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FDIC Regulatory Calendar
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