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This page is for community bankers to ask questions, share experiences and learn more about the PPP process.
​This is a peer exchange and not official interpretation or legal consultation.
Please refer to SBA and Treasury for 
official guidance. 

PPP Lending Operations Update – Tuesday, April 28, 2020

4/28/2020

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From SBA: 
​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. (Sheri.Mcconville@sba.gov)
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PPP Lending Operations Update – Monday, April 27, 2020

4/27/2020

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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_4-27-20_-_sba_xml_submission_guidance_memo_.pdf
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What steps  do borrowers need to follow to receive PPP loan forgiveness?

4/21/2020

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From a CCBN bank: 

Forgiveness is discussed in the following sections on the PPP – IFRN FINAL:
                a.) Section O starting Page 13
Forgiveness is discussed in the following sections on the PPP – IFRN FINAL (Addtl) –  for self-employed and independent contractors:
                a.) Section F starting Page 11
 
The clause that has merited attention on our side is the following from the PPP –IFRN FINAL on Page 13-14:
 
That is, the borrower will not be responsible for any loan payment if the borrower uses all of the loan proceeds for forgivable purposes described below and employee and compensation levels are maintained.
 
Our interpretation is that the number of employees can’t be reduced and no reduction in their compensation at the time of funding thru the 8 week period.  They could hire more or give raises if they chose.  Hence the borrower need for a current employee list/with salaries to track against.

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FinTech companies that were used by banks to help get loans into the system but who failed to do so before the system shutdown due to number of loans that overwhelmed their ability to process.

4/21/2020

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  • We know several of the Fintechs who are still sitting on those applications awaiting (and having anticipated) new funding and expect to continuing processing those applications.
  • Several of these bank/Fintech partnerships have actually been expanded during this limbo period and some new ones have been created in this time as well.
  • The Fintechs have used this period to improve their tech stack to speed up and improve the process.
    • This includes some KYC/underwriting elements that were causing eTran to reject some applications.
    • This includes improving the throughput integration into eTran to allow them to pump more loans into it faster.
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Third party agents?

4/21/2020

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Below is guidance from ICBAs FAQ’s on agents 
The obligation of a lender to pay the appropriate agent fee does not commence unless the bank has agreed that the accounting firm/CPA is acting as an agent for the bank. Please see guidance provided below from the American Institute of Public Accountants (AICPA) to their members in support of best industry practices.
 
“The law is clear that agents cannot collect a fee from an applicant but must instead collect a fee from the lender. If you choose to be an agent, we suggest you (the Accounting Firm) contact the lender before embarking on the engagement and get a written agreement with them so you get paid. You should have a conflict waiver in the agreement with the lender, just like in your loan assistance engagement letter with the client. Disclose this arrangement with your client as well.”
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How does a bank know the loan has been funded?

4/21/2020

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​We are still awaiting SBA guidance
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What is the amount of the PPP that is taxable?

4/21/2020

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The forgiveness of a PPP loan is not taxable to the borrower unlike the usual treatment of debt forgiveness.
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Are you sending a notice to PPP applicants that did not receive a loan authorization from the PPP?

4/20/2020

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How do we transmit lender application 2484?

4/17/2020

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When can we expect the forgiveness protocol to be released?

4/16/2020

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SBA Form 1502 and Instructions

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What is the process for getting the origination fees?

4/16/2020

1 Comment

 
1 Comment

Can you use housing costs for a church pastor as part of the payroll costs?

4/16/2020

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What happens to a borrower if they don’t fund within the 10 day period, can they reapply?

4/16/2020

1 Comment

 
1 Comment

Are you putting a late charge on the note?

4/16/2020

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    Related Resources:
    • ICBA 
      Info and FAQ on SBA PPP
    • ​Treasury FAQ 
    ​OriTrust
    ​

    OriTrust's PPP Fast Application is a powerful bank developed tool that can help its members fast-track PPP lending and is very straightforward and simple to use. It helps with making sure the bank is collecting all the required information and with the ongoing monitoring of information to ensure each borrower obtains loan forgiveness. 
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  • Membership
    • Member Portal Login
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        • Frontline New Accounts
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    • Resources >
      • Covid-19 Impact & Best Practices
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  • Advocacy
    • Legislative Successes
    • CCBN Policy Engagement
    • From ICBA >
      • From Washington DC
      • From the Top
  • About Us
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  • Preferred Service Providers (PSP)
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