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PPP Resource Archive

(May 21 11:30 AM EDT) SBA releases Procedural Notice on Lender Processing Fee Payment and 1502 Reporting Process >
The purpose of this Notice is to inform Paycheck Protection Program (PPP) Lenders of the reporting process through which PPP Lenders will report on PPP loans and collect the processing fee on fully disbursed loans which they are eligible to receive.

 

(May 20 9:00 PM EDT) SBA/Treasury release IFR # 13 - Second Extension of Limited Safe Harbor with Respect to Certification Concerning Need for PPP Loan and Lender Reporting >

 

(May 19 6:30 PM EDT) Treasury FAQ # 48 extends deadline for lenders to upload initial 1502 reporting information

48: Question:  What is the deadline for lenders to complete the initial SBA Form 1502 reporting process?  

Answer: SBA is extending the deadline for lenders to submit the initial SBA Form 1502.  Under SBA’s interim final rule on disbursements, posted April 28, 2020, lenders must disburse PPP loans within 10 calendar days of loan approval; a loan is considered approved when the loan is assigned a loan number by SBA.  That interim final rule also provides that loans for which funds have not been disbursed because a borrower has not submitted required loan documentation within 20 calendar days of loan approval shall be cancelled by the lender.  Previously, the deadline for lenders’ submission of the initial SBA Form 1502 reporting information was May 22, 2020.23  SBA is extending the deadline for lenders to electronically upload the initial SBA Form 1502 reporting information to the later of: (1) May 29, 2020, or (2) 10 calendar days after disbursement or cancellation of the PPP loan.  This extension of the timeline for the initial SBA Form 1502 reporting information will be promptly implemented through revisions to SBA’s interim final rules providing an extension to the certification safe harbor and the deadline for SBA Form 1502 reporting.

 

 

(May 15, 7:30 PM EDT) SBA / Treasury release PPP Loan Forgiveness Application (Form 3508)

11-page application >

SBA Press Release >

 

 

(May 15) NAGGL provides Comment Letters on first two PPP Interim Final Rules

Letter submitted to SBA on IFR # 1 >

Letter submitted to SBA on IFR # 2 >

Letter submitted to SBA on IFR # 3 >

 

URGENT NOTICE FROM SBA

Paycheck Protection Program (PPP) Lending Operations Update – Thursday, May 14, 2020

  1. SBA is launching a new search functionality within the E-Tran Servicing section of the Capital Access Financial System (CAFS). This tool will help PPP lenders review loans in their portfolios. SBA has marked some loans in some lender portfolios as requiring further research. Loan files appearing in “research” status require review by the lender.

    Lenders should review all fields in these files for accuracy and completeness including Borrower Name, Borrower EIN and/or Borrower SSN. If necessary, lenders should contact borrowers to determine whether a loan should be cancelled.  

    Please complete your review and make necessary changes no later than 5 PM EDT on Friday, May 15, 2020. Instructions on how to access CAFS and update records in “Research” status are attached.
  2.  SBA has also implemented changes by which it receives PPP loan data from lenders via E-Tran. Business type will now determine whether a loan application should be submitted with either an SSN or EIN.
  3. An SSN can no longer be used in place of a primary TIN for types of businesses that require an EIN.

SBA and Treasury continue to actively monitor PPP loan systems and will continue to provide updates to the PPP lending community.

RESEARCHING PPP LOAN DATA instructions >

 

 

(May 13 @ 5:00 PM EDT) Interim Final Rule #10: Business Loan Program Temporary Changes; Paycheck Protection Program – Loan Increases

 

(May 13 @ Noon EDT) SBA/Treasury add new FAQ - #46How will SBA review borrowers’ required good-faith certification concerning the necessity of their loan request?

NOTE: Per this FAQ, only loans over $2 million will have their required good-faith certifications reviewed.  For loans of less than $2 million, SBA will deem the borrower’s “certification concerning the necessity of the loan request [to have been made] in good faith”.

