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SBA Publishes Loan Forgiveness Application for Paycheck Protection Program

On May 15, 2020, the Small Business Administration (SBA) published a form of the loan forgiveness application for borrowers of Paycheck Protection Program (PPP) loans under the CARES Act. The application provides instructions...more

Federal Court: SBA’s PPP Ineligibility Rule Is Invalid

In a significant rebuke of the Small Business Administration (SBA), a Michigan federal district court has rejected the SBA’s attempt to deem a number of applicants, including sexually oriented dance clubs, ineligible for...more

California Bill Would Require Mortgage, Auto and PACE Forbearances and Restrict Payday Lending

Through an amendment to Assembly Bill 2501, California Assembly Banking and Finance Chair Monique Limon has introduced sweeping forbearance legislation that would impact single-family and multifamily mortgages, auto-secured...more

Federal Lawsuit Attacks SBA Paycheck Protection Program Guidance as Contrary to the CARES Act

On May 4, 2020, three Paycheck Protection Program (PPP) borrowers that received $750,000 in first-round funding sued the Small Business Administration (SBA) and the Treasury Department in the U.S. District Court, Central...more

Main Street Lending Program Expansion Announced

On April 30, the Federal Reserve Board, after receiving more than 2,200 letters in response to a request for feedback on its Main Street Lending Program, announced an expansion of the scope of and eligibility for the program....more

The Potential for Ultra Vires Regulatory Guidance During COVID-19

In response to the COVID-19 pandemic, federal and state governments and regulators have taken hasty actions that are arguably beyond the scope of their authority in order to provide assistance to businesses and consumers...more

Fair Lending and the Paycheck Protection Program

While predicting the enforcement priorities of the financial regulators has always been more of an art than a science, the current circumstances—including a pandemic, a presidential election and a Supreme Court case hanging...more

$310B Added to Paycheck Protection Program as SBA Weighs In on Eligibility

Highlights: - Program reauthorized for $310 billion and intended to be more widely distributed - Bad news for venture capital and private equity - Good news for hospitals and gaming - Renewed focus on the...more

New Federal Reserve Credit Facilities Providing up to $2.3 Trillion in Additional COVID-19 Funding

On April 9, the Federal Reserve took the following actions to provide up to an additional $2.3 trillion in economic aid to support the economy during the coronavirus pandemic...more

Interagency Statements on Residential Mortgage Servicing and Loan Modification and Reporting

Residential mortgage servicers have now received critical new guidance regarding borrowers adversely impacted by COVID-19. In the first guidance, on April 3, the CFPB, the Federal Reserve, the FDIC, the NCUA, the OCC and...more

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