Coronavirus Government Assistance Programs Information
The VBA has developed this page of resources to help keep Virginia banks informed.
SBA/PPP Information & Key PPP Updates
SBA Re-Opening Paycheck Protection Program to Small
Lenders on Friday, January 15 and All Lenders on Tuesday,
January 19
Lenders with $1 Billion* or Less in Assets Will be Able to
Submit First and Second Draw PPP Applications on January 15 –
Continuing Dedicated Access for Community-Based Lenders
*Please note that the $1B threshold is as of the 12/31/19 call report
Link to PPP page on SBA website, which includes:
- Loan Details
- Loan Forgiveness
- Who Can Apply
- Lender Forms and Guidance
- Program Data
- Other Assistance
Updated Borrower and Lender Guaranty Applications for Both First-draw and Second-draw PPP Loans
- Download the borrower disclosure
- Top-line Overview of PPP First Draw Loans
- Top-line Overview of PPP Second Draw Loans
- Download the borrower application for first-draw loans
- Download the lender guaranty form for first-draw loans
- Download the borrower application for second-draw loans
- Download the lender guaranty form for second-draw loans
Key PPP updates, as of January 12, 2021:
- PPP borrowers can set their PPP loan’s covered period to be any length between 8 and 24 weeks to best meet their business needs;
- PPP loans will cover additional expenses, including operations expenditures, property damage costs, supplier costs, and worker protection expenditures;
- The Program’s eligibility is expanded to include 501(c)(6)s, housing cooperatives, direct marketing organizations, among other types of organizations;
- The PPP provides greater flexibility for seasonal employees;
- Certain existing PPP borrowers can request to modify their First Draw PPP Loan amount; and
- Certain existing PPP borrowers are now eligible to apply for a Second Draw PPP Loan.
PPP Forgiveness information
- Interim Final Rule on PPP Forgiveness – 1/20/2021
- Download Form 3508
- Download Form 3508EZ
- Download Form 3508S
SBA Points of Contact
Payment Protection Program:
- PPP Hotline: (833) 572-0502 for:
- PPP questions and procedures
- Live assistance regarding SBA Paycheck Protection Platform access and support
- Capital Access Financial System (CAFS) and SBA’s Electronic Transmission (E-Tran) systems support
- SBA Paycheck Protection Platform
- SBA Paycheck Protection Platform Inbox (accessed within the
Platform):
- Loan-specific inquiries
- General PPP support
- General Platform functionality
- Platform access
- Policies and procedures
- Loan review
- Payment reconciliation
- General correspondence
- If unable to access the SBA Paycheck Protection Platform
inbox:
- Alternative access to the Platform Inbox: help@ussbaforgiveness.com
- General PPP questions: PPPForgivenessRequests@sba.gov
- Advanced technical support, API support and UAT error support:developer@ussbaforgiveness.com
- PPP Lender Fees – questions and corrections: PPPLenderFeeResearch@guidehouse.com
- E-Tran and CAFS – questions and technical support: cls@sba.gov or 833-572-0502 or SBA Paycheck Protection Platform inbox
Regular SBA Business Loan Programs:
- 7(a) Loan Program: Contact your SBA District Office; or 7aQuestions@sba.gov
- 504 Loan Program: Contact your SBA District Office; or 504Questions@sba.gov
- Microloan Program: Contact your SBA District Office; or Microloans@sba.gov
SBA Lenders & Public:
- Questions on PPP, 7(a), Microloans, or 504 Loan Programs: Contact your SBA District Office
- PPP Public Documents & Guidance:
PPP Information – Treasury and
PPP Information – SBA
- Office of Disaster Assistance (Disaster/EIDL):
- Comments on PPP interim final rules: https://www.regulations.gov or, only if including confidential business information: ppp-ifr@sba.gov
- General questions: DisasterCustomerService@sba.gov or 800-659-2955
- For subordination of collateral with EIDL: PDC.AccountsCollateralReview@sba.gov
Recently Released SBA/PPP Guidance & SAM.gov Information
- Guidance on maximum loan size calculations
- Notice on forgiveness
- Notice on excess loan errors
- SBA FAQs on Revenue Reduction, Max Loan Amount Calculations for Second-Draw PPP Loans - as of 1/19/2021
- PPP Guidance from SBA Administrator Carranza on Accessing Capital for Minority, Underserved, Veteran, and Women-Owned Business Concerns
- Interim Final Rule on Paycheck Protection Program as Amended by Economic Aid Act
- Interim Final Rule on Second Draw PPP Loans
- View the recording from recent VBA Update with ABA’s James Ballentine and Dan Martini
SAM.gov Information & Key Updates
According to SBA, lenders that were previously making PPP loans do not need to re-register with SBA to make first-draw or second-draw loans in this round of funding, although all participating lenders must register on SAM.gov. This requirement comes directly from IFR#1, which provides, in part:
“2. Do lenders have to register in SAM.gov to make PPP loans?[95]
Yes. Given the exigent circumstances in which small businesses and lenders currently find themselves due to the COVID-19 pandemic, PPP lenders will have thirty (30) days from the date of the first PPP loan disbursement made by them after December 27, 2020 to complete SAM registration and provide SBA with the lender’s unique entity identifier.”
Footnote [95] further provides “This subsection adds a new requirement that all PPP lenders must register in SAM.gov. See 2 CFR 25.110(c)(2)(iii).” The regulations at 2 CFR 25.110(c)(2)(iii)further provide:
“(iii) For an applicant, if the Federal awarding agency makes a determination that there are exigent circumstances that prohibit the applicant from receiving a unique entity identifier and completing SAM registration prior to receiving a Federal award. In these instances, Federal awarding agencies must require the recipient to obtain a unique entity identifier and complete SAM registration within 30 days of the Federal award date.”
