Monday, October 25, 2021

Common questions answered about PPP reopening

Here are additional details from the SBA’s Dustin Allen regarding the Paycheck Protection Program reopening set for next week.

1. There hasn’t been an application released yet for either of the new PPP loan options. We know there will be one released for the Second Draw PPP loans due to the program changes. We are waiting on further guidance on if a new application will be released for First Draw PPP loans or if we will use the one from the original rollout.

2. We haven’t been given information on the portal that will be used. I’ve heard from lenders we will use ETRAN, the AWS portal or that there will be an entirely new portal rolled out. At this time the PPP team hasn’t provided us with this info.

3. I have sent up for clarification on if a Second Draw PPP loan needs to have the original PPP loan forgiveness payment received or not. These questions are usually asked due to the IFR requirement that the borrower cannot have an unresolved first round PPP loan, they cannot currently be in a review status and/or the requirement that Round 1 PPP funds were used exclusively on approved expenses.

4. I just received definition of a CFI, which is listed below.

Per the Economic Aid Act, a Community Financial Institution (CFI) is one of the four types of lenders. CFIs will be able to submit First Draw (first time) PPP loans starting Monday, Jan. 11. Second Draw (second time) loans starting next Wednesday, Jan. 13.

• Community Financial Development Institution (CDFI).

• Minority Depository Institution (MDI).

• Community Development Corporation (CDC).

• Microlender Intermediary.


See 15 USC citation below highlighted in yellow. We should have it covered.

Statute – section 23(d)(1)(A)(i) –

(36) Paycheck protection program.-

(x) the term “community development financial institution” has the meaning given the term in section 4702 of title 12); 5
(xi) the term “community financial institutions” means-
(I) a community development financial institution;
(II) a minority depository institution, as defined in section 308 of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (12 U.S.C. 1463 note);
(III) a development company that is certified under title V of the Small Business Investment Act of 1958 (15 U.S.C. 695 et seq.); and
(IV) an intermediary, as defined in subsection (m)(11); and