(May 12 @ 8:00 PM EDT) NAGGL and CBA send letter to SBA/Treasury outlining key concerns regarding PPP forgiveness >

(May 11 @ 7:00 AM EDT) PPP loan report (as of May 8) >

(May 10 @ 6:00 PM EDT)  SBA publishes Interim Final Rule, Extension of Limited Safe Harbor with Respect to Certification Concerning Need for PPP Loan Request

Amends IFR #4 to extend to May 14 the date by which PPP borrowers can return loan proceeds with no penalty [safe harbor]. Also amends IFR #6 to extend from May 18 to May 22, the date by which lenders must submit their initial SBA Form 1502 reports on PPP loans.  [There will be a specialized 1502 report form for PPP loans.]

(May 7 @ Midnight)  Notice 5000-20025, Temporary Increase in Maximum SBA Express Loan Size and Fee Relief for SBA Express Loans to Veterans 

SBA announced its implementation of two additional provisions in the CARES Act which took effect on the date the Act was signed into law, March 27, 2020:

-- Section 1102(c) temporarily increased the SBA Express maximum loan amount from $350,000 to $1 million.  This temporary increase automatically expires after December 31, 2020.
-- Section 1102(d) permanently set the upfront guaranty fee for SBA Express loans to veteran-owned small businesses at zero.

 

(May 5 @ 8:30 PM EDT) SBA publishes IFR - Nondiscrimination and Additional Criteria > 

 

(May 5 @ 7:00 PM EDT) Treasury publishes 1 new FAQ >
Q#45

(May 5 @ 10:00 PM EDT) Treasury publishes 1 new FAQ>
Q#44

(May 5 @ 7:00 PM EDT) Treasury publishes 1 new FAQ>
Q#43

(May 3 @  11:00 PM EDT) Treasury publishes 3 new FAQ >
Q#40-Q#42

 

(May 6 @ 5:00 PM EDT) SBA releases updated PPP Loan Data as of 5/6/2020 >

(May 3) SBA/Treasury release press statement re: PPP success and program data report (through May 1)

(May 1 5:50 PM EDT) SBA notice provides guidance on procedures to complete whole sales of PPP loans between participating lenders

Procedural Notice 5000-20024 >

(April 30) Federal Reserve Expands Access to Its Paycheck Protection Program Liquidity Facility (PPPLF) to Additional Lenders, and Expands the Collateral That Can Be Pledged

(May 1) IRS Notice regarding the deductibility for Federal income tax purposes of certain otherwise deductible expenses incurred in a taxpayer’s trade or business when the taxpayer receives a PPP loan

 

(April 29) SBA publishes procedural notice on Section 1112 payments >

April 29 12:15 PM EDT) Paycheck Protection Program (PPP) Lending Operations Update – Wednesday, April 29, 2020
From SBA (emphasis added)

"SBA and Treasury value all lenders and their small business customers.

"To ensure access to the PPP loan program for the smallest lenders and their small business customers, starting at 4 p.m. today EDT through 11:59 p.m. EDT, SBA systems will only accept loans from lending institutions with asset sizes less than $1 billion dollars

"Please note, lending institutions with asset sizes less than $1 billion will still be able to submit PPP loans outside of this time frame. Please also note that lenders with asset sizes greater than $1 billion will be able to submit loans outside of today’s 4pm -11:59 pm EDT reserved processing time.

"This reserved processing time applies today April 29, 2020. SBA and Treasury will evaluate whether to create a similar reserved time again in the future. 

"SBA and Treasury continue to monitor loan system performance and will continue to provide frequent updates to the lending community."          

 

April 29 AM

URGENT MESSAGE Regarding loans entered into E-Tran on April 27 prior to 10:30 am (EDT)

SBA’s Capital Access Financial Systems (CAFS) team has advised that loans entered into E-Tran before 10:30 am (EDT) on Monday April 27 were NOT funded.  If you have one of those loans, you will need to log into the web screens to resubmit the loan for SBA approval. CAFS Hotline: 833-572-0502

FAQ

Q1:  Does this impact loans submitted for batch processing via the XML process prior to that time? 
A1:  No, it does not.


