For example, the sale of assets or assets: the PPP borrower files his application for forgiveness with the PPP lender and creates an interest-bearing receiver account controlled by the PPP lender for the outstanding credit balance. The communication confirms that there are no restrictions on the change of ownership if the P3 loan has already been paid. But that will rarely be the case. PPP borrowers want a full loan and do not want to have to repay the loan. No no. No no. A bank does not need a separate SBA authorization for the SBA to guarantee a PPP loan. The amount of the FDI loan to be refinanced does not include the amount of an „advance“ of the FDI (also known as the „subsidy“ of the FDI) received by the borrower, because the advance of the FDI does not have to be repaid. With regard to PPP loans, for which Form SBA 2484, „Lender Application Form – Paycheck Protection Program Loan Guaranty,“ Section D, Credit Amount Information, included an amount for the „refinancing of the loan in the event of an eligible economic disaster, net of advance,“ banks are required to pay and transfer the proceeds of the loan directly to the SBA (not the borrower) for the refinancing of an EIDL loan. If the bank has already paid the proceeds of the loan directly to the borrower for the refinancing of an FEDL loan, the bank is responsible for the borrower`s information on the amount of the proceeds of the PPP loan that must be returned by the borrower to SB. d. The loan process is complete and (i) the SBA has transferred funds to the PPP lender or (ii) the borrower has repaid the balance. When a bank makes its decision to the SBA, which finds that the borrower is not entitled to any amount of forgiveness, the bank must provide the SBA with the reason for its refusal as well as: (i) the calculation form for calculating the credit provision; (ii) the PPP A calendar; and (iii) the demographic information form for PPP borrowers (if submitted to the bank).
The bank must confirm that the information it provides to SB accurately reflects its P3 credit records and that the bank made its decision in accordance with the bank`s pfPP loan verification requirements. The bank must also inform the borrower in writing that the bank has refused SB to rule on the rejection of the PfPP loan application. The SBA reserves the right to verify at its sole discretion the Bank`s decision on pardon. Yes, if a bank is not able to change its application in time. Banks handle extremely high amounts of PPP loan applications. Because banks can rely on customer diligence (CDD) from existing bank customers, they can process existing client applications more quickly. As a result, non-bank customers can obtain a PPP loan from their existing bank more quickly. Therefore, if a bank is unable to process loan applications from a non-client in a timely manner, it should recommend that these applicants apply to their existing banks.
In addition, the fair lending requirements in a bank`s Regulation B do not explicitly prohibit limiting PPP lending or prioritizing the demands of existing bank customers. However, when a bank decides to limit or prioritize PPP lending in this way, it should establish appropriate guidelines, which will be reviewed by its compliance and legal teams. Banks should be aware of these and other issues that are presented in our customer alert on this topic: risk reduction through PPP loans. There is no need for a review for existing bank customers. If your bank has not yet collected information on actual beneficiaries regarding existing customers, you do not need to collect and verify actual beneficiary information for customers applying for new PPP loans, unless your BSA policies and procedures are prescribed by other provisions. Yes, a lender may require the SBA to purchase the expected amount of the pardon at the end of the seventh week of the covered period. The expected amount of the pardon is the amount of the P3 loan capital, which the lender reasonably expects the borrower to co-ord its