Additional COVID-19 Resources

PPP Digest Archive

1/15/2021 - Prepare to Apply for CDFI Fund Rapid Response Program (RRP) Grants
1/14/2021 - SBA Procedural Notice and PPP Timeline
1/13/2021 - Second Draw Available
1/11/2021 - New Technical Info
1/9/2021- PPP Relaunch Advocacy!
1/8/2021 - PPP Draws
1/8/2021 - PPP Relaunch!
1/7/2021 - SBA Issues Interim Rule on PPP
1/5/2021 - New PPP Rules
12/30/2020 - CDBA-NBA Joint Letter
>12/21/2020 - Second Stimulus Bill
12/11/2020 - PPP Loans Outside Target Market
12/9/2020 - More PPP Guidance
12/2/2020 - SBA PPP Field Guide
11/2/2020 - Loan Necessity
10/30/2020 - Fed Lowers Main Street Min Size
10/28/2020 - SBA Guidance for $2m+ loans
10/20/2020 - CDBA Letter to Congressional Small Business Committees
10/16/2020 - Forgiveness Platform Letter
10/14/2020 - Forgiveness FAQ
10/9/2020 - Simplified PPP
10/8/2020 - New SBA FAQ
10/2/2020 - IRS & SBA Guidance
9/29/2020 - Slimmer HEROES Act
9/22/2020 - IRS Offers PPP Guidance
9/18/2020 - Skinny Bill Defeated
9/14/2020 - PPP & Taxes
9/4/2020 - CAFS Down
8/27/2020 - SBA Webinar Registration Now Open
8/26/2020 - SBA Webinar
8/24/2020 - CDBA at CDFI Fund
8/19/2020 - PPP Fees
8/18/2020 - The Skinny Bill
8/17/2020 - Economic Distress Continues
8/14/2020 - SBA Warns of Scams
>8/13/2020 - Grassley-Hassan Extension
8/11/2020 - Additional PPP Guidance
8/10/2020 - PPP Applications Closed
8/7/2020 - The Fed's Few Main Street Loans
8/6/2020 - PPP Vote-a-Rama
8/4/2020 - Updated SBA FAQs
8/3/2020 - Senate Small Business and PPP
7/28/2020 - HEALS Act Negotiations Continue
7/27/2020 - Senate Republicans Introduce Round Four Stimulus Plan
7/23/2020 - SBA Updates on PPP
7/22/2020 - Advocacy Campaign for Jobs and Neighborhood Investment Act and Fed and Treasury Virus Aid
7/21/2020 - Senator Mark Warner Introduces The Jobs and Neighborhood Investment Act
7/20/2020 - Secretary Mnuchin Testimony on PPP Loan Forgiveness and Main Street Lending Program Modifications
7/16/2020 - PPP Fee Reimbursement, Secondary Markets, and NCRC Study on Treatment of Applicants
7/14/2020 - Updated "1502 Lender Processing Fee Payment and Reporting Process" and Economic Recovery Concerns
7/13/2020 - July 15th Deadline for PPP 1502 Monthly Reports, Economic Recovery Legislation, and FHA Home Retention Measures
7/10/2020 - Senate Economic Recovery Legislation and Federal Reserve Report on COVID-19 Economic Crisis
7/9/2020 - Senate Introduces Legislation for to Make PPP Loans Under $150,000 Fully Forgivable
7/8/2020 - CFPB Rescinds Payday Lending Rule on Borrower Ability to Repay
7/7/2020 - Media Analysis of Loan-Level PPP Borrower Data and Impact of Economic Collapse on Black-Owned Businesses
7/6/2020 - President Trump Signs PPP Extension and SBA Releases Loan-Level PPP Borrower Data
7/2/2020Bloomberg Law Recap of CDFI Efforts to Help Small Businesses
7/1/2020 - House Passes "Clean" Version of Bill to Extend PPP Program
6/30/2020 - Senate Passes Bill to Extend PPP Program Through August 8, 2020
6/29/2020 - PPP Lending Report
6/26/2020 - SBA Guidance on Calculating Loan Amounts and Treasury and SBA Write to Congress on Disclosure of PPP Borrower Information
6/25/2020 - U.S. Government Accountability Office Federal Agency COVID-19 Spending Report and Updated SBA FAQs
6/24/2020 - PPP Interim Final Rule on Borrower Eligibility and Potential Federal Digital Currency
6/23/2020 - PPP Forgiveness Interim Final Rule and Regulatory Agencies' Safety and Soundness Examiner Guidance
6/22/2020 - PPP Lending Report and FDIC Final Rule on Deposit Insurance Assessment Effects of Liquidity Facilities
6/19/2020 - SBA Launches Lender Match and Releases PPP Procedural Updates
6/18/2020 - Senate PPP Legislation and FDIC Inspector General's Report on Challenges of COVID-19 Pandemic<
6/17/2020 - SBA Publishes Revised Forgiveness Application and New "EZ" Forgiveness Application