Q2: How can a lender identify a loan submission affected by this?
A2: Lenders would know because NO LOAN NUMBER would have been issued.


Q3: Did the entire loan record(s) disappear in E-Tran or have E-Tran numbers been withdrawn?  Does this mean lenders need to go back and look at all their E-Tran loan files?
A3: An affected application would have been submitted into E-Tran prior to 10:30 on Monday, April 27 and would remain in the IP (in process) status.

 

(April 28 11:25 am EDT) PPP Lending Operations Update – Tuesday, April 28, 2020

SBA and Treasury value all lenders and their small business customers.

For the benefit of small business customers and their employees, SBA and Treasury are working on ways to optimize the loan processing system.

Starting today, Robotic Processing Automation (RPA), which are robotic systems used by some banks to mimic human data entry, may not be used to submit Paycheck Protection Program loans into SBA’s E-Tran loan system.  

RPAs burden the processing system and diminish its capabilities. Without RPAs, the loan processing system will be more reliable, accessible, and equitable for all small businesses.    

Application Programing Interface (APIs) will still be permitted. If you are a lender who needs assistance converting your submission process to a non-RPA API, contact Sheri McConville

 

 

(April 27 Noon EDT) Just received information from SBA: PPP Lending Operations Update - Monday, April 27

"SBA and Treasury have updated the guidance for lenders who have received a significant amount of Paycheck Protection Program (PPP) loan applications.

The minimum amount of lender-approved and SBA-ready PPP loans that a lender must have ready for the XML file submission process is now 5,000 loans.

Please note these XML files of 5,000 or more approved PPP loans must be submitted to SBA by 9pm EDT on Monday, April 27, 2020.

SBA and Treasury value all lenders and their small business customers and will continue to provide updates to the PPP lending community as loan processing resumes this week."

Updated info on XML submission guidance >

(April 26 1:50 PM EDT) Just received information from SBA: PPP Lending Operations Update

 

"Due to the unprecedented demand for Paycheck Protection Program loans by the nation’s small businesses and to ensure equitable access and system integrity, SBA and Treasury are taking prudent and reasonable steps to protect SBA’s loan systems for the next phase of PPP loan processing.

"SBA and Treasury are implementing the following measures:

  • Pacing the number of loans processed in the E-Tran system for participating lenders when processing resumes on Monday, April 27, 2020 at 10:30 am EDT;
  • Instituting a maximum dollar amount at 10% of PPP funding authority that any lending institution will be able to originate, exclusive of the additional $60 billion preserved for lenders with assets under $50 billion (i.e. $60 billion cap);
  • Implementing operational standards to ensure that lenders access PPP funds based on their asset size;
  • Ensuring the Paycheck Protection Program continues to operate on a first-come, first-serve basis so that every small business has access to PPP loans to sustain their business and retain their employees; and
  • Issuing the following guidance (memo attached) for lenders who have received a significant amount of loan applications.

"SBA and Treasury value all lenders and their small business customers and will continue to provide updates to the PPP lending community as loan processing resumes this week."

SBA XML submission guidance for PPP loans >

 

 

Lender Assistance Hotline: (833) 572-0502
SBA PPP site >

(April 30 11:30 AM EDT) SBA publishes IFR on Corporate Groups and Non-Bank and Non-Insured Depository Institutions >

(April 29) SBA publishes procedural notice on Section 1112 payments >

(April 28 @ 8:40 PM EDT) SBA publishes Interim Final Rule: PPP - Requirements - Disbursements >

(April 28) SBA publishes Interim Final Rule: PPP Requirements >
Promissory Notes, Authorizations, Affiliation, and Eligibility

(April 28) SBA/Treasury announce PPP loans in excess of $2 million (& others as appropriate) will be reviewed during 'forgiveness' process

(April 27) SBA publishes Interim Final Rule: Additional Criterion for Seasonal Employers >

(April 24 @ 10:00 PM EDT) SBA/Treasury Releases Additional PPP Guidance - How to Calculate Maximum Loan Amounts - by Business Type >

