We're all learning from each other. To ask a question or share a thought, email us at covid@iowacreditunions.com. We'll share with others on this page.

Frequently Asked Questions (FAQs)

Operations

What would need to be communicated to employees if a "Shelter in Place" order is issued?


Help employees understand that credit unions are essential businesses that need to continue services. Find the Department of Homeland Security’s definition of essential businesses here (financial services on page 11). CEOs in other states have provided copies of W-9 forms and/or letters to their employees citing state mandated verbiage to carry in their cars in case they get pulled over by the police. Click here to find a sample letter. This Memorandum from the Department of the Treasury states that the financial services sector is identified as Critical Infrastructure Sector by the Department of Homeland Security (DHS). *Note: Shelter in Place has not been mandated in Iowa as of April 8, 2020.




What are service options for credit unions without drive-thrus?


There is no clear answer for this, however, you will need to notify the Division if you close your office. Possibly see if other credit unions can help out. Some steps taken by national credit unions are self-distancing tellers, using gloves, taking appointments, promoting phone banking.




Can we reschedule our annual meeting?


Iowa credit unions have the entire calendar year (2020) to hold their annual meetings. Ensure this is done in good faith and well communicated to membership. Contact the Division if this is not an option.




Who do we notify if we close our office?


If there will be a change in your office hours, including closure of a branch location, email kevin.gorman@iowa.gov with the new information. You'll also need to notify the NCUA.




Sharing: How our credit union is helping members


Our management team decided we will waive all late payment fees at least through May 31; allow members to break all or partial amounts of CD’s without penalty; are offering a 2 payment skip pay without a fee to all members in good standing effective immediately; are waiving all NSF and ODP charges for members impacted by job loss or illness effective immediately and to be reviewed for continuation after May 31. Members who have CPI added to their loans will have the premium added to extend their loan rather than adjusting their payments as is required today. Find more stories about how Iowa credit unions are helping their members here.




Where can I find more information about SBA Disaster Loans?


The U.S. Small Business Administration is offering designated states and territories low-interest federal disaster loans for working capital to small businesses suffering substantial economic injury as a result of the Coronavirus (COVID-19). Find more information by visiting the SBA's COVID-19 webpage.




What training is available to help lenders support borrowers in times of stress?


ICUL was made aware of the Question. Persuade. Refer. training through in Iowa Institute of Cooperatives. While this training is geared toward the ag community, information is transferable to all borrowers. Click here for training information.





Employees & HR

What are credit unions doing about employee morale?


Emotional health of employees is key. If an employee is working remotely, consider using Facetime, Zoom or other technology to keep them engaged with management and co-workers. Seeing other co-workers can help an employee better manage working remotely. Consider letting employees wear what they want to wear (as allowed for casual dress under the credit union’s policy) so they feel comfortable at work.




Do you send people home who are not sick, but a family member is?


The CDC recommends they be sent home, as they may be carriers.




What is a resource for unemployment information?


Iowa Workforce Development - www.iowaworkforcedevelopment.gov




If employees go unpaid, when it is appropriate to file for unemployment if at all?


Please reach out to Iowa Workforce Development as they handle unemployment claims. IWD has a number of helpful resources available in response to COVID-19, including how various scenarios are addressed. In some instances it may be appropriate for employees to file for unemployment. Per IWD, effective March 30, 2020, employees who are or will be laid off, or are unable to work for reasons related to COVID-19, will no longer be required to use all paid leave prior to being eligible for unemployment insurance benefits. This change is not retroactive, and claims will not be backdated prior to the week of March 29, 2020, for new or existing claims by individuals who work for employers.




We are under 50 employees but is there any legislation or upcoming legislation that will help us through this?


