REDLINE Form Draft

DRAFT REDLINE 2014 Annual Lending Survey 12-2-14.docx

Small Business Lending Fund - Lending Survey

REDLINE Form Draft

OMB: 1505-0246

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U .S. Department of the Treasury



Lending Survey for Institutions Participating in the Small Business Lending Fund

INSTRUCTIONS

Treasury appreciates your institution’s accurate and timely completion of this survey. Completion of this survey is required by Section 3.1(c)(ii)(D) of your Securities Purchase Agreement. This survey includes questions about your institution’s small business lending policies and practices, its use of SBLF funding, and its efforts to engage in outreach activities with respect to small business lending. The survey questions are directed towards activities that have occurred over the year ended June 30, 20143. The information requested in this survey is not reported on your institution’s call reports and cannot be calculated from information reported on those call reports. Please answer all questions completely and accurately.


DEFINITIONS

Small business lending: For the purpose of this survey, small business lending means the “Qualified Small Business Lending” that your institution reports on the Supplemental Reports it submits to Treasury. Such lending includes business loans that are (a) $10 million or less in amount to businesses with $50 million or less in revenue and (b) included in one of the following categories: (i) commercial and industrial loans, (ii) owner-occupied nonfarm, nonresidential real estate loans, (iii) loans to finance agricultural production and other loans to farmers, and (iv) loans secured by farmland; in each case, subject to the adjustments for Qualified Small Business Lending provided for in the Supplemental Reports.

Applications for loans or credit lines: Applications submitted for new, renewal, increases in outstanding, or extensions or modifications of outstanding loans (or credit lines) that your institution considered over the past year and that, if approved and funded, would qualify for small business lending.

New loans or and increases in outstanding loans or credit lines: New loans (or credit lines) or increases in the dollar value of existing loans (or credit lines) that your institution approved and funded over the past year and that qualify as small business lending.

Extensions or modifications of existing loans or credit lines: Extensions of outstanding loans or credit lines: The entire dollar value Renewed loans (or credit lines) orof any loan or credit line attributable to extensions or modifications to the term of in the term of existing loans (or credit lines) your institution approved and funded over the past year and that qualifyies as small business lending. Include refinancing, restructuring, or other changes in terms as renewals and extensions of credit.


SUBMISSION OF THIS SURVEY

Please submit this Lending Survey by February XX10, 20154 by electronically entering the report data directly into the Survey form and emailing the completed copy to Treasury at SBLFComplSubmissions@treasury.gov. For institutions using digital signatures, the completed electronic survey is submitted as a single document. For institutions using handwritten signatures, both the completed electronic survey and a scanned copy of the entire survey, including the signature page, must be submitted.


FREEDOM OF INFORMATION ACT

Please note that any information submitted by participants may become subject to public disclosure pursuant to the terms of the Freedom of Information Act, 5 U.S.C. 552 (FOIA) and its exemptions. Nevertheless, Treasury’s FOIA regulation, 31 C.F.R. 1.1 et seq., provides that, in certain cases, businesses that submit information to Treasury shall receive notice of a pending FOIA request for that information, as well as an opportunity to object to the disclosure of any or all of that information on the grounds that the information qualifies for withholding under FOIA Exemption 4. See 31 C.F.R. 1.6.


To facilitate this business submitter notification process, Treasury encourages respondents to designate any such information that they believe, in good faith, is subject to FOIA Exemption 4. Such designations will help Treasury to recognize instances in which business submitter notification may be appropriate. Treasury reserves sole discretion to determine whether such designated information indeed qualifies for business submitter notification and, ultimately, whether it qualifies for withholding pursuant to FOIA Exemption 4. If you wish to identify any information in this survey that you believe is subject to FOIA Exemption 4, please identify that information and the reasons for your request on attached pages.


QUESTIONS

Please email SBLFInstitutions@treasury.gov if you have any questions regarding the completion of this survey.

