The Federal government’s COVID emergency loan programs and credit facilities have moved into critical new phases. As highlighted by the recent media focus on the new SBA PPP Forgiveness Questionnaire for borrowers, both...more
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 past decade has taught lenders much about regulatory enforcement risk. In the fallout of the 2008 financial crisis and collapse of the housing and related markets, the Department of Justice and other agencies...more
9/16/2020
/ Bank Fraud ,
Bank Secrecy Act ,
CARES Act ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Due Diligence ,
Due Process ,
Entrapment ,
Estoppel ,
False Claims Act (FCA) ,
Fraud ,
Indictments ,
Interim Final Rules (IFR) ,
Lenders ,
Loan Forgiveness ,
Mail Fraud ,
Paycheck Protection Program (PPP) ,
SBA ,
TARP ,
Underwriting ,
Whistleblowers ,
Wire Fraud
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 28, the Federal Reserve announced that many of its emergency lending facilities, including the Main Street Lending Program’s New Loan Facility, Priority Loan Facility, Expanded Loan Facility, Nonprofit Organization...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
The Federal Reserve has announced that the Main Street Lending Program will now be available to non-profits such as educational institutions, hospitals, and social service organizations, and has issued a set of Frequently...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
Wednesday evening, July 1, the House by unanimous voice vote passed a bill already approved unanimously by the Senate that will extend the period to obtain PPP loans until August 8, 2020. President Trump is expected to sign...more
To implement the changes to the PPP program contained in the recently enacted PPP Flexibility Act, Treasury has issued a new Interim Final Rule (IFR). It has also issued a revised forgiveness application form, worksheet and...more
On June 8, the Federal Reserve announced a number of changes to the Main Street Lending Program (“MSLP”), involving all three facilities, the Main Street New Loan Facility (“MSNLF”), the Main Street Priority Loan Facility...more
On June 5, the President signed the PPP Flexibility Act. As first described in Buchalter’s previous ALERT, this new law creates the following adjustments to PPP requirements:
For loans entered into on or after the date the...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
On May 22, Treasury issued a new Interim Final Rule (“IFR”) regarding Small Business Administration (“SBA”) Payroll Protection Program (”PPP”) loan forgiveness. Much of the IFR repeats information previously published by...more
The Treasury Department has issued a form application to be used for SBA Payroll Protection Program (PPP) borrowers to seek loan forgiveness, along with instructions for completing the form and an accompanying worksheet... ...more
The pandemic crisis unfolding in the United States and around the world has placed a significant strain on commercial lending relationships, and the pressure will only mount as the medical and financial ramifications unfold....more