The rollout of the Payroll Protection Program (PPP) has been rocky. You who are SBA approved lenders and are participating in the program are more aware of the hiccups in the first week of the PPP lending program than perhaps others.

But “rocky” and “hiccups” are our sanitized version of what we are hearing from some of our clients as they battle through the terrain of a $349 billion federal government agency coordinated loan guarantee program that was signed into law one Friday and open for business five business days later.

We have tried to keep you updated on the most current and, most importantly, the most pertinent information being distributed from so-called experts on a program that did not even exist ten days ago.

Just today there were three key pieces of guidance published that we thought important and pertinent enough to get into your hands.

One is from the SBA today. It is a very solid Q and A piece that is unquestionably based upon the true myriad of questions that they have been getting since the PPP program went live last Friday.

The link to the SBA publication on Frequently Asked Questions is below. We found it more clear than much of their earlier guidance.

https://home.treasury.gov/system/files/136/Paycheck-Protection-Program-Frequenty-Asked-Questions.pdf

The second is a letter to credit unions put out late yesterday by NCUA that covered the PPP program.

In particular, we call your attention to the sections on the PPP program as it relates to the member business lending cap.

https://www.ncua.gov/regulation-supervision/letters-credit-unions-other-guidance/small-business-administration-loan-programs-help-small-businesses-and-members-during

In addition, yesterday the NCUA put out a guidance in conjunction with their fellow FFIEC regulators on how loan modifications during the coronavirus national emergency can be treated without being considered temporary debt restructurings (TDRs).

If the examiners remember this guidance eighteen months from now, this could be quite meaningful relief from the TDR treatment that NCUA has been applying in the years since the Great Recession of 2008-10.

It might be advisable to keep a copy of this guidance in your files as well. The link is below.

https://www.ncua.gov/files/press-releases-news/interagency-statement-tdr-policy-revised.pdf

We will continue to try to help you separate the wheat from the chaff on all of the publications and guidance you are receiving from so many different sources today.

 

Until next time.