New PPP Guidance Amid Relaunch Difficulties

Dear Community Banker:

Following this morning's relaunch of the Paycheck Protection Program, ICBA is hearing the many problems community bankers are having accessing Small Business Administration systems to process their PPP applications.

ICBA is pressing Treasury and the SBA to address these issues. Meanwhile, community bankers can direct E-Tran assistance questions to the SBA at 833-572-0502 or [email protected].

Also today, Treasury and SBA just released additional PPP guidance, including for lenders that have received a significant amount of PPP loan applications. The agencies said the minimum amount of lender-approved and SBA-ready PPP loans that a lender must have ready for the XML file submission process is now 5,000 loans.

Further, these XML files of 5,000 or more approved PPP loans must be submitted to SBA by 9 p.m. (Eastern time) today—Monday, April 27, 2020.

Additionally, Treasury issued an interim final rule authorizing all lenders eligible to originate loans under the PPP to use an alternative criterion for calculating the maximum loan amount for PPP loans issued to seasonal employers.

In a message to lenders yesterday, the agencies announced the following measures:

• Pacing the number of loans processed in the E-Tran system for participating lenders.
• Instituting a maximum dollar amount at 10 percent of PPP funding authority that any lending institution will be able to originate, exclusive of the additional $60 billion preserved for lenders with assets under $50 billion.
• Implementing operational standards to ensure that lenders access PPP funds based on their asset size.
• Ensuring the PPP continues to operate on a first-come, first-serve basis.
• Issuing new guidance allowing lenders that have received a significant amount of loan applications to make a one-time bulk submission of XML files to E-Tran.

All additional prior guidance—including updated frequently asked questions, a document on calculating maximum PPP loan amounts, and an SBA notice with procedural guidance for PPP participation sales—can be found on Treasury’s PPP webpage.

The new law restarting the PPP dedicates at least $30 billion for loans from institutions under $10 billion in assets and another $30 billion for those with between $10 billion and $50 billion in assets. This allocation reflects ICBA, affiliated state association, and community banker advocacy for policymakers to dedicate program funds for loans from community banks under $50 billion in assets.

ICBA will continue pressing Treasury and SBA on the PPP system's problems while we keep you informed of the latest updates on the resumption of the program, including through our COVID-19 resource center. Thank you for all you are doing to meet the needs of your customers and communities at this challenging time.