DAILY UPDATE ON PAYCHECK PROTECTION PROGRAM LOANS
As of April 29th: Mnuchin threatens audit of Paycheck Protection Program (PPP) recipients
Index
UPDATE:
On April 29th, Treasury threatens audits of PPP recipients, gets sued over PPP ban for companies in bankruptcy, and bans the use of robots to submit applications
Treasury Secretary Mnuchin threatens audits of PPP recipients (Here and Here)
Fortune goes "Inside the Chaos" at the SBA
Financial times says PPP doesn't meet the needs of restaurants (Here)
Inc asks What to do when the PPP runs out
Cosi sues the SBA over bankruptcy rule
Short window reserved for smallest lenders
North Carolina SBA director says small business have better chance this time
SBA & Treasury ban use of robots to submit PPP loans
SBA Guidance
Find a copy of the "Final" Paycheck Protection Program Loan application form is available HERE.
For a top-line overview of the program CLICK HERE.
As a borrower, more information can be found HERE.
An Interim Final Rules have been issued HERE.
Additional Eligibility Criteria and Requirements for Certain Pledges of Loans
Additional information on Promissory Notes, Authorizations, Affiliation, and Eligibility
Frequently asked Questions (Updated 4/24/2020 HERE
Information for Faith Based Organizations HERE
SBA List of Lenders
On April 23rd, SBA published a list of more than 500 banks, credit unions and other lenders participating in the PPP in NC. (This list seems likely to be in the order of most applications submitted in the first round or most funding received in NC.)
Red Background means the lender is not accepting applications. Green means the lender is accepting applications. Yellow means it is unclear.
We have marked the smaller lending institutions with an § if they have between $10 billion and $50 billion in assets and with §§ if they have assets less than $10 billion. These lenders have reserved funds in the second round.
Truist Bank d/b/a Branch Banking & Trust Co
First Citizens Bank & Trust Company §
PNC Bank, National Association
First National Bank (of Pennsylvania) §
Southern Bank and Trust Company
Towne Bank §§
First Bank §§
Bank of America, National Association
Aquesta Bank §§
American National Bank and Trust Company §§
Peoples Bank §§
JPMorgan Chase Bank, National Association
Select Bank & Trust Company §§
The Park National Bank (Carolina Alliance) §§
Union Bank §§
Bank OZK §
Newtek Small Business Finance, Inc.
Blue Ridge Bank, National Association §§
OneWest Bank, A Division of CIT
BMO Harris Bank National Association
Citizens Bank, National Association
Wells Fargo Bank, National Association
BlueHarbor Bank
United Bank
Toyota Financial Savings Bank
United FCU §§
KeyBank National Association
East West Bank
Radius Bank
Bell Bank
Greater Nevada CU
Bremer Bank, National Association
Wintrust Bank, National Association
Minnesota Bank & Trust
Alliance Bank & Trust Company
Cadence Bank, National Association
LifeStore Bank
Renasant Bank
Benchmark Community Bank
Coastal Bank & Trust
First Commonwealth Bank
Modern Bank, National Association
Webster Bank, National Association
IBERIABANK
Corning FCU
MetaBank, National Association
BankUnited, National Association
Trustmark National Bank
American Bank of the Carolinas d/b/a American Bank
Bank Leumi USA
Manufacturers and Traders Trust Company
Piedmont Federal Savings Bank
Pacific Premier Bank
TCF National Bank
Liberty Bank
Stearns Bank National Association
Nantahala Bank & Trust Company
Bank of Tennessee
UMB Bank, National Association
WebBank
West Town Bank & Trust
Byline Bank
Enterprise Bank of South Carolina
Village Bank and Trust, National Association
Academy Bank, National Association
BOKF, National Association
Hanmi Bank
Centennial Bank
Arvest Bank
Plains Commerce Bank
University Bank
Transportation Alliance Bank, Inc. d/b/a TAB Bank, Inc.
Lake Forest Bank & Trust Company, National Association
CapStar Bank
Congressional Bank
MidFirst Bank
Community First Bank, Inc.
Mountain Bizcapital, Inc.
