Month: May 2020 Page 1 of 3

The Federal Reserve Bank of Boston today released several borrower and lender documents and a revised FAQ for the Federal Reserve’s Main Street Lending Program.  The documents were released on the Federal Reserve of Bank of Boston website.  The lending program was established with the passing of the CARES Act and is expected to be operational by early June. 

The Program is meant to support small and medium-sized businesses that were in sound financial condition before the COVID19 pandemic.

Our team is working through all of the information and will include an overview during Monday’s webinar.

The revised FAQ document is 56 pages long and the list of documents released late last night are below:

• Instructions
  
• Lender Registration Certifications and Covenants
• Lender Wire Instructions
• Participation Agreement Transaction Specific Terms
• Participation Agreement Standard Terms and Conditions
• Servicing Agreement
• Assignment-in-Blank
• Co-Lender Agreement Transaction Specific Terms
• Co-Lender Agreement Standard Terms and Conditions
• MSNLF Lender Transaction Specific Certifications and Covenants
• MSELF Lender Transaction Specific Certifications and Covenants
• MSPLF Lender Transaction Specific Certification and Covenants
• MSNLF Borrower Certifications and Covenants
• MSELF Borrower Certification and Covenants
• MSPLF Borrower Certification and Covenants
• Main Street FAQs

Please reach out to cares@brinkersimpson.com… Read More

On May 26, 2020, the bipartisan Paycheck Protection Program Flexibility Act of 2020 (H. R. 7010) was introduced in the House of Representatives to address some of the major concerns voiced by Paycheck Protection Program (PPP) borrower with regard to forgiveness and to modify other provisions of the Program.  

PPP borrowers across the county have expressed major concern with the loan requiring funds be spent over the 8 week covered period following receipt of the loan proceeds.  Many businesses, the most severely impacted, are only now beginning to see relaxed rules or information about reopening plans from their states.  The PPP required borrowers to restore both their headcount and salary levels to pre pandemic levels by the end of the covered period or June 30th. … Read More

Nearly four million people are being sent their Economic Impact Payment by prepaid debit card, instead of paper check, the Internal Revenue Service announced last week. 

The announcement comes as a result of an interpretive rule issuance from the Consumer Financial Protection Bureau (CFPB) clarifying that coronavirus relief payments will not be considered “government benefits” and can be issued as prepaid cards, as a result.  The CFPB has issued a FAQ page with more information.

The determination of which taxpayers receive a debit card was made by the Bureau of the Fiscal Service, another part of the Treasury Department that works with the IRS to handle distribution of the payments. … Read More

The CARES Act was enacted on March 27th, 2020 to provide immediate assistance to individuals, families, and organizations affected by the COVID-19 emergency.

Among the provisions contained in the CARES Act are provisions authorizing SBA to temporarily guarantee loans under the Paycheck Protection Program (PPP).  The intent was to quickly provide funding to struggling business owners impacted by the government mandated public health measures designed to mitigate the spread of the virus.  In service of that goal, the structure of the program relies on borrower documentation and certifications to apply for loans and forgiveness.

The central purpose of the program, per the CARES Act, is keeping workers paid and employed. … Read More

The Small Business Administration released the Paycheck Protection Program (PPP)  Forgiveness Application last week on May 15th (a Friday after the close of business).  We provided a summary of the application HERE and hosted a webinar last week to answer your questions about the application.  You can download and view the Webinar HERE.

Last night the SBA released two new Interim Final Rules related to the PPP.  The first is related to the Forgiveness Application and answers some, but not all, questions we had related to the application.  The second is related to Lender and Borrower Responsibilities, you can find more details on that release HERE. … Read More