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Financial Services Law Insights and Observations

Louisiana Office of Financial Institutions issues declaration to state-chartered financial institutions

State Issues Covid-19 Louisiana Financial Institutions SBA Shareholders

State Issues

On June 5, the Louisiana Office of Financial Institutions issued an emergency declaration granting parity to Louisiana state-chartered financial institutions with federally-chartered financial institutions as it relates to loans made under the Small Business Administration’s Paycheck Protection Program. As such, loans made under the program will be excluded from the legal lending limits of Louisiana state-chartered institutions. This guidance follows previous guidance issued by Louisiana on the same topic, which was previously discussed here. Further, the emergency declaration grants state-chartered financial institutions the authority to (i) temporarily close an existing branch office; (ii) establish a temporary location; and (iii) reduce operations, products, and services. Additionally, state-chartered financial institutions unable to comply with Louisiana law regarding annual meetings may, provided certain requirements are met, (i) permit shareholders or members to participate by means of remote communication or (ii) hold the annual meeting without a physical location. The declaration is effective until June 26, 2020, unless terminated sooner.