Wednesday, April 1
8 am AZ time/9 am CO & WY time – WOCCU Webinar: Credit Union COVID-19 Regulatory Issues
12:00pm AZ Time/1:00pm CO & WY Time – Families First Requirements Webinar
Friday, April 3
10:00am WY Time – WY Credit Union’s Conference Call with Congresswoman Liz Cheney
10:00am AZ Time – AZ Credit Union’s Conference Call with Congressman Andy Biggs
Tuesday, April 7
10:00am AZ Time/11:00am CO & WY Time – All CEO Conference Call
Questions for us? email firstname.lastname@example.org and our team will get back to you as soon as possible.
The Association aims to be a resource to you for preparedness. This page serves as a compilation of the latest information, best practices, ideas for member support, communication tips and more in this comprehensive resource area. We are recommending that credit unions review their crisis plans for maintaining operations in the event of a situation that would require limited or widespread closures of their physical facilities. In addition, we recommend designating a spokesperson for the credit union and dedicate a team to monitor the most current guidelines from the Centers for Disease Control and follow accordingly. Additionally, credit unions should be monitoring and/or in contact with their local government health agencies for more local direction regarding business impact and potential closures should the virus spread to their community.
COVID-19 CEO Roundtable – Link to recording
First off, thank you to the 115 folks who were able to join the 3/31 call live. That was a tremendous response and I hope that it proved a valuable use of your time. Now more than ever, our ability to collaborate and help each other is critical. For anyone who could not join, or if you want to revisit the call, here is the link.
Notes can be found here. (3/24/20)
Mark your calendars for next Tuesday, April 7 at 11 in CO & WY/10 in AZ.
Small CU CEO Roundtable – Link to recording
Leaders from credit unions under $50mm in Arizona, Colorado and Wyoming participated in a virtual roundtable to share ideas and discuss unique issues facing smaller institutions. If you missed, or want to revisit the call, here is the link.
Treasury Department Issues Guidance
Last night and earlier this morning, the U.S.Treasury released additional documents for lenders participating in the Paycheck Protection Program.
The new documents include:
Both forms are outlined in the PPP Final Rule that was released on Thursday afternoon. To automatically qualify to make PPP loans, a federally insured credit union must transmit a CARES Act Section 1102 Lender Agreement (SBA Form 3506). New lenders need to submit their application to email@example.com
Once your credit union determines if you will be participating, please let us know, and if that participation is only for your current members. We anticipate questions on referrals of members to other participating credit unions and want to be able to assist with collaboration between our members.
Here is a more detailed interpretation of the interim rule from CUNA’s CompBlog.
NCUA holds Webinar discussing COVID-19 Response
The NCUA held a webinar on 3/31 for Federally insured credit unions to learn more about the agency’s response to the COVID-19 outbreak. During the webinar, NCUA staff discussed recently issued guidance and changes to the agency’s examination program. Some notable items:
- NCUA continues to look for ways to provide regulatory relief – the Agency wants to hear from credit unions
- NCUA has revised rules related to the Central Liquidity Facility to make access to funds easier and quicker
- There is relief provided for TDR designation when credit unions modify loan terms to work with borrowers affected by the Coronavirus
- Eased the requirements for reporting loan modifications under the Current Expected Credit Loss (CECL) rule
- Foreclosure forbearance is not required for portfolio loans but required if a mortgage is purchased or insured or guaranteed by Fannie Mae, Freddie Mac, HUD or the USDA
- Credit unions are encouraged to make prudent small-dollar loans (including to small businesses)
- Relevant federal and state laws must be considered when extending or modifying loans
- NCUA has created a streamlined net worth restoration plan process – credit unions should notify their regulators if a decline in net worth is anticipated below 6%
- The NCUA is developing further guidance regarding relief for mortgage borrowers
- Low Income designated credit unions are encourage to access the Community Development Revolving Loan Fund (CDRLF) for grant and loan assistance
- Review the slide deck to access resources here.
MWCUA Sends letter to AZ. Governor on behalf of the states’ credit unions and members
The Association sent a formal letter to Governor Doug Ducey to update Arizona’s Executive Branch on what Arizona credit unions are doing in response to the coronavirus. In the letter, the Association is also requesting that the Governor sign an executive order that would allow the remote online notarization law to go into effect immediately. In addition, we are requesting that changes be made that will allow liens to be perfected without requirements to physically deliver documents during the crisis.
CARES Act Passes, Signed into law
Below are the key parts of the CARES Act that was signed 3/27.
Section 1102: Paycheck Protection Program
Credit unions can offer small business loans for operational costs: Credit unions will be eligible to participate in the paycheck protection program, which would allow for 100% federally guaranteed loans to small businesses that maintain their payroll, rent, benefits, insurance premiums and other emergency expenses. This is a large lending program through which credit unions can help millions of Americans.
Section 1102 – Temporary Relief from TDR Disclosures
Flexibility to modify loans impaired by COVID-19: Temporary relief from TDR disclosures allows credit unions to modify troubled and other loans in relation to COVID-19 difficulties without being required to comply with FASB Troubled Debt Restructurings by Creditor Accounting Standards.
