CFAR’s local bank sent out the following email to its clients a few minutes ago. I thought some of you might find it useful to know, especially the part where they claim no one will be getting these loans before next week.
Clients of Community Bank of the Bay,
The SBA issued its Interim Final Report on the Paycheck Protection Program (“PPP”) on Thursday evening at about 6:00 est. Since then, we and other SBA Preferred Lenders have been reviewing the guidance, and have gotten clarity on some issues and found that others still remain undecided. You may note that this information comes from the Interim Final Rule.
What we have found is that all applications will be submitted digitally. They will be completed directly by you the borrower through our bank’s portal once we provide you with secure access. Along with the application, which is to be an SBA application (not a U.S. Treasury application) THAT HAS NOT YET BEEN FINALIZED, you will need to provide the following so that the Bank can verify payroll information and comply with applicable regulations. Specifically, we must be able to do a number of certifications, including but not limited to the following:
Bank must confirm that borrower was in business and incurred payroll costs on or about February 15, 2020. (please gather your February 2020 payroll information)
Bank must confirm that the loan amount conforms with borrower’s average monthly payroll in the preceding calendar year. (please gather your 2019 payroll information).
Conform with all applicable Bank Secrecy Act / Anti-Money Laundering and Beneficial Ownership regulations. (This will already have been done for borrowing entities that are already clients. If the borrowing entity is an affiliate of a CBB client, but does not have accounts here, we will need to focus on obtaining this information / documentation.)
All in all the application process appears to be fairly simple. The borrower completes the application, certifies to various items of status and provides information on line. The Bank then approves the loan through its SBA Delegated Authority. Because we are required to certify recent payrolls using prior calendar year information, my advice would be to not complicate the application by trying to include a lot of special circumstance employees. For this program, simple equals speed to approval, documentation and receipt of funds.
The loans will be for two years at an interest rate of 1.00% p.a. and SBA will defer all payments during the first six months. Eight weeks after the loan is disbursed the borrower provides the Bank with documentation of how the funds were utilized and applies for loan forgiveness. Per the Interim Final Rule, “ Loan forgiveness will be provided for the sum of documented payroll costs, covered mortgage interest payments, covered rent payments, and covered utilities. Not more than 25% of the forgiven amount may be for non-payroll costs.”
The issue now is of course that the official SBA application and associated on-line portal is not yet finalized. Therefore we have not yet been able to post it to our website and test it. It is the same for other banks. Wells Fargo is stating on their website that they will not offer this loan until Monday at the earliest. And regarding the application that I know others are telling you is official, Chase Bank literally says on their website, “Please do not send us U.S. Treasury applications”. To my knowledge only Bank of America has made a portal available to their clients, but they specifically state that they won’t be processing any applications until mid-next week.
I know this is frustrating, and I assure you it to us as well. Community Bank of the Bay has been an active, SBA Preferred Lender for over ten years. We are in direct contact with the SBA and their national servicer. We assure you that we will keep you informed of the latest information on this Program, and as soon as it is available we will process your application in an efficient and timely manner.
In the meantime, please gather the payroll information that I cited above. If you are planning to apply through an entity that is not already a client of the Bank please contact your RM or branch to get started on opening the account. If you would like to read the Interim Final Report, here is a copy that was distributed by a reputable third party -
CFAR’s local bank sent out the following email to its clients a few minutes ago. I thought some of you might find it useful to know, especially the part where they claim no one will be getting these loans before next week.
We’re now in contact with Chase (our bank) about applying. Unsure about the timeline.