Banking Agencies Update “Host State Loan-to-Deposit Ratios” For 2020

The Federal Reserve Board, the FDIC and the OCC (collectively, the “Agencies”) updated “host state loan-to-deposit ratios” for 2020.

The ratios are used in assessing compliance with Section 109 of the Riegle-Neal Interstate Banking and Branching Efficiency Act of 1994, which prohibits a bank from establishing or acquiring a branch or branches outside its home state primarily for the purpose of deposit production. Congress enacted section 109 to ensure that interstate branches would not take deposits from a […]

By | June 1st, 2020 ||

Federal Reserve Banks And Federal Home Loan Banks May Accept Pledges Of PPP Loans As Collateral

The Small Business Administration’s (“SBA”) Paycheck Protection Program (“PPP”) guarantees loans from qualified lenders to small businesses impacted by the COVID-19 pandemic so that those businesses can keep workers employed. In the Third Interim Final Rule issued on April 20, 2020 (see 85 Fed. Reg. 21747), the SBA cleared the way for members of Federal Reserve Banks (“FRB”) and Federal Home Loan Banks (“FHLB”) to pledge PPP loans to secure borrowings by excluding the […]

By | May 23rd, 2020 ||

Federal Reserve Bank Of NY Releases Guidance To Terms Of Primary Market Corporate Credit Facility And Secondary Market Corporate Credit Facility

The Federal Reserve Bank of New York (“NY Fed”) published additional guidance for the Primary Market Corporate Credit Facility (“PMCCF”) and the Secondary Market Corporate Credit Facility (“SMCCF”, and, jointly, the “Facilities”). The term sheets for the Facilities were originally published by the Federal Reserve Board on April 9, 2020, and can be found at https://www.federalreserve.gov/newsevents/pressreleases/monetary20200409a.htm.

The PMCCF will provide a funding backstop for corporate debt to eligible issuers so that they are better able to […]

By | May 17th, 2020 ||