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New guidance from SBA
SBA issues guidance on calculating max PPP loan size

SBA on Saturday guidance to help borrowers and lenders calculate and document the maximum PPP loan amount a business may be eligible for. The guidance covers several situations about which lenders have sought clarity.
The guidance addresses calculations and documentation requirements for applicants that are:
  • Self-employed with no employees.

  • Self-employed with employees.

  • Self-employed farmers who report income on Schedule F.

  • Partnerships.

  • Subchapter S and C corporations.

  • Nonprofit organizations.

  • Eligible nonprofit religious organizations, veterans’ organizations and tribal businesses.

  • Limited liability company owners.
“Borrowers and lenders may rely on the guidance provided in this document as SBA’s interpretation of the CARES Act and of the Paycheck Protection Program Interim Final Rules,” SBA added in the guidance.

“The U.S. government will not challenge lender PPP actions that conform to this guidance and to the PPP Interim Final Rules and any subsequent rulemaking in effect at the time.”
SBA announces measures aimed at smoothing operations 

SBA on Sunday notified lenders of several steps it will take to ensure the smooth operation of the program, including pacing the number of loans processed once the system reopens.
Acknowledging that many lenders have a large number of applications currently waiting for submission, SBA said it will allow a one-time large bulk submission of XML files to the E-Tran system from each lender. Lenders using this option must have a minimum of 15,000 loans to submit and should create a single XML file to send to SBA. This file should use the standard 6.0 SBA .xml data set for each loan, delimited. Loan applications submitted in bulk will be processed individually by the E-Tran system once it reopens, and each individual loan is subject to funds availability.

For more information on bulk submissions, lenders may refer to SBA guidance.

SBA also announced that it will cap the maximum dollar amount of funding authority that any one institution may receive to 10% of total PPP funding authority ($660 billion), exclusive of the $60 billion set aside for lenders with assets under $50 billion. Loan applications will continue to be processed on a first-come, first-served basis.

Colorado Bankers Association
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