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
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 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
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 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