The Federal Government may not collect, and the public is not required to respond to, a collection of information that does not display a currently valid OMB Control Number. The control number for this collection is 1505-0246. The public reporting burden for this information collection is estimated to average 8 hours per response, including time to gather and maintain data in the required form and to review instructions and complete the information collection. This information collection is set to expire on 08/31/2015.





Part I. Small Business Lending Policies

For Questions 1-5, please select one button in each row that most closely describes the change in lending policies or lending demand. Please do not select more than one button in any given row.

Questions 1-3 request information regarding changes in your institution's small business lending policies over the year ended June 30, 20132014. If your institution's small business lending policies have not changed over the year, please report them as unchanged even if the policies are either restrictive or accommodative relative to longer-term norms. If your institution's policies have tightened or eased over the year, please report them, regardless of how they stand relative to longer-term norms. Also, please report changes in enforcement of existing policies as changes in policies.


  1. Over the year ended June 30, 20132014, how have your institution’s credit standards for approving applications for loans (or credit lines) that qualify as small business lending—other than those used to finance mergers and acquisitions—changed?




Not Applicable

Tightened considerably

Tightened somewhat

Remained basically unchanged

Eased somewhat

Eased considerably

  1. Commercial and industrial







  1. Owner-occupied nonfarm, nonresidential real estate







  1. Agricultural production







  1. Secured by farmland







  1. Overall small business lending


















  1. For applications for loans (or credit lines) that qualify as small business lending—other than those used to finance mergers and acquisitions—that your institution currently is willing to approve, how have the terms of those loans changed over the year ended June 30, 20143?


Tightened considerably

Tightened somewhat

Remained basically unchanged

Eased somewhat

Eased considerably

  1. Maximum size of loans (or credit lines)






  1. Maximum maturity of loans (or credit lines)






  1. Costs of loans (or credit lines)






  1. Spreads of rates over your institution’s cost of funds (wider spreads=tightened, narrower spreads=eased)






  1. Premiums charged on riskier loans (or credit lines)






  1. Covenants






  1. Collateralization requirements






  1. Use of interest rate floors (more use=tightened, less use=eased)










  1. If your institution has tightened or eased its credit standards or terms for approving and funding loans (or credit lines) that qualify as small business lending over the year ended June 30, 20132014, how important have been the following possible reasons for the change?



  1. If your institution’s answer to any part of question (1) or question (2) is “tightened considerably” or “tightened somewhat,” how important have been the following possible reasons for the change?


Not important

Somewhat important

Very important

  1. Deterioration in your institution’s current or expected capital position




  1. Less favorable or more uncertain economic outlook




  1. Worsening of industry-specific problems (please specify industries in space below)




  1. Less aggressive competition from other financial institutions




  1. Reduced tolerance for risk




  1. Decreased liquidity in the secondary market for these loans (or credit lines)




  1. Deterioration in your institution’s current or expected liquidity position




  1. Increased concerns about the effects of legislative changes, supervisory actions, or changes in accounting standards






  1. If your institution’s answer to any part of question (1) or question (2) is “eased considerably” or “eased somewhat,” how important have been the following possible reasons for the change?


Not important

Somewhat important

Very important

  1. Improvement in your institution's current or expected capital position




  1. More favorable or less uncertain economic outlook




  1. Improvement in industry-specific problems (please specify industries in space below)




  1. More aggressive competition from other financial institutions




  1. Increased tolerance for risk




  1. Increased liquidity in the secondary market for these loans (or credit lines)




  1. Improvement in your institution's current or expected liquidity position




  1. Reduced concerns about the effects of legislative changes, supervisory actions, or

changes in accounting standards





If either “improvement” or “worsening” of industry-specific problems is selected in question (3) as “somewhat important” or “very important” (i.e., option (c) in section A or B), please specify the industries and problems.




  1. How has demand for loans (or credit lines) that qualify as small business lending changed over the year ended June 30, 20143? (Please consider inquiries and applications for new, renewal, increases in outstanding, or extensions or modifications to the term of outstanding loans or credit lines.)



