Hoosier Banker 45 1 The joint statement is available at: fdic.gov/news/financial-institution-letters/2020/fil20019a.pdf 2 OCC Bulletin 2020-452 is available at: occ.gov/news-issuances/bulletins/2020/bulletin-2020-45.html the OCC encouraged banks providing loans under the PPP to: • Document implementation and lending decisions; and • Identify and track PPP loans made to small business borrowers that have annual revenues of $1 million or less and are located in low- to moderate-income (LMI) areas. Additionally, the OCC encouraged national banks to track information provided during the application process regarding: borrowers’ annual revenue; loans made in LMI census tracts, distressed and underserved areas; and loans that benefit LMI individuals, families and communities. This information may be useful for CRA purposes. Prudent practices may also include documenting implementation decisions when setting eligibility criteria, establishing processes for considering applications, and approving or denying PPP applications. In addition, relevant business considerations may include resources needed to implement and offer the There’s lending, and there’s intelligent lending. The tools to succeed in every stage of your lending lifecycle. Learn more at spglobal.com/commercial-lending Copyright © 2020 S&P Global Market Intelligence Inc. All rights reserved. Market Insight & Lead Generation Pricing & Total Relationship Optimization Portfolio & Lender Performance Analysis Credit Surveillance & Portfolio Tracking Credit Analysis & Assessment PPP, including staff resources, and the ability to access applicant information in a timely way, among other factors. The OCC also encourages banks to identify and track PPP loan volumes. Such documentation enables the bank to demonstrate the full spectrum of businesses served, including small businesses and those in LMI areas. When exercising supervisory and enforcement responsibilities in this area, the OCC indicated it will take into account the unique circumstances resulting from the pandemic and good faith efforts to comply with legal requirements. Documentation of these issues can help a bank write its own story of PPP participation, as well as inform regulatory assessment of that involvement. HB A communications toolkit created by the Indiana Bankers Association helps member banks share good-news stories with media outlets. Additionally, the toolkit provides an optional quick-link webform for submitting updates to Hoosier Banker, such as bank hires/promotions, branch openings, community service and more. • View the toolkit at: indiana.bank/communications-toolkit • Access the webform at: indiana.bank/submit-news For more information, contact Laura Wilson at lwilson@indiana.bank, 317-333-7146. HB Toolkit Helps ‘Tell the Story’ of Banking Tell the Story
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