New SBA PPP, CFPB rules for CUs to be aware of
As credit unions work to secure paycheck protection program (PPP) loans for small businesses in their community and provide financial assistance for members impacted by the coronavirus pandemic, there are several new updates and resources for credit unions to be aware of.
The Small Business Administration (SBA) Wednesday released two interim final rules clarifying disbursements and seasonal employees under the PPP.
Under one interim rule, the SBA indicated that the disbursement of PPP loans must be one-time and made within 10 calendar days of the loan approval. For loans that received an SBA loan number prior to the rule and have not been fully disbursed, the ten-day period begins on April 28. For 1502 reporting, lenders must upload the SBA form within 20 days after the PPP loan is approved. A lender must also report through the E-Tran system or the 1502 report any PPP loans that were cancelled before disbursement or voluntarily terminated and repaid. The SBA will provide further information on access and instructions to complete the reporting.
The second interim rule allows lenders to use alternative criteria for calculating the maximum loan amount for PPP loans issued to seasonal employers.
The SBA also added an additional question to its FAQs for lenders and borrowers regarding applications from private companies that own businesses.
Additionally, Treasury Secretary Steven Mnuchin and SBA Administrator Jovita Carranza reiterated their commitment to ensuring PPP loans are limited to eligible borrowers in a joint statement, committing to review all loans about $2 million.
Also on Wednesday, in efforts to "to ensure access to the PPP loan program for the smallest lenders and their small business customers," the SBA only allowed lenders with less than $1 billion in assets to submit loan applications for an eight-hour window. The SBA and Treasury said they will evaluate the process to determine whether to pursue more time reservations for smaller lenders in the future.
NAFCU Wednesday released updated PPP FAQs addressing new guidance regarding disbursements, payment of fees to lenders, and loans to board members. The FAQs also discuss the NCUA's interim final rule and letter to credit unions on the PPP. The association will continue working with the SBA, Treasury, NCUA and Congress to ensure credit unions have the guidance and resources needed to effectively participate as PPP lenders.
The CFPB issued an interpretive rule providing greater flexibility under the TILA-RESPA Integrated Disclosure (TRID) rule and Regulation Z, in order to allow financial institutions to better help consumers obtain access to mortgage credit during the coronavirus pandemic.
The rule clarifies that consumers can modify or waive certain required waiting periods set under TRID and Regulation Z rescission rules.
“The steps we are taking today will help consumers facing financial emergencies obtain access to mortgage credit faster,” said CFPB Director Kathy Kraninger. “The pandemic is resulting in consumers facing various challenges, and our temporary and targeted solutions are intended to ensure that consumers receive the credit they need in a timely manner.”
The bureau also released an FAQ document addressing when creditors must provide appraisals or other written valuations to mortgage applicants.
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Add to Calendar 2021-02-25 14:00:00 2021-02-25 14:00:00 Fundamentals of Credit Union Subordinated Debt This webinar will cover NCUA’s new rule authorizing the issuance of subordinated debt by natural person credit unions for purposes of regulatory capital treatment. Previously only low-income credit unions could issue subordinated debt that can count toward their net worth requirement. Under the rule, complex credit unions and new credit unions, as well as low-income credit unions, may issue subordinated debt that can count toward their risk-based capital requirement. The webinar will address material terms of the rule and the subordinated debt instrument. We’ll also cover the regulatory approval process, eligible investors, the offering process, reasons to issue subordinated debt and the current interest rate environment. Key Takeaways Understand managing the regulatory approval process. Gain familiarization with key terms of the subordinated debt note. Review the issuance and marketing process. Discuss current market dynamics for credit union sub debt. Purchase Now$295 Members | $395 Nonmembers (Additional $50 for CD)One registration gives your entire credit union access to the on-demand recording until February 25, 2022.Already registered? Go to the Online Training Center to view live. Who Should Attend? NAFCU Certified Compliance Officers (NCCOs) NAFCU Certified Risk Managers (NCRMs) Chief Executive Officers Executive Vice Presidents Chief Financial Officers Education Credits NCCOs will receive 1.5 CEUs for participating in this webinar. NCRMs will receive 1.5 CEUs for participating in this webinar. CPA credit information is below; recommended 1.5 CPE credits. CPA Certification Credit Information Reviewer: Josie Collins, Associate Director of Education, NAFCU Learning Objectives: Understand managing the regulatory approval process. Gain familiarization with key terms of the subordinated debt note. Review the issuance and marketing process. Discuss current market dynamics for credit union sub debt. Program Level: Basic Prerequisites Needed: None Advance Preparation Needed: None Delivery Method: Group Internet-Based Recommended CPE Credits: 1.5 credits Recommended Field of Study: Finance - Technical National Association of Federal Credit Unions (NAFCU) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. Learn more. About Our Webinars Our webinars are streamed live from NAFCU headquarters near Washington, D.C. Your audio/video feed of the presenters includes presentation slides and downloadable handouts. You can easily submit your questions to the presenters at any time during the live broadcast, with no dialing over the phone! The audio and video stream directly through your computer. Web NAFCU email@example.com America/New_York public
Credits: NCRM, NCCO, CPE
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