6/16/2020 - SBA Administrator Carranza Recognizes CDFIs' PPP Efforts
6/15/2020 - PPP Lending Report and EIDL Program Reopening
6/12/2020 - System Maintenance for SBA Loan Capital Access Financial Systems
6/11/2020 - News Coverage of PPP Execution and Senate Small Business Hearing
6/10/2020 - Senate Small Business and Entrepreneurship Hearing on CARES Act and FDIC MDI Study
6/9/2020 - PPP Flexibility Act Implementation Guidance
6/8/2020 - Federal Reserve Adjusts Main Street Lending Programs and Treasury Secretary Mnuchin Statement on PPP Flexibility Act
6/4/2020 - Forgiveness Calculator Tool
6/3/2020 - CDBA Members Testify in House Financial Services Committee Hearing and Senate Passes PPP Flexibility Act
6/2/2020 - Senate Support for PPP Legislation and Proposed Improvements to Main Street Lending Program
6/1/2020 - SBA Report on PPP Lending and CDBA and Inclusiv Letter on PPP Legislation
5/29/2020 - House PPP Flexibility Act
5/28/2020 - Legislation to Amend PPP and $10 Billion Set-Aside for CDFIs
5/27/2020 - SBA Debt Relief for 7(a), 504 and Microloan Program Loans
5/26/2020 - Reminder of PPP Interim Final Rule Updates and Free Loan Forgiveness Webinar
5/25/2020 - PPP Interim Final Rule Updates on Loan Forgiveness Requirements
5/22/2020 - Upcoming Legislation: House Paycheck Protection Program Flexibility Act and Senate Restart Act
5/21/2020 - SBA Interim Final Rule Updates and Legislation Easing PPP Loan Restrictions
5/20/2020 - Interagency Lending Principles for Responsible Small-Dollar Loans and OCC CRA Final Rule
5/19/2020 - Heroes Act Summary, CRA Modernization Update, and Form 1502 Deadline Extension
5/18/2020 - Federal Reserve Updates on Outstanding Liquidity Facilities and SBA Guidance on Foreign Affiliates
5/15/2020 - PPP Loan Forgiveness Application Released
5/14/2020 - Guidance on Loan Increases and E-tran Updates
5/13/2020 - Loan Forgiveness Safe Harbor for Amounts Under $2 Million and SBA Data Request
5/12/2020 - PPP Funds Return Date Extension and FDIC Proposed Rulemaking on Mitigating Effects of Participation in PPP
5/11/2020 - SBA Inspector General Report and Michigan Judge Invalidates Rule Barring Banks from PPP Loans 
5/8/2020 - Nonprofit Loan Fund PPP Ineligibility<
5/7/2020 - Updated Implementation FAQs, Interim Final Rule, and Loan Data
5/6/2020 - Extended Repayment Period for PPP Borrowers and Updated Round Two Data
5/5/2020 - Liquidity Coverage Ratios Modifications and AICPA PPP Loan Forgiveness Tool
5/4/2020 - PPP Round Two Results Report
5/1/2020 - Federal Reserve PPPLF and MSLP Updates and IRS Expense Deduction Update
4/30/2020 - SBA Announces PPP-Specific Process for Form 1502 Filings and FAQ Updates
4/29/2020 - SBA and Treasury Implementation Updates on Disbursement and Seasonal Employers
4/28/2020 - PPP Relaunch Progress and SBA Prohibition on RPAs
4/27/2020 - PPP Relaunch and Democratic Congressional Leaders' Letter to SBA and Treasury
4/24/2020 - SBA Procedural Notice and Updated Interim Final Rule and FAQs
4/23/2020 - Treasury FAQs, Liquidity Facility Disclosures, and PPP Webinar for New Lenders
4/22/2020 - Agency Webinar for PPP Lenders
4/21/2020 - Extended PPP Funding Deal and SBA Borrower Debt Relief
4/20/2020 - SBA Clarifies PPP Secondary Market Sale Requirements
4/17/2020 - PPP Results Report Released
4/16/2020 - PPP Funds Exhausted
4/15/2020 - Fed Liquidity Facilities FAQs and FinTech PPP Lenders
4/14/2020 - Updated PPP Interim Rules and SBA Approvals Report
4/13/2020 - Treasury FAQs and Sole Proprietorship Eligibility
4/9/2020 - Implementation Materials, Fed Liquidity Facilities, and FinCEN Reporting
4/7/2020 - Implementation Materials and Interagency Statement on COVID-19 Borrowers
4/6/2020 - Changes to Community Bank Leverage Ratio
4/4/2020 - E-Tran Security and Lender/Borrower Applications
4/3/2020 - PPP Interim Final Rule and Fact Sheets 

