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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. 


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