June 8, 2023 By: Stephanie Shea and Michael Flynn On June 6, 2023, the FDIC, FRB and OCC collectively issued a document entitled, “Interagency Guidance on Third-Party Relationships: Risk Management” (“2023 Guidance”). Prior...more
On October 8, Treasury issued a new Interim Final Rule Re Additional Revisions to Loan Forgiveness and Loan Review Procedures Interim Final Rules (new IFR), along with a new Loan Forgiveness Application Form 3508S and...more
On October 2, the SBA issued SBA Procedural Notice 5000-20057, Paycheck Protection Program Loans and Changes of Ownership (“Notice”). A link to the Notice is set out below. The Notice sets forth SBA procedural...more
10/6/2020
/ Borrowers ,
Change of Ownership ,
Coronavirus/COVID-19 ,
Covered Transactions ,
Escrow Accounts ,
Lenders ,
Loan Forgiveness ,
New Guidance ,
Paycheck Protection Program (PPP) ,
Publicly-Traded Companies ,
SBA
On September 18, 2020, the Federal Reserve issued new Frequently Asked Questions (FAQs) for its Main Street Lending Program (MSLP). Separate FAQs for the MSLP’s three for-profit programs (the Main Street New Loan Facility...more
The Centers for Disease Control and Prevention has issued an order titled “Temporary Halt in Residential Evictions To Prevent the Further Spread of COVID-19” (“Order”) forbidding evictions of residential tenants who do not...more
9/8/2020
/ CARES Act ,
Centers for Disease Control and Prevention (CDC) ,
Coronavirus/COVID-19 ,
Economic Impact Payments ,
Eviction ,
IRS ,
Landlords ,
Loss of Income ,
Moratorium ,
New Guidance ,
Property Owners ,
Public Health Service (PHS) ,
Relief Measures
On July 31st the Federal Reserve posted amended versions of a number of Main Street Lending Program (MSLP) transaction documents, including the Frequently Asked Questions (FAQs) and Term Sheets for MSLP. Many of the changes...more
On July 23, SBA announced that lenders may begin submitting PPP loan forgiveness requests to SBA on August 10. To assist lenders, SBA issued a Procedural Notice with new guidance regarding lenders’ reviews of forgiveness...more
On July 15, 2020, the Federal Reserve published a number of changes to the Main Street Lending Program’s frequently asked questions, which FAQs were amended to provide further guidance on a number of issues. The Federal...more
By a near-unanimous 417-1 vote, the House has passed the PPP Flexibility Act, which if enacted would, among other things, extend the time to utilize Payroll Protection Program (PPP) loan proceeds and obtain forgiveness,...more