(April 24 @ 10:50 AM EDT)  Interim Final Rule:Business Loan Program Temporary Changes; Paycheck Protection Program Requirements –Promissory Notes, Authorizations, Affiliation, and Eligibility>

(April 14 @ 1:15 PM EDT) 
Interim Final Rule: PPP - Additional Eligibility Criteria and Requirements for Certain Pledges of Loans 

(April 3 @ 11:00 PM EDT) 
Interim Final Rule: PPP - Affiliation Guidance 

(April 2 @ 6:47 PM EDT) 
Interim Final Rule: Paycheck  Protection Program     

 Department of the Treasury PPP site >

(April 29 Midnight EDT) Treasury publishes 1 new FAQ >
Q#39

(April 29) Treasury publishes 1 new FAQ >

Q#38 Addresses PPP eligibility for existing businesses with a change in ownership after 2/15

(April 28) Treasury publishes 1 new FAQ >
Q#37: Do businesses owned by private companies with adequate sources of liquidity to support the business’s ongoing operations qualify for a PPP loan?

(April 26 @ Noon EDT) Treasury adds another FAQ >

Q#36 on definition of employee for loan purposes & loan forgiveness

(April 24 @ 4:50 PM EDT) Treasury publishes 4 new FAQ >

Housing stipend; principal residence in US; Ag producer, farmer, rancher eligibility 

(April 23 @ 10:07 AM EDT) Treasury publishes new FAQ >

Adds Q#31: Do businesses owned by large companies with adequate sources of liquidity to support the business’s ongoing operations qualify for a PPP loan?

 

 

 

(April 28 @ 8:40 PM EDT) SBA publishes Interim Final Rule: PPP - Requirements - Disbursements >

(April 28) SBA publishes Interim Final Rule: PPP Requirements >
Promissory Notes, Authorizations, Affiliation, and Eligibility

(April 28) SBA/Treasury announce PPP loans in excess of $2 million (& others as appropriate) will be reviewed during 'forgiveness' process

(April 27) SBA publishes Interim Final Rule: Additional Criterion for Seasonal Employers >

(April 24 @ 10:00 PM EDT) SBA/Treasury Releases Additional PPP Guidance - How to Calculate Maximum Loan Amounts - by Business Type >

(April 24 @ 10:50 AM EDT)  Interim Final Rule:Business Loan Program Temporary Changes; Paycheck Protection Program Requirements –Promissory Notes, Authorizations, Affiliation, and Eligibility>

(April 24 @ 10:00 PM EDT) SBA/Treasury Releases Additional PPP Guidance - How to Calculate Maximum Loan Amounts - by Business Type >

(April 25 @ 2:28 PM EDT) CLARIFICATION FROM TREASURY on loan calculation guidance:  In FAQ 17, we note that “Borrowers and lenders may rely on the laws, rules, and guidance available at the time of the relevant application.”  In this case, the relevant application is the borrower application.  So any applications received prior to these calculation FAQs do not require re-calculation.

(April 24 @ 4:50 PM EDT) SBA releases Procedural Notice on Participation Sales of PPP Loans

(April 24 @ 4:00 PM EDT) SBA will resume accepting PPP loan applications on Monday, April 27 at 10:30 AM EDT. Read SBA's Press Release >

(April 23 @ 5:40 PM EDT) House passes $484B coronavirus relief package >

(April 23 @ 10:50 AM EDT) Treasury publishes new FAQ

"#31: Question: Do businesses owned by large companies with adequate sources of liquidity to support the business’s ongoing operations qualify for a PPP loan? 

"Answer:  In addition to reviewing applicable affiliation rules to determine eligibility, all borrowers must assess their economic need for a PPP loan under the standard established by the CARES Act and the PPP regulations at the time of the loan application. Although the CARES Act suspends the ordinary requirement that borrowers must be unable to obtain credit elsewhere (as defined in section 3(h) of the Small Business Act), borrowers still must certify in good faith that their PPP loan request is necessary. ... Lenders may rely on a borrower’s certification regarding the necessity of the loan request. Any borrower that applied for a PPP loan prior to the issuance of this guidance and repays the loan in full by May 7, 2020 will be deemed by SBA to have made the required certification in good faith."

