Fri ~11pm: Treasury/SBA release first guidance on #PPPloans, helping large religious orgs & not small businesses.
Mon ~11pm: Second guidance just dropped. There's a typo in the URL ("Frequenty Asked Questions"). Not a good sign?
Let's dive in...
1/
home.treasury.gov/system/files/1…
Mon ~11pm: Second guidance just dropped. There's a typo in the URL ("Frequenty Asked Questions"). Not a good sign?
Let's dive in...
1/
home.treasury.gov/system/files/1…
Startups, small businesses, & investors were pleading for a bright-line rule for "affiliation," since eligibility for a #PPPloan may hinge on it.
Bright side: Banks can rely on the loan applicant's certifications, which should speed things up & keep SBA getting bogged down…
2/
Bright side: Banks can rely on the loan applicant's certifications, which should speed things up & keep SBA getting bogged down…
2/
Less helpful: Implied requirement that any minority shareholder with certain rights must "irrevocably waive or relinquish" these rights.
Will this FAQ help anyone, or just perpetuate the current scramble to amend investment docs (& only for those with sophisticated lawyers)?
3/
Will this FAQ help anyone, or just perpetuate the current scramble to amend investment docs (& only for those with sophisticated lawyers)?
3/
Also, will banks be calmed by the FAQ's claim that "the US government will not challenge lender #PPP actions
that conform to this guidance," or will they be weirded out by this footnote & still deny applications that aren't frictionlessly easy?
cc @EdGrapeNutZimm @nvca
4/4
that conform to this guidance," or will they be weirded out by this footnote & still deny applications that aren't frictionlessly easy?
cc @EdGrapeNutZimm @nvca
4/4
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