2023 Employment Law Changes — And Steps To Take Before 2024

Paycheck Protection Program: Treasury Guidance on Processing Fees

By: Anton J. Moch

Yesterday, Treasury released an updated set of rules that finally provide guidance on how banks and other lenders participating in the SBA’s Paycheck Protection Program (“PPP”) can report disbursements of funds and collect on PPP processing fees.  The newly updated rules make it clear that any PPP lender must make a one-time disbursement of funds ...

Main Street Lending Program

By: Jonathan W.J. Armour and Chelsea M. Mularoni

The Federal Reserve (the “Fed”) announced the establishment of a $600 billion Main Street Lending Program (the “Program”) to support lending to small and medium-sized businesses impacted by the COVID-19 pandemic. The funds were appropriated under the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”). The Program will be comprised of two lending ...

CARES Act Summary: Changes for Banks and Other Financial Service Providers

By: Amber L. Kraemer

Expanded Authority of Lenders to Enter The CARES Act established the authority of the U.S. Department of Treasury, the Farm Credit Administration, and other federal financial regulatory agencies to authorize bank and non-bank lenders to participate, including insured credit unions in loans made under the Paycheck Protection Program. For financial institutions under this section, Treasury ...

CARES Act Summary: Expanded Access to Capital for Businesses

Paycheck Protection Program The CARES Act increases the federal guarantee of loans made for the Payment Protection Program under section 7(a) of the Small Business Act to 100 percent through December 31, 2020. Eligibility for loans is defined as a small business, 501(c)(3) nonprofit, a 501(c)(19) veteran’s organization, or Tribal business concern described in section ...

SBA Interim Final Rule: What Lenders Need to Know

By: Jonathan W.J. Armour

Yesterday, April 2, the Small Business Administration issued an interim final rule providing additional guidance on implementing its Paycheck Protection Program. While questions still remain, here is the new information that lenders need to know: Lenders who are already SBA 7(a) lenders may begin accepting and processing applications today.  Other lenders can become eligible upon ...

Paycheck Protection Program: Q&A For Lenders

By: Anton J. Moch

By now most banks have been alerted to the fact that a significant part of the Coronavirus Aid, Relief and Economic Security Act (“CARES ACT”), is comprised of the Paycheck Protection Program (PPP), which was signed in to law on March 27, 2020. The CARES Act authorizes $349 billion in forgivable Section 7(a) SBA loans to small and mid-size businesses (“PPP Loans”). What Banks may not have seen is how it may impact their organization directly. Below are some of the relevant questions we have received and what we know today as a result of the CARES ACT.