NAGGL REMINDS LENDERS that when a loan is canceled prior to disbursement, the funds allocated for that loan go back into the program and become available to fund loans for other eligible applicants. So if you have any loans that should not be disbursed based on new FAQ #31, NAGGL urges you to cancel them through E-Tran immediately. If a loan has been disbursed and must be repaid based on this FAQ, those funds will be lost to the program and will not benefit other borrowers. Stay tuned for more guidance from SBA on canceling loans in E-Tran!


(April 22 @ 9:37 am EDT) Update from NAGGL CEO: Senate Passes Additional PPP Funding; Creates Crisis for 7(a) Program >

(April 21) Another key SBA lending program jeopardized by bailout chaos (Politico) >

***UPDATED April 17, 6:15 pm EDT   Procedural Notice released:  5000-20020 ***-- updated to add a paragraph for revolving lines of credit and clarify the 504 borrower fees paid.  

Section 1112 Gross Loan Payment Amounts - Blank Template - MANDATORY Format >

(April 17 @ 2:09 pm EDT) SBA PPP statistics >

(April 16, 6:15 pm EDT) Implementation of Section 1112 of the CARES Act, Subsidy for Certain Loan Payments for the 7(a) and 504 Loan Program

The notice contains guidance regarding SBA’s payment to lenders and CDCs of 6 months of principal, interest and “associated fees” for borrower with “covered loans” in “regular servicing status” (including loans currently on deferment), as defined in the notice.  

(April 16) Federal Reserve announces its Paycheck Protection Program Liquidity Facility is fully operational and available to provide liquidity to eligible financial institution


(UPDATE April 16 @ 10:18 am EDT)  NAGGL WAS JUST INFORMED THAT PPP FUNDING HAS BEEN EXPENDED
(April 15 @ 9:00 PM EDT) IMPORTANT: Update on from SBA on Paycheck Protection Program (PPP) Funding

(April 15 9:37 PM EDT) SBA/Treasury Press Release >

(April 15 @ 6:30 PM EDT) NAGGL sends letter to House and Senate leadership requesting to separate 7(a) commitments from PPP commitments. Read the Letter >


(April 15)
NAGGL received the following message from SBA to share with our members:
In the near future, SBA expects the amount of processed PPP loan volume to reach the maximum amount authorized and appropriated by Congress. Once the authorization limit is reached, SBA will not be able to accept any new loan applications for the Paycheck Protection Program.
This will mean that lenders will no longer be able to load PPP applications into the Capital Access Financial System (CAFS or E-Tran) [the Lender Gateway]. SBA is unable to maintain a queue for PPP applications. Further, PPP loan amounts may not be adjusted by lenders within the CAFS system.
Additionally, once the authorization limit is reached, SBA will no longer be able to accept new lender applications to become PPP lenders. 
SBA is reaching out to the lending community to make them aware of this eventuality so that they may prepare and inform their small business customers of the situation.
SBA will continue to inform its lending partners of new updates should Congress authorize additional funds. 


(April 14 @ 5:55 PM EDT) Through April 13, SBA has guaranteed 1,035,086 loans under the PPP for $247,543,393,521

Handling Payments Due Now on Existing 7(a) Loans
Many NAGGL members have requested guidance regarding how they should handle payments on existing 7(a) loan that would be due now or will come due in the very near future.  As lenders are well aware, we are waiting for guidance regarding the implementation of Section 1112 of the CARES Act.  That section authorizes the government to make six months of complete loan payments on SBA-backed loans.  Although we have NOT received any guidance on this point, because of the uncertainty regarding how this program will be implemented on a practical basis, NAGGL suggests that lenders may want to consider postponing collecting payments that would otherwise be due beginning April 1 up to the date that SBA issues guidance regarding the implementation of this initiative.  Once the SBA guidance is received, lenders will be in a better position to determine how to proceed in a way that will be most beneficial to borrower, and less burdensome on lenders.