Families First Coronavirus Response Act: Questions and Answers from the U.S Department of Labor

  • When does the small business exemption apply to exclude a small business from the provisions of the Emergency Paid Sick Leave Act and Emergency Family and Medical Leave Expansion Act?
    • An employer, including a religious or nonprofit organization, with fewer than 50 employees (small business) is exempt from providing (a) paid sick leave due to school or place of care closures or child care provider unavailability for COVID-19 related reasons and (b) expanded family and medical leave due to school or place of care closures or child care provider unavailability for COVID-19 related reasons when doing so would jeopardize the viability of the small business as a going concern. A small business may claim this exemption if an authorized officer of the business has determined that:
  • The provision of paid sick leave or expanded family and medical leave would result in the small business’s expenses and financial obligations exceeding available business revenues and cause the small business to cease operating at a minimal capacity;
  • The absence of the employee or employees requesting paid sick leave or expanded family and medical leave would entail a substantial risk to the financial health or operational capabilities of the small business because of their specialized skills, knowledge of the business, or responsibilities; or
  • There are not sufficient workers who are able, willing, and qualified, and who will be available at the time and place needed, to perform the labor or services provided by the employee or employees requesting paid sick leave or expanded family and medical leave, and these labor or services are needed for the small business to operate at a minimal capacity.
  • If I am a small business with fewer than 50 employees, am I exempt from the requirements to provide paid sick leave or expanded family and medical leave?

    • A small business is exempt from certain paid sick leave and expanded family and medical leave requirements if providing an employee such leave would jeopardize the viability of the business as a going concern. This means a small business is exempt from mandated paid sick leave or expanded family and medical leave requirements only if the:
  • employer employs fewer than 50 employees;
  • leave is requested because the child’s school or place of care is closed, or child care provider is unavailable, due to COVID-19 related reasons; and
  • an authorized officer of the business has determined that at least one of the three conditions described in Question 58 is satisfied.

If providing child care-related paid sick leave and expanded family and medical leave at my business with fewer than 50 employees would jeopardize the viability of my business as a going concern, how do I take advantage of the small business exemption?

  • At this time the Families First Act provides some exemptions for those with less than 50 employees if the plan would result in an economic hardship, but the Department of Labor is still drafting regulations to interpret this. Please see the Davis Brown Law Firm website for current information on the exemption.




If you layoff employees or they go on unemployment, what happens to insurance?


The employer could subsidize the cost of the COBRA. You don’t have to charge the full COBRA rate. If this is done you should consider a specified period of time for the subsidy, like three months or whatever is financially feasible. The employee could go to the government exchange for insurance. Depending on income and family status the employee could receive a subsidy from the exchange. If the credit union works with a benefit broker, see what the broker recommends.




What are some Employee Assistance Program resources?


If you don’t currently offer Employee Assistance Program and you would like to offer free and confidential counseling services to help staff, their dependents and other household members resolve personal issues, a resource could be Employee and Family Resources. Contact them for an overview of services and how you might be able to offer your staff support in a cost effective way.




When does the Families First Coronavirus Relief Act start?


The Department of Labor has set the effective date for April 1, 2020. Check the Davis Brown website for updates.




How do we keep our hourly employees paid?


If the employee is sick due to COVID-19 or is caring for a child whose school or place of care is closed, please refer to the Families First Coronavirus Response Act. Allow employees to use accrued PTO/vacation/sick/disability time, allow employees to work remotely or continue to pay them. If you have to lay off employees, employees do not have to exhaust all other options before filing for unemployment through Iowa Workforce Development (IWD). Please reach out to legal counsel for additional guidance.

You can also check the Davis Brown website.




Is there guidance for laid-off employees who do not return to work?


Iowa Workforce Development issued guidelines for employers to follow follow when workers being recalled from layoffs refuse to return to work. Refusing to return to work when recalled, or in an attempt to continue to draw unemployment benefits, will be considered a "voluntary quit," which would disqualify a claimant from receiving benefits, including the Federal Pandemic Unemployment Compensation benefit of $600 weekly. The six circumstances that are exceptions are: - If you have tested positive for COVID-19 and are experiencing symptoms. - If you have recovered but it caused medical complications rendering you unable to perform essential job duties. - If a member of your household has been diagnosed with COVID-19.- If you are providing care for a member of your household who was diagnosed with COVID-19. - If you do not have child care due to COVID-19 reasons. - If you do not have transportation to your place of work because of COVID-19. Read the full press release here.




