Important PPP updates as of this AM:
1/As of late last night, banks have not yet received guidance from SBA. This will include lender application, workflow, and post loan monitoring. Banks could take risks if processes are not followed.
1/As of late last night, banks have not yet received guidance from SBA. This will include lender application, workflow, and post loan monitoring. Banks could take risks if processes are not followed.
2/I've heard some in market say "well my local CU" is open and processing. They are not. They may have created an online portal, but no one is processing. Also first come, first serve is when SBA receives. This cannot happen until 4/3 at EARLIEST.
3/ Banks when they do start will have online forms, document collection, etc. Per our discussions, credit memos and verification of self certification items will be needed prior to submission to LP. Failures to do this correctly *could* impact loan forgiveness
4/ No change on affiliation rules yet. Some companies are being counseled to submit anyway. Civil and criminal penalties could be assessed if submission a loan is funded but later audited and found to conflict with rules. Be sure.
5/ Still have gotten questions from VC firms/PE firms. One of the key certification points is whether not receiving this loan because of current hardships would result in suspension of operations. This generally means steep loss in revenues. This is NOT typical case for PE/VC
6/ Also, SBA PDF application is not an official application. Banks will need to collect things like 1099 and other supporting docs for verification. I realize everyone is nervous, but banks are still in holding pattern. SBA/Treasury tweets/releases have not been 100% transparent
7/ We will all get there, and we (FRB) are working tirelessly to get ready once we have the necessary info. The bank will put a formal comm package together soon.
