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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. 

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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    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
    • Bankers Helping Bankers
    • Associate Membership
    • CCBN Associate Member Directory
  • Education and Events
    • Seminars and Events
    • Webinars >
      • Categories >
        • AUDIT & ACCOUNTING
        • Collections
        • Compliance
        • Directors
        • Frontline New Accounts
        • Human Resources
        • IT
        • IRA
        • Lending
        • Marketing
        • Operations
        • Security & Fraud
        • Senior Management
    • Recorded Webinars
    • Community Banker University >
      • CBU Certification Programs
      • CBU Bank Director Program
      • CBU Leadership Academy
      • CBU Online Training
      • ICBA LIVE 2023
      • ICBA Lead FWD Summit
  • Advocacy
    • Legislative Successes
    • From ICBA >
      • From Washington DC
      • From the Top
      • Portfolio Management
  • About Us
    • Our Team
    • Board of Directors
    • Contact
  • Preferred Service Providers (PSP)
    • PSP Announcements