CAFS:

 NEW USERS must go through the security protocol to receive a user ID and password. That  protocol can be found in these links:                                               
  CAFS >                                         Create a new account >                
  Some instructions >

 

E-Tran Pro Tip: Be careful when entering passwords to E-Tran. Encourage your team members to enter passwords carefully.

Repeated attempts to enter a password into the system can result in temporary account suspension(due to security protocols) requiring password reset.

(April 13 @ 4:30 PM EDT) SBA + Treasury publish updated FAQ 
Questions 22-25 added: info on $10 million cap for  franchises; for hotels, restaurants (NAICS 72xxx); beneficial ownership under BSA

(April 11)

CAFS SCHEDULED MAINTENANCE NOTICE:

The system will undergo scheduled maintenance on Saturday, April 11, 2020, from 12:01 a.m. EDT until 6:00 a.m. EDT (Friday night)
The Capital Access Financial System (CAFS) and the Lender Gateway located at connect.sba.gov will not be accepting loans during this time. 
During this timeframe, new lenders seeking approval to participate in the program may continue to submit their applications to the appropriate email account. 
•             Non-Bank Lender (fin tech) applications to NFRLapplicationforPPP@sba.gov
•             Federally insured banks, credit unions and farm credits applications to delegatedauthority@sba.gov 

 


(April 10 @ 8:00 PM EDT) Update on PPP Funding from NAGGL CEO - Read the Article >

(April 9 @ 1:50 PM EDT) Paycheck Protection Program: Should Lenders Proceed to Close PPP Loans? Read the Article >

(April 9 10:42 AM EDT) Federal Bank Regulators Issue Interim Final Rule for Paycheck Protection Program Facility 

(April 9 @ 2:30 PM EDT) More than 480,000 loans valued at more than $124 billion were approved 

(April 9 9 9:25 AM EDT - PLEASE NOTE - SBA approving additional franchise brands (e.g., 7-11, Chick-fil-a, Aaron's with more to come) for PPP purposes only

Increased franchise eligibility for PPP:  Franchises that have not previously been eligible for SBA loans may be eligible for PPP loans, so you cannot rely on previous listings, but will need to check the SBA Franchise Directory for each franchise applicant.  The brands being added to the Directory specifically for the purpose of making them eligible for PPP loans will show the following message in the “notes” column:  “THIS BRAND IS ONLY ELIGIBLE FOR THE PAYROLL PROTECTION PROGRAM (PPP) LOAN PROGRAM, AND WILL ONLY BE LISTED FOR THE DURATION OF THAT PROGRAM.”

 

(April 8 @ 12:00 PM EDT) SBA reports 362,000 approved PPP loans totaling $95 billion

(April 7 @ 9:00 PM EDT)SBA + Treasury publish updated FAQ >

NOTE:  The FAQ on PPP now carries a date of April 7 and a quick analysis shows that there were changes to language in Question #1

(April 6 @ 7 PM EDT) SBA reports 178,000 PPP loans approved totaling $50 Billion

(April 3 @ 8:00 pm EDT) According to SBA, 1101 participating 7(a) lenders processed 17,503 PPP loans totaling $5,457,256,936 today

(April 3 @ 8:00 pm EDT) E-Tran Access and Security Protocols

SBA advised NAGGL that it is aware of the issues that some lenders are having accessing E-Tran because of security issues. SBA noted that each institution must have an authorizing individual and meet required security protocols, and asked NAGGL to share the following information:  

Here is what SBA is doing NOW to improve this situation while preserving IT infrastructure security.   
 
1.  SBA is running a software script to enable all lenders that previously had an account with CAFS (Capital Access Financial Systems, which is the portal to E-Tran) to be automatically reactivated.  

 

(April 2 @ 11:30 AM EDT) UPDATE FROM NAGGL CEO: Additional Guidance Expected Today

(March 29 @ 9:00 PM EDT) UPDATE FROM NAGGL CEO: Comprehensive Summary of CARES Act

Passage of the CARES Act repeals the Interim Final Rule, effective March 27. Affiliation standards revert back to prior standards outlined in the Federal Register Notice on June 27, 2016

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