Section 2301: Employee retention credit for employers subject to closure due to COVID-19
The Employee Retention Payroll Tax Credit or Employer Subject to Closure or 50% Reduction in Gross Receipts does appear to apply to credit unions. The bill provides a refundable payroll tax credit, capped at $10,000.00 per employee, for 50% of wages paid by employers to employees from March 13 through Dec. 31, 2020. Employers qualify if they either (1) are subject to a full or partial shut-down order due to the COVID-19 crisis or (2) see gross receipts decline by more than 50% when compared to the same quarter in the prior year. In the event the qualifying event is a decline in gross receipts, the employer remains eligible for the credit during 2020 until it reaches 80% of gross revenues in a quarter compared to the prior year.
Section 4008: Debt Guarantee Authority
Unlimited federal insurance protection through NCUSIF and FDIC for transaction accounts held at credit unions and banks: By reestablishing the Transaction Account Guarantee Program, the government will guarantee certain noninterest-bearing transaction accounts. This will help credit unions support business and other large accounts.
Section 4014. Optional Temporary Relief from Current Expected Credit Losses
Temporary relief for credit unions currently required to comply with CECL: Affected credit unions have the option to temporarily delay measuring credit losses on financial instruments under the new Current Expected Credit Losses methodology.
Section 4016: Temporary Credit Union Provisions; Expanding Liquidity Temporarily enhances access to the Central Liquidity Facility (CLF)
Increased resources available for liquidity needs: Expanding liquidity temporarily enhances credit union (including corporates) access to the Central Liquidity Facility (CLF). The amendment makes it easier for credit unions to access, which will be essential if there is a higher demand for cash
Section 4021: Credit Protection During Covid-19.
The law amends the Fair Credit Reporting Act to shield borrowers from the reporting of negative information related to pandemic-related loan accommodations.
Section 4022: Foreclosure Moratorium and Consumer Right to Request Forbearance
The bill includes provisions related to forbearances of federally-backed mortgage loans as well as a foreclosure moratorium on those loans during the COVID-19 pandemic. These provisions seem to codify policies already announced by FHFA. CUNA continues to evaluate the impact these policies may have on credit unions and CUSOs.
Best Practices by departments – in the App!
Using the MWCUA App for Real-Time Business Impact Group Conversations
First: If you do not have the app yet, click this to get it:
Also, as mentioned on the call, we have set up forums by departments for you to be able to share and ask questions of each other and/or our staff. The instructions below will get you set up.
If you have the app, please update your profile with this code to get set up in the groups mentioned on the call:
- Please update your Advocacy profile and request the groups to be added to with this link here MWCUA ADVOCATE UPDATE FORM or scan the QR Code above.
- If you are already on the APP – Please give us some time to update users to the app, REFRESH your app to see your groups.
- If you are NOT on the app, use the “get the app” code above, or:
- Once you update the Advocacy update form – Please monitor your email (including Junk/Spam/Other)
- Once you receive the email, it will ask you to log in to and create a password
- Please note, app approval is not immediate, we go through each signup and add to appropriate state and groups
- Please respond to the email sent and correspond with any groups you are associated with (i.e. LPC, Women’s Conference, Regulatory Affairs, Chapters)
- Attached is the MWCUA Sign up instructions to the app – Please use as a resource once you have received your email.
- If you need assistance, please email Christopher Kemm at firstname.lastname@example.org or TEXT 720.256.6672.
Centers for Disease Control & Prevention (CDC)
- CDC 2019 Novel Coronavirus Situation Summary
- Interim Guidance for Businesses and Employers to Plan and Respond to 2019 Novel Coronavirus (2019-nCoV), February 2020
- Business Pandemic Influenza Planning Checklist
- CDC Travel Guidance
- CDC Communication Resources
World Health Organization (WHO)
- WHO Advice for the Public
- Checklist for Pandemic Influenza Risk and Impact Management: Building capacity for pandemic response
- Coronavirus disease (COVID-19) advice for the public: Myth busters
Occupational Safety & Health Administration (OSHA)
- FFIEC IT Examination Handbook – Business Continuity Planning Booklet, Appendix D: Pandemic Planning
- FFIEC IT Examination Handbook – Business Continuity Management Booklet
- Major Disasters: Interagency Examiner Guidance for Institutions Affected by Major Disasters
- Preliminary Coronavirus Financial Industry Common Practices
- For Arizona Financial Institutions
BEWARE OF SCAMS!
MWCUA credit unions assistance, member service information during COVID-19 situation
We are gathering information on what you are doing during this crisis to help your members, as well as any operational changes you’re making (closing lobbies, etc.). That information can be found here. Please contact Patti Hazlett, email@example.com, with any updates for your credit union.
Leading in times of crisis – free resource
Cathy J. Bradley, PhD, Associate Dean for Research, Professor & Deputy Director of the CU Cancer Center @University of Colorado School of Public Health and Randy Walk, President of Hoyt, Inc. in Salt Lake City, Utah discusses Leading in a Time of Crisis.
CUNA/AACUL request input on COVID-19 Response
Similar to what was happening last year during the government shut down, CUNA has begun collecting data to help provide information on what leagues and credit unions are doing during the COVID-19 situation. Earlier today, Jim Nussle and Brad Miller asked credit union leaders across the movement to share how they are equipping their members and employees amid the ongoing coronavirus disease (COVID-19) emergency. This survey by CUNA and AACUL will help us quantify just how credit unions are exemplifying their people-helping-people philosophy by understanding how credit unions are altering branch hours and services, extending financial support to members, and stepping in to cooperatively support credit unions that must close branches due to interactions with the virus.
CUNA/ACCUL, in partnership with Leagues and Associations, has put together a resource page as well. https://www.cuna.org/COVID19/Resources/