Feeling bloated after the holiday?

Uncategorized Jan 18, 2021

Well, you are not alone.  Your Bank is likely feeling bloated after this unprecedented year of PPP loans and the excess liquidity that most banks have on their balance sheets.


To deal with the Bank’s bloating, the regulators have offered a solution. In acknowledgement of the bloating that has taken place this year,  your Bank has been offered a hall-pass on reporting requirements that kick into play upon a bank reaching a new asset-based Call Report threshold.  In addition,  the FDICIA audit and certification requirements are also subject to the hall-pass if your Bank’s asset size as of January 1, 2020 was below the impact threshold for Part 363 of the FDI Act.


Keep in mind, you only get the hall-pass if your Bank’s balance sheet is inflated due to funding PPP loans or the money market mutual funds purchased as a result of participating in the FRB of Boston’s Money Market Mutual Fund Liquidity program. 


To learn more about the hall-pass, and how it might apply to your Bank,  please refer to our Call Report Resources site to access information as issued in the applicable Financial Institution Letters (FIL).


With regard to your personal over-indulgence that may be causing a post-holiday meal bloat, I can only offer the following:   Drink lots of water, take a walk, drink some hot tea, cut back on the alcohol (that is no fun), avoid carbonated beverages and avoid chewing gum!


Until the next time,




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