Additional COVID-19 Resources

Small Business Needs - Small Business Administration (SBA)

Numerous agencies and organizations have published guides to the small business provisions of the CARES Act. Included here are links to some of the most useful ones:

Below are summaries of some of the provisions. 

Paycheck Protection Program: UPDATE 4/23/2020: Treasury updated FAQs addressing the ability of large companies with adequate sources of liquidity
to qualify for PPP loans. (Click here for the FAQs).  UPDATE 4/14/2020: Treasury released additional PPP guidance addressing the eligibility of self-employed individuals as well as businesses owned by directors or shareholders of PPP lenders. The update also included clarifications of the requirements for pledging PPP loans for borrowing from a Federal Reserve Bank or Federal Home Loan Bank. (Click here for the Treasury guidance). UPDATE 4/13/2020: Treasury released additional PPP guidance in the form of FAQs. Topics included non-bank lender eligibility, the $10 million cap as it relates to franchises, hotels and restaurants under the affiliation rule, and the collection of BSA-related information from business owners with a 20% or higher interest. (Click here for the Treasury guidance). UPDATE 4/7/2020: Treasury and SBA released additional PPP guidance in the form of FAQs. Topics included the subject of faith institutions. (Click here for the Treasury guidance.) (Click here for the SBA faith institution guidance). UPDATE 4/7/2020: American Banker reported that Treasury plans to request an additional $250 billion supplement for PPP. (Click here for article).  UPDATE 4/6/2020: The Federal Reserve announced it will establish a facility to facilitate lending to small businesses via the PPP by providing term financing backed by PPP loans. (Click here for the announcement). UPDATE 4/3/2020: Detailed guidance for implementing the program is published. (Click here for the interim final rule).  All existing SBA-certified lenders will be given delegated authority to speedily process PPP loans. (Click here to see if your CDFI bank is SBA-approved). All federally insured depository institutions, federally insured credit unions, and Farm Credit System institutions are eligible to participate in this program. (Click here for the new lender application.) The New Lender Application Form (Federally Insured Depository Institutions, Federally Insured Credit Unions, Farm Credit System Institutions) can be submitted to delegatedauthority@sba.gov

The PPP provides cash-flow assistance through 100 percent federally guaranteed loans to employers who maintain their payroll during this emergency. If employers maintain their payroll, the loans will be forgiven (as long as at least 75% of the loan has used for payroll related expenses). PPP also includes no SBA fees, and six months of deferral. Small businesses and other eligible entities, including non-profits and veterans organizations, will be able to apply if they were harmed by COVID-19 between February 15, 2020 and June 30, 2020. This program will be retroactive to February 15, 2020, in order to help bring workers who may have already been laid off back onto payrolls. Loans are available through June 30, 2020.

CDBA joined other banking trades in supporting the PPP under the CARES Act. (Click here for the support letter).

