News & Analysis as of

Interim Rule CARES Act

Sheppard Mullin Richter & Hampton LLP

Federal Reserve Clarifies that Distributions to Tribal Governments are Permitted Under the Main Street Lending Program

On July 15, 2020, the Federal Reserve Bank of Boston issued new guidance expressly permitting tribal businesses that are borrowers under the Main Street Lending Program (“MSLP”) to pay dividends to their tribal government...more

McCarter & English, LLP

SBA Revisions Expand Paycheck Protection Program Eligibility And Loan Forgiveness

On June 19 and June 22, 2020, the Small Business Administration (“SBA”) issued new revisions to their First Interim Final Rule concerning the Paycheck Protection Program (“PPP”). The Revised Interim Final Rule and the...more

Bradley Arant Boult Cummings LLP

Lender Liability and False Claims Act Issues Under the Paycheck Protection Program

Among the most significant aspects of the CARES Act is the $660 billion small business forgivable loan program known as the Paycheck Protection Program (PPP), and it was perhaps inevitable that the administration of the...more

Foley & Lardner LLP

SBA Loans Under the CARES Act - Updated as of May 20, 2020

Foley & Lardner LLP on

The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”), signed into law on Friday March 27, 2020, introduced the Paycheck Protection Program (the “PPP”) with an initial $349 billion in funding and the goal of...more

Downs Rachlin Martin PLLC

New Interim Final Rule on PPP Borrower and Lender Disbursements

Disbursement of PPP Loan Proceeds - Questions persist regarding how loans under the Paycheck Protection Program (“PPP”) are to be funded by lenders. Specifically, some Borrowers have sought multiple draws hoping to achieve...more

Holland & Knight LLP

SBA Issues Third Interim Rule Implementing the Paycheck Protection Program

Holland & Knight LLP on

On April 24, the Small Business Administration (SBA) issued its Third Interim Rule containing guidance for execution of the Coronavirus Aid, Relief, and Economic Security (CARES) Act's Paycheck Protection Program (PPP)....more

Foley & Lardner LLP

SBA Loans Under the CARES Act - Updated as of April 25, 2020

Foley & Lardner LLP on

The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”), signed into law on Friday March 27, 2020, introduced the Paycheck Protection Program (the “PPP”) with an initial $349 billion in funding and the goal of...more

Vedder Price

The Federal Reserve Provides Liquidity to Banks Participating in the Paycheck Protection Program

Vedder Price on

On April 9, 2020, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued guidance for banks that wish to participate in the Federal Reserve’s Paycheck Protection Program Lending Facility (the...more

Foley & Lardner LLP

SBA Loans Under the CARES Act - Updated as of April 10, 2020

Foley & Lardner LLP on

The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”), signed into law on Friday March 27, 2020, introduces the Paycheck Protection Program (the “PPP”) with $349 billion in funding and the goal of preventing...more

Vedder Price

Interim Rule Issued – Paycheck Protection Program

Vedder Price on

On April 3, 2020, the Small Business Administration (the “SBA”) published its Interim Final Rule (the “Interim Rule”) governing the origination of “paycheck protection loans” under the newly created small business lending...more

Vedder Price

Paycheck Protection Program Loans May Be Excluded from a Bank’s Regulatory Capital Ratios

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On April 9, 2020, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), and the Office of the Comptroller of the Currency (collectively, the “federal banking...more

Bass, Berry & Sims PLC

Are You an Affiliate? Guidance for Physician Practice Management Companies under the Paycheck Protection Program

With the much-anticipated release of the Small Business Administration (SBA) Interim Final Rule on affiliation under the Paycheck Protection Program (PPP) late on April 3, those waiting with bated breath for any clarification...more

Vedder Price

Temporary Regulatory Relief: Community Bank Leverage Ratio Set At 8%

Vedder Price on

On April 6, 2020, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation and the Board of Governors of the Federal Reserve System (collectively, the “federal banking agencies”) announced the...more

Greenbaum, Rowe, Smith & Davis LLP

SBA Announces Rule Governing Paycheck Protection Program

On April 2, 2020, the Small Business Administration (SBA) issued its Paycheck Protection Program (PPP) Interim Final Rule, which makes some key changes to the implementation of the PPP program announced in Sections 1102 and...more

Hinshaw & Culbertson LLP

$2.2 Trillion CARES Act Provides Opportunity for Community Banks

The $2.2 trillion Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was enacted late last week. Designed to provide emergency economic assistance to businesses, families, and individuals, the CARES Act also...more

Stinson LLP

Modified Community Bank Leverage Ratio

Stinson LLP on

On April 6, 2020, the Federal Deposit Insurance Corporation (FDIC), Board of Governors of the Federal Reserve System, and Office of the Comptroller of the Currency issued two interim final rules that make changes to the...more

Genova Burns LLC

COVID-19: SBA Paycheck Protection Program

Genova Burns LLC on

The Interim Final Rule (the “Rule”) pertaining to applications for the Paycheck Protection Program was released this evening. A few unexpected positions have been taken (and some ambiguity/uncertainty still remains) – ...more

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