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Proposal:

1712(AF86) Reg Q; Paycheck Protection Program Lending Facility and Paycheck
Protection Program Loans

Description:
Comment ID:

137244

From:

Horizon Community Bank, Ralph Tapscott

Proposal:

1712(AF86) Reg Q; Paycheck Protection Program Lending Facility and Paycheck
Protection Program Loans

Subject:

Regulatory Capital Rule: Paycheck Protection Program Lending Facility and
Paycheck Protection Progra

Comments:
Date:May 06, 2020
Proposal:Regulatory Capital Rule: Paycheck Protection Program Lending Facility and Paycheck [R1712]
Document ID:R-1712
Revision:1
First name:Ralph
Middle initial:
Last name:Tapscott
Affiliation (if any):Horizon Community Bank
Affiliation Type:Commercial (Com)
Address line 1:225 N. Lake Havasu Avenue
Address line 2:
City:Lake Havasu City
State:Arizona
Zip:86403
Country:UNITED STATES
Postal (if outside the U.S.):
Your comment:We know there is guidance on how to treat, for regulatory capital requirements, the
impact of PPP loans and the offset of the PPPLF. I would like guidance on treatment of just the PPP
portion on the asset side of our balance sheet if we have not leveraged it by using the PPPLF. It
seems some type of reprieve should be granted for banks that have not had to leverage the liability
side of their balance sheet to promote this program.