Small Business Debt Relief ProgramUPDATE 4/8/2020SBA issued Procedural Guidance. (Click here). This program will provide immediate relief to small businesses with non-disaster SBA loans, in particular 7(a), 504, and microloans. Under this program:
The SBA will pay the principal and interest of new 7(a) loans issued prior to September 27, 2020, and the SBA will pay the principal and interest of current 7(a) loans for a period of six months.

Economic Injury Disaster Loans (EIDL) & GrantsThe SBA has also been authorized to modify its direct disaster lending through the Economic Injury Disaster Loans (EIDL) program. (Click here for the application). The program can be used in conjunction with the PPP. The program offers loan amounts up to $2 milion, terms of up to 30 years based on ability to repay, rates of 2.5% for nonprofits and 3.5% for for-profits, as well as expedited approval based solely on credit scores, and 1-year deferment on loans provided due to COVID-19. Loan advance grants now also provide an emergency advance of up to $10,000 to borrowers harmed by COVID-19 within three days of applying. The advance does not need to be repaid under any circumstance, and may be used to keep employees on payroll, to pay for sick leave, meet increased production costs due to supply chain disruptions, or pay business obligations, including debts, rent and mortgage payments.

Counseling and TrainingBusiness owners are encouraged to contact “Small Business Development Centers (SBDC), Women’s Business Centers (WBC), or SCORE mentorship chapters. These resource partners, and the associations that represent them, will receive additional funds to expand their reach and better support small business owners with counseling and up-to-date information regarding COVID-19. There will soon be a joint platform that consolidates information and resources related to COVID-19 in order to provide consistent, timely information to small businesses. To find a local resource partner, visit https://www.sba.gov/local-assistance/find/. In addition, the Minority Business Development Agency’s Business Centers (MBDCs), which cater to minority business enterprises of all sizes, will also receive funding to hire staff and provide programming to help their clients respond to COVID-19.”

Bank Regulatory Concerns - Interagency (FDIC, OCC, Federal Reserve, FASB)

Troubled Debt RestructuringsUPDATE 4/7/2020: The agenices published an updated joint statement. (Click here for the statement). On March 22, the Agencies (OCC, FDIC, Federal Reserve, FASB) published a joint statement to assure lenders that efforts to provide relief to COVID-19 impacted borrowers will not necessarily lead to criticism of modified loans as Troubled Debt Restructurings. (Click here for the statement).

The Statement encourages lenders “to work prudently with borrowers who are or may be unable to meet their contractual payment obligations because of the effects of COVID-19,” and states:

“The agencies will not criticize financial institutions that mitigate credit risk through prudent actions consistent with safe and sound practices. The agencies consider such proactive actions to be in the best interest of institutions, their borrowers, and the economy.”

Evaluations and Appraisals for Real Estate Transactions: UPDATE 4/15/2020: The federal banking agencies have issued an interim final rule to temporarily defer real estate-related appraisals and evaluations under the agencies' interagency appraisal regulations. (Click here).

Current Expected Credit Losses (CECL): The CARES Act also provides that banks have the option to temporarily delay measuring credit losses on financial instruments under the new Current Expected Credit Losses methodology promulgated under Financial Accounting Standards Board Accounting Standards Update No. 2016-13. The option to delay expires at the earlier of December 31, 2020, or the date on which the national emergency declaration related to COVID-19 is terminated. The FDIC issued a Financial Institutions Letter on the interaction of the CARES Act with the CECL rule. (Click here for the letter).

Fair Credit Reporting: The CARES Act amends the Fair Credit Reporting Act to provide that, if an institution that furnishes information to credit reporting agencies makes an "accommodation" with respect to one or more payments on a credit obligation or account of a consumer, and the consumer makes the payments or is not required to make one or more payments pursuant to the accommodation, then the furnisher must report such obligation or account as "current" (or as the status reported prior to the accommodation) during the period of accommodation.

Foreclosure Moratoriums and Consumer Forbearance: A borrower with a federally-backed mortgage loan may request forbearance regardless of delinquency status by submitting a request to the borrower's servicer and affirming that the borrower is experiencing a financial hardship during the COVID-19 pandemic. Upon such a request, borrowers are provided up to 180 days of forbearance, which will be extended for an additional period of up to 180 days, provided that the borrower requests an extension.