- SAM.gov Registration Information
- Read the procedural notice on lender registration.
- View the platform user guide.
- View the API technical information.
It is noted that the registrations in SAM.gov does require someone at the lender register as a user so they may add the lender to SAM.gov, and also make changes as necessary after registration of the lender in SAM.gov. Usually, this is done at an corporate office level and usually not done by the small business lending or commercial credit staff of the lender. There is no charge to register or become a registered user in SAM.gov.
Second, SBA SOP 50 10 6 requires the SBA Lender to consult the SAM.gov Exclusions to determine if any Agents involved in the loan process, or Associates of the small business Applicant have been suspended, debarred, revoked, or otherwise excluded by SBA or another Federal agency, and document the loan file with “screen shots” from their search results. (see SOP 50 10 6 Part 2, Section A, Ch. 5, Para. B., beginning on page 170). This verifications is done for every SBA loan. SAM.gov does not require anyone to register in order to perform a search of the SAM Exclusions listing. This search is also done at no charge to the user.
Third, Lenders are also are required to verify all employees of the lender (including agents of the lender, including LSPs)) are not in the SAM.gov Exclusion listing as well, and that check is usually done at the hiring or onboarding of the of the employee or Agent, and the documentation kept in the lenders records for review at anytime by SBA. This is a one-time verification of the Lender’s employees (including Agents and LSPs) involved in any way with the SBA loan process (from generation, closing, servicing, and liquidation. Again, SAM.gov does not require anyone to register in order to perform a search of the SAM Exclusions listing. This search is also done at no charge to the user.
Economic Impact Payment Information
The Internal Revenue Service announced on January 11th that—in a reversal of previous guidance—it will reissue payments for taxpayers who did not initially receive their second-round economic impact payments due to a processing error. The IRS noted that these payments may either be issued as paper checks or via an ACH direct deposit, and that taxpayers do not need to take action in order to receive their reissued payment.
- Coronavirus Response and Relief Supplemental Appropriations Act - Key Highlights
- ABA EIP Backgrounder
- ABA EIP Talking Points
Rebuild VA
Last month, Governor Ralph Northam allocated an additional $20 million in federal CARES Act funding to the Rebuild VA economic recovery fund to meet demand for the program and fulfill pending grant applications. This new funding will bring the program total to $120 million and will enable more than 300 small business and nonprofit organizations that applied before the last round of funding was exhausted in early December to receive grants. In December, Governor Northam announced that Rebuild VA had fully committed the $100 million in federal funds previously allocated to the program, which provided grants to 2,500 small businesses and nonprofits whose normal operations were disrupted by the COVID-19 pandemic. To date, Rebuild VA has received nearly 20,000 applications and the average grant award was $35,636. You can read the full release here.
VBA Partner Resources
Abrigo
Abrigo has begun supporting community financial institutions participating in the latest round of PPP through its Sageworks SBA Lending solution. Customers leveraging the solution can simplify and automate the underwriting processes of PPP so you can quickly get money into the hands of small business owners. Learn how you can get implemented and begin automating PPP loans within 48 hours.
- January 11th Webinar Recording – What’s Changed with PPP in 2021
- PPP Live Demo – Abrigo will be adding additional times/dates frequently
- Blog post – Lender guidance for borrowers wanting a second loan
compliance alliance
Compliance Alliance has put together new tools and resources as you prepare for PPP re-opening. You can find all of these resources here. Resources include:
- C/A Summary of IFR Paycheck Protection Program as Amended by Economic Aid Act
- C/A Summary of SBA Procedural Notice: Modifications to SBA Forms 3506, 3507 and 750 CA (PPP)—
- C/A Summary of SBA Procedural Notice: Repeal of EIDL Advance Deduction Requirement for SBA Loan Forgiveness Remittances to PPP Lenders—
- Paycheck Protection Program Tracker
- C/A Summary on SBA FAQ: How to Calculate Maximum Loan Amounts for First Draw PPP Loans
- C/A Summary of SBA Procedural Notice: Resubmissions of Loan Forgiveness Applications, Lender Notice Responsibilities, and Offset of Remittances
- C/A Summary of SBA Procedural Notice: Excess Loan Amount Errors
- Link to SBA Loan Forgiveness Application—Form 3508S (1.19.2021)
- Link to SBA Loan Forgiveness Instructions—Form 3508S (1.19.2021)
- Link to SBA Loan Forgiveness Application—Form 3508EZ (1.19.2021)
- Link to SBA Loan Forgiveness Instructions—Form 3508EZ (1.19.2021)
- Link to SBA Loan Forgiveness Application—Form 3508 (1.19.2021)
- Link to SBA Loan Forgiveness Instructions—Form 3508 (1.19.2021)
- Link to SBA Form “Borrower’s Disclosure of Certain Controlling Interests” 3508D
Compliance Alliance Huddles & Recordings
Upcoming Huddle: PPP Huddle on January 27th at 3:30 pm. Register for this Huddle here.
The following Huddle recordings can be found here.
- January PPP Huddle 2021 (recording)
- PPP Compliance Huddle 01/20/21 (recording coming soon)
VBA Media Relations & Resources
- VBA Newsroom – read recent VBA press releases and articles
- VBA In the News – read recent mentions of VBA and VBA member banks in the news
VBA MEMBER BANKS TWITTER LIST
The VBA has put together a list of our member banks on Twitter. This is a finely-curated feed of all our member banks’ Twitter profiles, which displays only the tweets from those organizations. This is a great resource for viewing what other banks are doing and sharing at this truly unique time. Please be sure to pass this tool along to your marketing team. Don’t see your bank’s Twitter handle on the list? Email Chandler Owdom to be added to the list.