Not Applicable

Substantially stronger

Moderately stronger

About the same

Moderately weaker

Substantially weaker

  1. Commercial and industrial







  1. Owner-occupied nonfarm, nonresidential real estate







  1. Agricultural production







  1. Secured by farmland







  1. Overall small business lending









  1. If demand for loans (or credit lines) that qualify as small business lending has strengthened or weakened over the year ended June 30, 20132014, how important have been the following possible reasons for the change?


  1. If your institution’s answer to any part of question (4) is “substantially stronger” or “moderately stronger,” how important have been the following possible reasons for the change?


Not important

Somewhat important

Very important

  1. Customer inventory financing needs increased




  1. Customer accounts receivable financing needs increased




  1. Customer investment in plant or equipment increased




  1. Customer internally generated funds decreased




  1. Customer merger or acquisition financing needs increased




  1. Customer borrowing shifted to your institution from other bank or nonbank sources because these other sources became less attractive




  1. Other (specify):______________________________________________________





  1. If your institution’s answer to any part of question (4) is “substantially weaker” or “moderately weaker,” how important have been the following possible reasons for the change?


Not important

Somewhat important

Very important

  1. Customer inventory financing needs decreased




  1. Customer accounts receivable financing needs decreased




  1. Customer investment in plant or equipment decreased




  1. Customer internally generated funds increased




  1. Customer merger or acquisition financing needs decreased




  1. Customer borrowing shifted from your institution to other bank or nonbank credit sources because these other sources became more attractive




  1. Other (specify):______________________________________________________





Questions 6-10 ask about your institution’s practices regarding applications for and approvals of loans (or credit lines) that qualify as small business lending over the year ended June 30, 20132014.

  1. For applications for loans (or credit lines) that qualify as small business lending and that your institution did not approve over the year ended June 30, 20132014, how significant were the following possible obstacles?


Not significant

Somewhat significant

Very significant

  1. Collateral – applicants lacked the assets required for use as security




  1. Returns – applicants did not generate high enough returns to attract risk investors or had insufficiently high levels of profitability, liquidity, or stability




  1. Risks – applicants lacked satisfactory business plans or were risky for other reasons




  1. Other (specify): ______________________________________________________






  1. This question asks for information on loans (or credit lines) that your institution considered or approved and funded over the year ended June 30, 20132014 and that qualify as small business lending. The information requested is from your institution’s lending data on the volume of loans (or credit lines) it considered or approved and funded from July 1, 20132 to June 30, 20132014. Like other questions on this survey, the information requested in this question is not reported on your institution’s call reports and cannot be calculated from information reported on those call reports. The definition of small business lending is included on the first page of this survey. Among other things, this definition excludes any government guaranteed portion of loans (or credit lines).



