Business Tax Provisions of the Worker, Homeownership, and Business Assistance Act of 2009

On November 6, 2009, President Barack Obama signed into law the Worker, Homeownership, and Business Assistance Act of 2009 (the “Act”). The significant tax changes applicable to businesses under the Act are summarized below.1

Net Operating Loss Carryback. A net operating loss (“NOL”) for a taxable year is the excess of business deductions over the business’ gross income for that taxable year. Under current law, a taxpayer may “carry back” an NOL to offset taxable income of the two tax years immediately prior to the tax year in which the NOL is incurred and may then carry forward any remaining portion of the NOL up to 20 years to offset taxable income in future tax years. Current law also provides that “eligible small businesses” may elect to carry back an “applicable 2008 NOL” for three, four or five years. An “eligible small business” is generally defined as a taxpayer with annual gross receipts of $15,000,000 or less in the tax year in which the applicable 2008 NOL arose. For purposes of the election, an “applicable 2008 NOL” is defined as the taxpayer’s NOL for any tax year ending in 2008, or, at the taxpayer’s election, any tax year beginning in 2008. The election to extend the carryback period is irrevocable and can be made only with respect to one tax year.

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Federal Reserve Requires Banks to Implement New Overdraft Procedures and Related Disclosures

The Federal Reserve emphasized its newly donned role of the consumer protector on November 12, 2009 when it issued final revisions to Regulation E (the “Final Rule”) that will require many banks to revise their existing procedures for paying and disclosing consumer overdrafts that result from automated teller machine (“ATM”) and one-time debit card transactions. Banks are required to achieve full compliance with the Final Rule by July 1, 2010. For many banks, it is likely that full compliance will involve significant operational and processing changes, as well as the implementation of new procedures and new customer disclosures. These types of changes take time to implement, and so we recommend that banks act immediately to assess their overdraft protection services in light of the Final Rule, in order to determine what changes will be necessary to achieve timely compliance.

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Senate Banking Committee Democrats Release Financial Regulatory Overhaul Draft Bill

Today Senate Banking Committee Chairman Christopher Dodd and his Democratic Banking Committee colleagues released draft financial regulatory reform legislation. The new draft legislation comes as the House Financial Services Committee has yet to complete its markup of similar legislation.  Today's released legislation outlines a process for the government to determine which financial companies are more stringently regulated, the regulations to be used and the inner workings with a newly created Agency for Financial Stability.   Additionally, the legislation sets forth a process for winding down such financial companies.  Both the Office of Thrift Supervision and Office of the Comptroller of the Currency would be eliminated under the bill and replaced by a single entity, the Financial Institutions Regulatory Administration.  

Click here for the press release, click here for a summary of the draft legislation and click here for the actual draft legislation.

New CRE Loan Workout Rules Provide Relief and Pitfalls

On October 30, 2009, all of the federal regulatory agencies issued a new policy statement on commercial real estate (“CRE”) loan workouts. The policy statement does offer opportunities for financial institutions (“FI”) to reduce the amount of charge-offs on CRE loans, return restructured loans to a performing status faster and generally work with customers on mutually beneficial workouts. Nonetheless, the policy statement does present challenges before FIs can achieve such results, especially for those management teams seeking to “kick the can down the road” to await better days. Notably, however, the policy statement does not change regulatory reporting guidelines or the accounting requirements under generally accepted accounting principles (“GAAP”).

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