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Dear Community Banker:
The Treasury Department and Small Business Administration just answered key questions ICBA has been asking about the Paycheck Protection Program. In today's updates to the agencies' PPP FAQs, they confirmed the following:
Lenders may use their own promissory note or an SBA form of promissory note for PPP loans.
The lender must make the first disbursement of the loan no later than 10 calendar days from the date of loan approval.
The eight-week period of borrower payroll costs that determines the amount of forgiveness for PPP loans begins on the date the lender makes the first disbursement of the PPP loan to the borrower.
ICBA has added information from the Treasury/SBA FAQs to our own FAQs on the PPP, which we continue to update with new information as we receive it. The updates follow yesterday's SBA launch of its portal to facilitate PPP access. The new portal allows non-SBA-certified lenders to:
Create an account on SBA Connect.
Request authorization to the Paycheck Protection Lender Gateway by providing their FDIC or Federal Reserve number and authorization number.
Proceed to the Lender Gateway to begin submitting loan authorization requests.
The SBA launched the portal while ICBA Chairman Noah Wilcox and ICBA Vice Chairman Brad Bolton participated in a virtual White House meeting with President Donald Trump, Treasury Secretary Steven Mnuchin, and SBA Administrator Jovita Carranza to discuss the status of the PPP. At the meeting, Secretary Mnuchin said he is working with congressional leaders to procure an additional $250 billion for the PPP as soon as this week.
Nevertheless, key questions remain unanswered. ICBA still continues to ask Treasury and the SBA to provide definitive guidance on:
Whether banks can lend to their directors with eligible small businesses, and
Whether owner draws or distributions count as payroll costs.
As soon as we have answers to those questions, we will let you know.
The SBA continues encouraging lenders who need assistance to call its Lender Customer Service Line at 833-572-0502. And we encourage community bankers who are having problems accessing the program to check spam filters for password-reset emails and other auto-generated messages from the SBA E-Tran at [email protected].
Meanwhile, ICBA is hosting a complimentary briefing on the COVID-19 response at noon (Eastern time) tomorrow, and we continue encouraging community bankers to weigh in by completing our new survey on PPP access and processing.
And we thank you for all of your efforts to support local communities throughout the United States at this challenging time.
Sincerely,
Rebeca Romero Rainey
President and CEO
Independent Community Bankers of America