CRA Consideration for COVID-19 Related Activities: On March 9, 2020, the federal financial institution regulatory agencies and state bank regulators issued a statement to encourage financial institutions to meet the financial services needs of their customers and members in areas affected by COVID-19. Favorable will be given to retail services that include accomodations such as waiving fees and modifying loan terms. Also, favorable consieration will be given for activities conducted in a bank's broader statewide or regional area. (Click here for the statement).

Bank Regulatory Concerns - FDIC

Liquidity: The CARES Act authorizes the FDIC to implement liquidity guarantee programs, including unlimited insurance for accounts held in non-interest-bearing transaction accounts through December 31, 2020. (Click here for the legislation).

The FDIC has acknowledged the liquidity concerns of CDFI and community banks as depositors have acted on the impulse to remove accounts in a perceived “flight to quality.” Chairman Jelena McWilliams recorded a video to explain that the best place to keep money remained in an FDIC-insured bank (Click here for the video) and the Corporation has provided a FAQ on their COVID-19 resource page. (Click here for the FAQ).

Bank Regulatory Concerns - Federal Reserve

Liquidity: UPDATE 4/16: The Federal Reserve on Thursday announced that its PPP Liquidity Facility is fully operational and available to provide liquidity to eligible financial institutions, which will help support small businesses. (Click here). UPDATE 4/9: The Federal Reserve has released details of the facilities it is introducing to provide up to $2.3 trillion in loans to support the economy. At present, the facilities do not mention special provisions for CDFIs or other community lenders. (Click here for announcement and draft term sheets). UPDATE 4/6/2020: The Federal Reserve announced it will establish a facility to facilitate lending to small businesses via the PPP by providing term financing backed by PPP loans. (Click here for the announcement). The CARES Act authorizes the Federal Reserve to provide liquidity to the financial system that supports lending to eligible businesses, States, or municipalities by "purchasing obligations or other interests directly from issuers of such obligations or other interests; purchasing obligations or other interests in secondary markets or otherwise; or making loans, including loans or other advances secured by collateral." (Click here for the legislation).

Bank Regulatory Concerns - CDFI Fund

Fund Operations: On April 1, Director Harris released a statement acknowledging the operational challenges facing CDFIs and CDFIs' concerns about meeting reporting deadlines. Director Harris stated that the Fund takes the concerns seriously and will handle reporting issues on a case-by-case basis. (Click here for the message).

Reporting and Performance Deadlines: UPDATE 4/7/2020: The Community Development Financial Institutions Fund (CDFI Fund) will extend the upcoming application deadlines for the fiscal year (FY) 2020 funding round of the Community Development Financial Institutions Program (CDFI Program) and Native American CDFI Assistance Program (NACA Program). The new deadlines are: 

  • April 28, 2020 at 5:00 p.m. ET: the last day to contact CDFI Program and NACA Program staff with questions about the application (previously April 17, 2020)
  • April 30, 2020 at 5:00 p.m. ET: the last day to contact the CDFI Fund’s IT Help Desk with any technical problems with the Awards Management Information System (AMIS) (previously April 21, 2020)
  • April 30, 2020 at 11:59 p.m. ET: the last day to submit a complete FY 2020 CDFI Program or NACA Program Financial Assistance or Technical Assistance Application through AMIS (previously April 21, 2020)

All other deadlines and requirements in the FY 2020 CDFI Program and NACA Program NOFAs as previously published on February 21, 2020, remain in effect and unchanged. The deadline to submit the SF-424 via Grants.gov to request assistance through the FY 2020 application round was March 23, 2020.

CDBA had previously asked the CDFI Fund to provide extensions without adverse consquences for reporting and performance requirement submissions. (Click here for the letter).

Emergency AppropriationUPDATE 4/7/2020: CDBA has organized other banking trades to support a $1 billion emergency appropriation in an expected fourth round of emergency legislation. (Click here for the letter). Unfortunately, the stimulus packages to date have not included increased funding for the CDFI Fund. Prior to the passage of the CARES Act, CDBA joined other CDFI trades in supporting a $1 billion emergency appropriation for the Fund and is now working with partners to ensure that an emergency appropriation will be included in an expected fourth stimulus package.