We’ve heard about the E-Tran security request issues. Here’s what's happening improve this now while preserving IT infrastructure security.

  1. SBA is running a script to enable all lenders that previously had an account with CAFS (Capital Access Financial Systems which is the portal to E-Tran) to be automatically reactivated.
  2. Any NEW USERS still must go through the security protocol to receive a user ID and password. That protocol can be found in these links.

Interim final rule issued for Paycheck Protection Program
Everything you need is linked below

Linked here is the interim final rule on the Paycheck Protection Program created by the CARES Act and which goes into operation today. Also provided are SBA Form 2483 which the applicant must submit, and SBA Form 2484 which lenders must submit. The applicant must submit SBA Form 2483 (Paycheck Protection Program Application Form) and payroll documentation. The lender must submit SBA Form 2484 (Paycheck Protection Program Lender’s Application for 7(a) Loan Guaranty) electronically in accordance with program requirements and maintain the forms and supporting documentation in its files.

The new interim final rule makes significant changes from original plans, including raising the fixed interest rate on loans made under the program from 0.5% to 1% in response to banking feedback that the terms could prevent community banks from participating in the program. Since passage of the CARES Act last week, CBA has shared bankers’ views with the agencies and particularly key Members of Congress who have the ear of Secretary Mnuchin to ensure the PPP works as intended when Congress passed it a week ago and that all banks can participate fully and efficiently.

The new rule provides greater clarity on several issues. It specifies underwriting expectations, which are limited to the application form and the streamlined certifications in it, the borrower’s payroll documentation and applicable Bank Secrecy Act requirements. Lenders may rely on borrower documentation for loan forgiveness, providing greater protection for lenders should borrowers misrepresent information in their application. The rule says “The lender does not need to conduct any verification if the borrower submits documentation supporting its request for loan forgiveness and attests that it has accurately verified the payments for eligible costs. The Administrator will hold harmless any lender that relies on such borrower documents and attestation from a borrower.”

After seven weeks, lenders may request that SBA purchase the expected forgiveness amount of PPP loans; these requests may be submitted in advance, and SBA will purchase the expected forgiveness amount of the loan within 15 days after it receives a complete report.

Banks already certified as 7(a) lenders may begin approving loan applications with SBA delegated authority today. The rule says that all banks (with few exceptions) will be “automatically qualified” to make loans with delegated authority once they submit SBA Form 3506, which is expected to be posted this morning on the SBA and Treasury websites, along with the official forms 2483 and 2484 to receive the 7(a) guaranty.

Good luck with this. We know many questions remain. As CBA obtains additional information we will provide it to you.  As a reminder we have yet another CBA Webinar this morning at 10 on SBA programs under the CARES Act.  Yesterday’s CBA Webinar covered the Paycheck Protection Program and other SBA programs are the focus this morning. Please contact CBA with any questions or comments.
Colorado Bankers Association
303-825-1575 | 303-825-1585