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SUBSEQUENT EVENTS SUBSEQUENT EVENTS
3 Months Ended
Mar. 31, 2020
Subsequent Events [Abstract]  
SUBSEQUENT EVENTS
17. SUBSEQUENT EVENTS

On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security ("CARES") Act was signed into law. It contains substantial tax and spending provisions intended to address the impact of the COVID-19 pandemic. The CARES Act included an allocation of $349 billion for loans to be issued by financial institutions through the Small Business Administration (“SBA”). This program is known as the Paycheck Protection Program (“PPP”). PPP loans are forgivable, in whole or in part, if the proceeds are used for payroll and other permitted purposes in accordance with the requirements of the PPP. These loans carry a fixed rate of 1.00% and a term of two years, if not forgiven, in whole or in part. Payments are deferred for the first six months of the loan. The loans are 100% guaranteed by the SBA. The SBA pays the originating bank a processing fee ranging from 1% to 5%, based on the size of the loan. From April 3, 2020, the date the SBA began accepting submissions for the initial round of PPP loans through April 16, 2020, the date the SBA reached the limit of funds available to disburse under the initial round of the program, the Company received approval from the SBA on over 4,100 loans totaling approximately $475 million. As the initial $349 billion allotted for PPP loans ran out in less than two weeks, an additional $310 billion was added to the program. From April 27, 2020, the date the SBA began accepting submissions for the second round of PPP loans through April 30, 2020, the Company received approval from the SBA on over 1,500 loans totaling approximately $66 million. Certain PPP loans approved by the SBA may be cancelled or withdrawn prior to closing and funding. Although the Company believes that the majority of these loans will ultimately be forgiven by the SBA in accordance with the terms of the program, there could be risks and liability to the Company associated with participation in the program that cannot be determined at this time.

In April 2020, various regulatory agencies, including the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation, (“the agencies”) issued a revised interagency statement encouraging financial institutions to work with customers affected by COVID-19 and providing additional information regarding loan modifications. The revised interagency statement clarifies the interaction between the interagency statement issued on March 22, 2020 and the temporary relief provided by Section 4013 of the CARES Act. Section 4013 allows financial institutions to suspend the requirements to classify certain loan modifications as TDRs. The revised statement also provides supervisory interpretations on past due and nonaccrual regulatory reporting of loan modification programs and regulatory capital. In response to the COVID-19 pandemic, the Company is providing 3-month principal and interest payment deferrals for its residential mortgage and consumer customers. The Company is also deferring either the full loan payment or the principal component of the loan payment for 3 to 6 months for its commercial real estate and commercial and industrial customers on a case-by-case basis depending on need. The Company executed loan deferrals on outstanding balances of approximately $65 million through March 31, 2020. As of April 30, 2020, the Company executed loan deferrals on outstanding balances of approximately $453 million, which includes the loans deferred during the first quarter of 2020, and is approximately 10% of the Company’s total loan portfolio. In accordance with the revised interagency guidance issued in April 2020, these short-term deferrals are not presently considered TDRs and at this time interest has continued to accrue. Collectibility of the accrued interest on deferred loans is uncertain and the Company may need to reverse the accrued interest which may negatively impact interest income in future periods.
Additional loan modifications to capitalize interest and/or extend loan terms may also be necessary. The Company anticipates increased requests for loan deferrals in the second quarter of 2020.