Has the Department of Labor issued a small business exemption form under the FFCRA?


Davis Brown Law Firm's Answer:

It is a self-certification and documentation process rather than a formal application. A business needs to document why the exemption applies. An authorized officer must determine that at least one of the following is rue:

  1. The small business cannot afford to provide the requested leave because doing so would cause the business/expenses and financial obligations to exceed available business revenue and cause the business to cease operations at a minimal capacity; or
  2. The employee requesting leave has specialized skills, knowledge of the business, or responsibilities, such that the absence of that employee would pose a substantial risk to the financial health or operational capabilities of the small business; or
  3. The employee requesting leave performs services that are necessary for the business to operate at a minimum capacity, and there are not sufficient workers available to perform those services while the employee is on leave.

So this is done on a case by case purpose.

Please contact legal counsel with questions on this process.





Communications

How do we help remind members of share insurance?


Template communication: < NAME OF CU> wants to remind our members of the safety of your deposits in federally insured credit unions. Federally insured credit unions offer a safe place for credit union members to save money. All deposits at federally insured credit unions are protected by the National Credit Union Share Insurance Fund, with deposits insured up to at least $250,000 per individual depositor. Credit union members have never lost a penny of insured savings at a federally insured credit union. Additional information on National Credit Union Association (NCUA) share insurance coverage for consumers is available at MyCreditUnion.gov. Credit union members can calculate the amount of insured funds at a federally insured credit union using NCUA’s Share Insurance Estimator. The Estimator can be used for personal, business, or government accounts. Personal accounts include individual ownership, joint ownership, payable-on-death (accounts with named beneficiaries), living trusts, and IRAs. The Estimator also includes an extensive Glossary of Terms and Frequently Asked Questions. NCUA is the independent federal agency created by the U.S. Congress to regulate, charter and supervise federal credit unions. With the backing of the full faith and credit of the United States, NCUA operates and manages the National Credit Union Share Insurance Fund, insuring the deposits of account holders in all federal credit unions and the overwhelming majority of state-chartered credit unions.




What do we say to the media if an employee tests positive?


Sample media statement: “At [CREDIT UNION NAME], people always come first. The health and safety of our employees, members and community is of utmost importance and we have closely followed guidance from state and federal authorities since the onset of COVID-19. The employee that tested positive for COVID-19 is self-quarantined and doing well. We are taking all necessary precautions to safely continue the services on which our members rely.”




How can we access ICUL's social media template images?


ICUL will be sharing social media templates for member credit unions to utilize on their social media channels as they would like. You can find these here under Social Media. Find COVID-19 specific social media here.




What tools are people using to host virtual staff meetings?


Looking for a free way to connect your team, board or groups virtually? Zoom offers a simple platform to connect virtually for a 30 minute meeting at no cost.




What are some ways to engage membership during this time?


Consider ramping up your social media presence and really show your credit union's personality. Invite your members to like/follow you on social media for the latest updates about your credit union. Some credit unions are sending postcards to their members in the mail, especially focusing efforts on those who are elderly and may not be as connected online.





Regulatory Compliance

Where do we go for a template business continuity plan?


Your ICUL membership gives you access to PolicyAid from PolicyWorks. There is a templated BCP available in PolicyAid. You will need to customize the plan to your unique situation.




Are we able to modify member loans to help them during this time?


There is already code in place (2502 and 2503) regarding loan modification, small dollar loans and flexibility in loan payments. Any changes to your policies will need to be approved by your board of directors and documentation is required.





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This situation, including the response by the state and federal government, continues to change rapidly. The content is based on information known at the time of posting and may not have yet been updated at the time you view it, so we strongly recommend that you regularly check the resources sent out. Content provided by ICUL is for educational and informational purposes only and is not legal services, legal advice or in any way establishes an attorney-client relationship. Readers should consult an attorney to understand how this content relates to their individual situation.

© 2020 by Iowa Credit Union League