Paycheck Protection Program 2.0
On Sunday, December 27, 2020, the Consolidated Appropriations Act, 2021 (the “CAA”) was signed into law, which expands certain provisions of the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”).
Community Banks and the Main Street Lending Program
The Federal Reserve continues to release additional guidance relating to the Main Street Lending Program (the “MSLP”) originally announced in April 2020. Though the program is still largely in the setup phase, many community banks are contemplating whether to participate.
ECOA Implications for COVID Lending Programs
During the past month, banks have scrambled to accommodate customers—working around the clock to process emergency requests for loan modifications and thousands of applications under the Payroll Protection Program (PPP). They have done this with reduced staff, and while simultaneously overhauling delivery and workflow systems in an attempt to keep customers, employees and their families safe.
Opening Up Bank Strategy Again
Banks can adopt their own version of the White House’s plan to reopen the economy by identifying key triggers for acting and preparing to implement those actions in a clear and organized fashion.
SBA Releases Additional Guidance on Paycheck Protection Program; Federal Regulators Publish More Information on PPPLF and Real Estate Appraisals
On the afternoon of April 14, the SBA provided additional guidance regarding the Paycheck Protection Program (“PPP”) in the form of an interim final rule, which supplemented the previously issued interim final rule announcing the implementation of PPP.