Commercial and industrial

Owner-occupied nonfarm, nonresidential real estate

Agricultural production

Secured by farmland

  1. Total number of applications for loans or credit lines

  1. New or increases in outstanding credit





  1. Renewals or eExtensions or modifications to the term of of outstanding credit





  1. Total number of loans or credit lines approved and funded

  1. New or increases in outstanding credit





  1. Extensions or modifications to the term of of outstanding creditRenewals or extensions of outstanding credit





  1. Total dollar value of loans or credit lines approved and funded (in thousands)

  1. New or increases in outstanding credit





  1. Extensions or modifications to the term of of outstanding creditRenewals or extensions of outstanding credit





  1. Total number of loans or credit lines approved and funded by size

  1. $100,000 or less





  1. More than $100,000 up to $250,000





  1. More than $250,000 up to $1,000,000





  1. More than $1,000,000 up to $10,000,000





  1. Total dollar value of loans or credit lines approved and funded by size (in thousands)

  1. $100,000 or less





  1. More than $100,000 up to $250,000





  1. More than $250,000 up to $1,000,000





  1. More than $1,000,000 up to $10,000,000





  1. Total dollar value of loans or credit lines approved and funded by length of term (in thousands)

  1. Less than one year





  1. One-to-two years





  1. More than two years, but less than five years





  1. More than five years





  1. Total dollar value of loans or credit lines approved and funded by type of interest rate (in thousands)

  1. Fixed





  1. Adjustable Rate (at time of origination)





  1. Average interest rate of loans or credit lines funded by type

  1. Fixed

%

%

%

%

  1. Adjustable Rate (at time of origination)

%

%

%

%





  1. Over the year ended June 30, 20132014, estimate the percentage of the total dollar value of loans (or credit lines) that qualify as small business lending that your institution has approved and funded in each of the following categories of businesses, as defined by the North American Industry Classification System (NAICS). Please include owner-occupied nonfarm, nonresidential real estate loans (or credit lines) that qualify as small business lending in the industry category in which the occupant participates. The sum of the percentages should total 100 percent.

  1. Manufacturing

%

  1. Construction

%

  1. Transportation

%

  1. Communication

%

  1. Wholesale trade

%

  1. Retail trade

%

  1. Service

%

  1. Agricultural

%

  1. Other (specify): ______________________________________________________________________________

%

Total

%


  1. Over the year ended June 30, 20132014, estimate the percentages of the total dollar value of loans (or credit lines) that qualify as small business lending and that your institution has approved and funded that are secured by collateral and those that are not. The sum of the percentages should total 100 percent.

  1. Secured by collateral

%

  1. Unsecured by collateral

%

Total

%


For those loans (or credit lines) made by your institution over year ended June 30, 20132014 that are secured by collateral, estimate the percentages of those loans in each of the following categories. For loans (or credit lines) that are secured by more than one type of collateral, please include these in all categories that apply. The sum of the percentages may exceed 100 percent.

  1. Secured by business-owned real estate collateral

%

  1. Secured by business-owned non-real estate collateral

%

  1. Secured by personal collateral

%

  1. Other (specify): ______________________________________________________________________________________

%


Part II. Use of SBLF Funding

Treasury understands that the cash associated with SBLF funding may not be readily distinguishable from other cash sources and that your institution may need to estimate how the SBLF funding was deployed or how many SBLF dollars were allocated to each use.

  1. Over the year ended June 30, 20132014, what action(s) was your institution able to take that your institution may not have taken without the SBLF funding? Please select all responses in the following chart that apply to your institution. In the space below the chart, elaborate on each action(s) as appropriate.


  1. Increase small business lending or reduce it by less than otherwise would have occurred


  1. Increase other business lending or reduce it by less than otherwise would have occurred


  1. Increase other non-business lending or reduce it by less than otherwise would have occurred


  1. Increase securities purchased (e.g., ABS, MBS)


  1. Make other investments


  1. Increase reserves for non-performing assets


  1. Reduce borrowings


  1. Increase charge-offs


  1. Purchase another financial institution or purchase assets from another financial institution


  1. Held as non-leveraged increase in total capital (i.e., strengthened capital position)


  1. Pay dividends or redeem outstanding equity or debt


  1. Other (specify):______________________________________________________________________________



For each action(s) your institution selected above, please estimate the magnitude and elaborate as appropriate, especially if the action(s) has changed over the year ended June 30, 20132014.




  1. As of June 30, 20132014, for each of the following categories of loans (or credit lines), has your institution increased its small business lending by greater than, less than, or about the same amount as it expected over this period at the time it received the SBLF investment?




Not Applicable

Greater than expected

Less than

expected

About the same

  1. Commercial and industrial





  1. Owner-occupied nonfarm, nonresidential real estate





  1. Agricultural production





  1. Secured by farmland





  1. Overall small business lending






For those categories of loans (or credit lines) in which your institution’s lending was “greater than expected” or “less than expected,” please describe the reasons for this outcome.





Part III. Small Business Outreach Activities

Per Section 4103(d)(8) of the Small Business Jobs Act of 2010, SBLF participants are required to provide linguistically and culturally appropriate outreach and advertising describing the availability and application process of receiving loans through the use of print, radio, television, or electronic media outlets that target organizations, trade associations, and individuals that represent or work with or are (a) members of minority communities, (b) women, and/or (c) veterans.

