New Main Street Lending Program FAQ Update for November 19, 2020
he Federal Reserve announced changes to the FAQs for the Main Street Lending Program: Click here to read the FAQs related to Non-Profit Organizations Click here to read the FAQs related to For-Profit Organizations We expect the Federal Reserve to continue issuing new guidance with respect to the Main Street Lending Program, which we will provide as it becomes available.
Continue ReadingNew Main Street Lending Program FAQ
As part of our practice, we assist lenders with Federal Main Street Lending Program transactions. Recently, the Federal Reserve issued the following: Updated FAQ, click here to read; Lowered the minimum loan size from $250,000 to $100,000 and changed the fee structure for loans with a principal amount of less than $250,000; Overview explaining the core terms of the program and eligibility criteria for non-profit borrowers, click here for more; and, Monthly report dashboard based on usage and geographic distribution, click here to view. We expect the Federal Reserve to continue issuing new guidance with respect to the Main Street Lending Program, which we will provide as it becomes available.
Continue ReadingSBA Procedural Notice 5000-20058 – Update for October 22, 2022
The SBA issued Procedural Notice 5000-20058 on Additional Guidance on the Implementation of Section 1112 of the CARES Act, Subsidy for Certain Loan Payments, for the 7(a) and 504 Loan Programs, click here to read the notice. We expect that there will continue to be further guidance and clarification which we will continue to provide as they become available.
Continue ReadingSBA IFR on Loan Forgiveness and SBA Form 3508S
The SBA and Treasury released a simplified loan forgiveness application for PPP loans of $50,000 or less To view the IFR on Additional Revisions to Loan Forgiveness and Loan Review Procedures, click here to read. To view SBA Form 3508S for simplified PPP loan forgiveness application, click here To view instructions for completing SBA Form 3508S, click here To view the SBA Press Release on the simplified forgiveness application, click here. Important considerations for this announcement: SBA Form 3508S is a “streamlined” forgiveness application, and should NOT be interpreted as “automatic” forgiveness; SBA Form 3508S may not be used if total PPP loans for the Borrower and its Affiliates is equal to or greater than $2 million; Loans eligible for SBA Form 3508S are not subject to reduction of forgiveness based on reduction of FTE or salaries/wages; and Borrowers and Lenders must still follow all other PPP loan forgiveness guidelines. We expect that there will continue to be further guidance and clarification which we will continue to provide as they become available.
Continue ReadingSBA Procedural Notice 5000-20057
SBA Procedural Notice 5000-20057 on Paycheck Protection Program Loans and Changes of Ownership was recently released by SBA, click here to read. The following are important issues to consider with proposed changes of ownership: Stock Transfer vs. Asset Sale Partial Change of Ownership vs. Full Change of Ownership Review of Purchase Agreement SBA Approval vs. Escrow Accounts Status of PPP Loan Forgiveness Application Use of SBA Loans to Fund Change of Ownership We expect that there will continue to be further guidance and clarification which we will continue to provide as they become available.
Continue ReadingNew PPP FAQ Update for October 8, 2020
New Paycheck Protection Program FAQ released, click here to read. Important Considerations: Notify borrowers of the change to the deferment period; Avoid specific repayment dates in the notice; Adjust internal systems to avoid sending out inaccurate monthly installment invoices; and Once the loan forgiveness process is complete, lenders may then choose to have borrowers complete a formal note modification agreement for any unforgiven PPP loan balance. We expect that there will continue to be further guidance and clarification which we will continue to provide as they become available.
Continue ReadingReminder New SOP 50 10 6 and SBA Procedural Notice 5000-20050 Update for September 29, 2020
As a reminder, SBA released the much anticipated SOP 50 10 6 which will go into effect on October 1, 2020. Click here to access the full SOP on the SBA’s website. Over the next several weeks, we will highlight the various changes within the SOP. Watch your inbox for more of these newsletters to catch the details. SBA Procedural Notice Update available from the SBA for: SBA Procedural Notice 5000-20050 on the Extension of Previous Guidance on Acceptable Signatures for Applications and Loan Documents in the 7(a) and 504 Business Loan Programs Through November 30, 2020, click here to read.
Continue ReadingNew SBA Procedural Notice 5000-20049 Update for September 25, 2020
SBA Procedural Notice 5000-20049: Further Guidance on the Implementation of Section 1112 of the CARES Act, Subsidy for Certain Loan Payments, for the 7(a) and 504 Loan Programs, click here to read. We expect that there will continue to be further guidance, processes, and procedures issued which we will continue to provide updates once available.
Continue ReadingNew SBA SOP 50 10 6 Released: Effective October 1, 2020
The U.S. Small Business Administration (SBA) has released the much anticipated update to the Lender and Development Company Loan Programs. The SOP 50 10 6 will become effective October 1, 2020, and will apply to all applications received by SBA on or after that date. Click here to access the new SOP on the SBA website. Participants must continue to use SOP 50 10 5(K) for SBA 7(a) and 504 applications submitted through September 30, 2020. If you have questions about the SOP 50 10 6 notice, please do not hesitate to contact Your SBA Legal Department at Jellum Law
Continue ReadingNew PPP Interim Final Rule Update for August 25, 2020
Update available on the Treasury website: Interim Final Rule on Treatment of Owners and Forgiveness of Certain Nonpayroll Costs, click here to read. We expect that there will continue to be further guidance, processes, and procedures issued which we will continue to provide updates once available.
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