FALL 2020 RESOURCE Interim Commissioner, Rhoshunda Kelly
The Examiner Tips, Tools & Insight from the Field
Loan Modifications for all Survey Respondents by Asset Size: # Banks Responded # of Loan Modifications
Total $ Amt. of Loan Modifications
% of Total $
Banks < $500 Million
37
2,833
$361,551,218 $196,924,821 $1,578,635,487 $7,773,160,114 $9,910,271,640
3.65% 1.99% 15.93% 78.44%
Banks $500 Million to $1 Billion Banks $1 Billion to $10 Billion
7 6 3
320
6,935 15,827 25,915
Banks > $10 Billion
TOTAL 100% ____________________________________________________________________________________________________ COVID-19 GUIDANCE INTERIM GUIDANCE ISSUED BY DBCF: • Industry Pandemic Preparedness and DBCF Response (March 13, 2020) o Sent to CEOs of state-chartered banks. o Outlined DBCF expectations for business continuity planning and offsite exam protocol. • Statement on Financial Institutions Working with Customers Affected by the Coronavirus and Regulatory Assistance (March 13, 2020) o Sent to CEOs of state-charted banks. o Outlined DBCF expectations of banks to work with customers. • Interim Regulatory Guidance – Banking Hours and Service (March 16, 2020) o Sent to CEOs of state-charted banks. o Temporarily allowed banks to modify current operating procedures and hours. o SEE: Section 81-5-97 (Hours of Business) . o SEE: Bank Regulation 1 . • Restatement of Guidance – Legal Lending Limit: Government Guaranteed Loans (April 7, 2020) o Sent to CEOs of state-chartered banks. o Provided clarity on legal lending limits related to SBA loans, including the Paycheck Protection Program (PPP). o SEE: 81-5-77(b). PROCLAMATIONS/EXECUTIVE ORDERS IMPACTING THE BANKING INDUSTRY: 53 o Declares a State of Emergency pursuant to Miss. Code Ann. 33-15-11(b)(17). o Directs state agencies and departments to utilize state resources and to do everything reasonably possible to assist communities and entities affected by the COVID-19 outbreak (Miss. Code Ann. 33-15-11(c)). o Directs that the provisions of state statutes, rules, regulations or orders may be temporarily suspended or modified if compliance with such provisions would prevent, hinder, or delay action necessary to cope with the COVID-19 outbreak (Miss. Code. Ann. 33-15-11(c)(1). • Executive Order No. 1463: March 24, 2020 (Essential Services) o Provides that “essential services” include “financial services including banks and related financial institutions, insurance, payroll, accounting, processing financial transactions, services related to financial markets….” o Supplement to order issued March 26, 2020. Clarifies authority of political subdivisions to impose restrictions regarding essential services. The following Executive Orders can be found at this link. https://governorreeves.ms.gov/covid-19/#executiveOrders • Proclamation: March 14, 2020 (State of Emergency)
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