  1. Over the year ended June 30, 20132014, which of the following outreach and advertising activities designed to target small businesses owned by members of minority communities, women, and/or veterans has your institution engaged in? Please select all responses in the following chart that apply to your institution or select “(g)” for no activities.


  1. Paid advertisement or notices in print, radio, TV, or electronic media communications


  1. Outreach to media outlets, press, or reporters


  1. Membership or participation in community organizations and/or trade associations


  1. Distributing marketing materials targeted to these groups


  1. Hiring or training staff to conduct outreach to these groups


  1. Other (specify):______________________________________________________________________________


  1. No activities




  1. Please estimate your institution’s total expenditures over the year ended June 30, 20132014 associated with outreach and advertising activities to small businesses. Your estimate should include expenditures on activities designed to target small businesses owned by members of minority communities, women, and/or veterans. Separately, estimate the dollar value of your institution’s total expenditures that were designed to target small businesses owned by members of minority communities, women, and veterans, respectively. For activities designed to target more than one of these groups, divide the expenditures between the groups as appropriate.



  1. Dollar value of total expenditures on outreach and advertising activities that target small businesses


  1. Dollar value of expenditures in (13a) that target small businesses owned by members of minority communities


  1. Dollar value of expenditures in (13a) that target small businesses owned by women


  1. Dollar value of expenditures in (13a) that target small businesses owned by veterans







Please describe the outreach and advertising activities designed to target small businesses owned by members of minority communities, women, and/or veterans that your institution engaged in.






Part IV. Repayment of SBLF Funding

Questions 14-167 assist the Department of Treasury into managingadminister the SBLF program. The responses provided below are not binding or used as official notice of action for participating firms. It is expected and understood that the institutions’ plans will evolve over time, so please complete each question to the best of your current knowledge and planning.


  1. If your institution has completed a partial redemption to date, please describe the reasons for doing so below.




  1. Please estimate the calendar quarter and year in whichIf your institution anticipates fully redeemingplans to redeem Treasury’s investment and exiting, provide an estimate of the calendar quarter, year, and percent of total outstanding Treasury Investment for each of the SBLF program. expected redemptions. If your institution does not anticipate redeeming Treasury’s investment, please indicate this by selecting N/A below and leave leaving blank questions (156) and (167).


1

2

3

4

Calendar Quarter





Year





Percent of Total Outstanding Balance





  1. What factor(s) most influence your institution’s anticipated timing for exiting the SBLF program? PleaseIf multiple reasons exist, please select all responseseach applicable option provided below and provide any reason not included in the following chart that apply to your institution.“Other”.


  1. Dividend or interest rate rises to 9 percent after the initial period (or 13.8 percent for S corps and mutuals)1


  1. Current dividend or interest rate is unattractive


  1. Lack of opportunities to deploy capital


  1. Other (specify):______________________________________________________________________________



  1. When your institution exits the SBLF program, how does it plan to replace the SBLF capital? Please select all responses in the following chart that apply to your institution. If multiple reasons exist, please select each applicable option provided below and provide any reason not included in “Other”.



  1. Plan to replace capital through an equity offering


  1. Plan to replace capital with retained earnings


  1. Will not need to replace SBLF capital as we presently hold surplus capital


  1. Replace capital through loan, debt offering, or debt obligation


  1. Other (specify):______________________________________________________________________________




General comments:






SIGNATURE
I attest that this Lending Survey is prepared in conformance with the instructions issued by the Treasury, fully completed, and is true and correct to the best of my knowledge and belief.

______________________________________________________ ______________________________________________________________

Signature of Authorized Official Date Name / Title of Authorized Official

______________________________________________________ ______________________________________________________________

Name of Institution City State Zip


SBLF#







1 Please note, for any SBLF banking institutions, the step-up rate will go into effect on the day of the 4 ½ year anniversary of Treasury’s initial investment. For SBLF CDLFs the step-up rate will go into effect on the day of the 8 year anniversary of Treasury’s initial investment.

L ending Survey 1


Treasury Department Form: TDF 102.6 OMB Number 1505-0246

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