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The Small Business Administration last night issued an interim final rule providing clarity on the 10-day loan disbursement requirement under the Paycheck Protection Program, as well as the filing required to receive the lender processing fee. Moving forward, lenders must make a full, one-time disbursement of PPP loan funds within 10 calendar days of the loan being approved—that is, when …
April 2020
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April 26, 2020
SBA announces measures aimed at smoothing operations ahead of PPP restart
Breaking news from the ABA: With the U.S. Small Business Administration expecting a high volume of Paycheck Protection Program loan applications when the E-Tran system reopens at 9:30 a.m. tomorrow, SBA today notified lenders of several steps it will take to ensure the smooth operation of the program, including pacing the number of loans processed once the system reopens. Acknowledging …
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April 25, 2020
OBA President/CEO Roger Beverage addresses concern for the PPP
MEMORANDUM TO: All OBA Chairmen, Presidents, CEOs and CFOs RE: Good Faith Certification Good afternoon: Some additional guidance was released by the Treasury Department this week, and I found it very troubling. Here’s why. Question #31 was added to the Treasury’s list of FAQs last Thursday. You may recall that there has been some controversy about whether large organizations, like …
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April 25, 2020
SBA issues guidance on calculating max PPP loan size
Breaking news from the ABA: With the Small Business Administration reopening its E-Tran system for Paycheck Protection Program applications on Monday morning, SBA last night issued guidance to help borrowers and lenders calculate and document the maximum PPP loan amount a business may be eligible for. The guidance covers several situations about which lenders have sought clarity. The guidance addresses …
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April 24, 2020
PPP loans to resume on Monday morning
Paycheck Protection Program loans will resume through the Small Business Administration’s E-Tran platform at 9:30 a.m. (CDT) Monday. President Trump signed a bill earlier today appropriating more than $320 billion for the PPP. Of this, a minimum of $30 billion will be set aside for community development financial institutions, banks and credit unions with less than $10 billion in assets. …
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April 23, 2020
House approves additional PPP funds, President to sign imminently
Breaking news from the ABA: By a strong bipartisan vote this evening, the House cleared legislation providing more than $320 billion in new funding for the Small Business Administration’s Paycheck Protection Program. The Senate passed the bill earlier this week, and President Trump is expected to sign it shortly. Of the more than $320 billion appropriated for PPP loans, a …
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April 23, 2020
Preparing for round two of the PPP
Breaking news from the ABA: The House is expected this afternoon to approve the bill providing an additional $320 billion in funding for the SBA’s Paycheck Protection Program. The president will sign it expeditiously, and the Treasury has said it will work to get the appropriation to SBA ASAP. We therefore expect the E-Tran system to be reopened as early …
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April 22, 2020
April 2020 OBA Legal Briefs
Coronavirus and Assisting Customers Modify Policies—COVID-19 addendums Assisting borrowers New loans Loans past due or about to be Limits on fee, penalties and interest Regulatory reporting Credit bureau reporting Coronavirus and Assisting Customers By Andy Zavoina (with Pauli Loeffler) There is a risk balance that banks must follow so that in six months or at your next exam, you will …
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April 21, 2020
Senate clears $320B in additional funding for Paycheck Protection Program
Breaking news from the ABA: After bipartisan negotiations, the Senate this afternoon unanimously passed legislation to provide more than $320 billion in new funding for the Small Business Administration’s Paycheck Protection Program. The House must now approve the bill, which it is expected to do in a floor vote later this week. Of the more than $320 billion appropriated for …
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April 21, 2020
Community Bank Solutions
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