Hiawatha National Bank
IncredibleBank
INTRUST Bank, National Association
1st Source Bank
Celtic Bank Corporation
First Financial Bank
U.S. Bank, National Association
Touchstone Bank
Popular Bank
Central Bank of Lake of the Ozarks
Capital Bank, National Association
National Cooperative Bank, National Association
Independent Bank
First Capital Bank
Enterprise Bank & Trust
S & T Bank
Gulf Coast Bank and Trust Company
Saints Avenue Bank
CenterState Bank, National Association
Bank of the Flint Hills
Texas Capital Bank, National Association
Suncoast CU
Mid Penn Bank
Fulton Bank, National Association
ServisFirst Bank
South Atlantic Bank
Westfield Bank, FSB
Partners Bank of California
Atlantic Capital Bank, National Association
First United Bank and Trust Company
America's Christian CU
Sandy Spring Bank
Community Banking Company of Fitzgerald
Cogent Bank
The Leaders Bank
CoBank ACB
Fidelity State Bank and Trust Company
Touchmark National Bank
Oriental Bank
Newton Federal Bank
Midwest Bank
Bank of Clarke County
First Resource Bank
Anderson Brothers Bank
Valley National Bank
Sandhills Bank
First Command Bank
First Community Bank
First State Bank
Pinnacle Bank
Movement Bank
Zions Bank, A Division of
First Merchants Bank
Commerce Bank
First Bank Financial Centre
Citizens Bank
Southern First Bank
Origin Bank
The Piedmont Bank
Coastal States Bank
EverTrust Bank
First Savings Bank
Millennium Bank
The Old Point National Bank of Phoebus
Carolina Bank & Trust Co.
United Midwest Savings Bank, National Association
Sunwest Bank
Farm Bureau Bank, FSB
Flagstar Bank, FSB
First Midwest Bank
First International Bank & Trust
American National Bank
Customers Bank
Bank of George
New York Business Development Corporation
Midwest BankCentre
Midland States Bank
Oxford Bank
Queensborough National Bank and Trust Company
The Provident Bank
Northstar Bank
The Farmers National Bank of Canfield
Beacon Community Bank
Republic Bank & Trust Company
Connecticut Community Bank, National Association
The Conway National Bank
First Bank
Coastal Carolina National Bank
Putnam County Bank
WesBanco Bank, Inc.
Old National Bank
The First Bank and Trust Company
Village Bank
First Secure Bank and Trust Co.
Legacy Bank
First State Bank Nebraska
Allegiance Bank
Settlers Bank
Horizon Bank
Bank of Ann Arbor
Amarillo National Bank
Great Plains National Bank
Silver Lake Bank
Community Trust Bank, Inc.
Wheaton Bank & Trust Company, National Association
First State Bank
First Palmetto Bank
Business Development Corporation of South Carolina
Bank of York
Treynor State Bank
Merchants and Manufacturers Bank
CFBank, National Association
First Republic Bank
First Federal Bank
T Bank, National Association
Platinum Bank
Security Federal Bank
Georgia Banking Company
Peoples Bank
First Service Bank
First Florida Integrity Bank
Pendleton Community Bank, Inc.
Red River Bank
First American Bank
Level One Bank
Dallas Capital Bank, National Association
Lake City Bank
SAFE CU
First Business Bank
1st Constitution Bank
Royal Banks of Missouri
Meadows Bank
BancFirst
ABNB FCU
Hancock Whitney Bank
Vinings Bank
First Reliance Bank
Seacoast National Bank
Nizari Progressive FCU
First Citrus Bank
Evansville Teachers FCU
Northern Bank and Trust Company
Citizens National Bank
People's United Bank, National Association
Idaho First Bank
First Federal Community Bank, National Association
American Bank, National Association
The Farmers & Merchants State Bank
Glacier Bank
Seacoast Commerce Bank
Small Business Bank
First Federal Bank of the Midwest
Riverview Bank
First Choice Bank
Sabine State Bank & Trust Company
Central Bank of St. Louis
VeraBank, National Association
Investar Bank, National Association
TransPecos Banks, SSB.
The Canandaigua National Bank and Trust Company
CornerstoneBank
Select Bank
First Western Trust Bank
First Midwest Bank of the Ozarks
First Bank of Owasso
First American Bank & Trust Company
Bank of St. Francisville
BMW Bank of North America, Inc.
The National Bank of Blacksburg
Vibrant CU
Union Bank and Trust Company
Signature Bank
Kaw Valley Bank
Citizens Bank of the South
Sterling State Bank
Citizens and Farmers Bank
Solera National Bank
Southern States Bank
Delta Community CU
Adams Bank & Trust
Mars Bank
Embassy National Bank
The Peoples Bank
Prime Meridian Bank
Countybank
Centerstone SBA Lending, Inc.
Tennessee State Bank
Loyal Trust Bank
Metro City Bank
Merchants Bank of Indiana
BANK
United Business Bank
Affiliated Bank, National Association
First Chatham Bank
River Bank & Trust
Southern Michigan Bank & Trust
Western State Bank
First Vision Bank of Tennessee
HSBC Bank USA, National Association
Piermont Bank
Five Star Bank
Umpqua Bank
The MINT National Bank
Bank of Colorado
Carolina Farm Credit, ACA
Optus Bank
Poppy Bank
Central Bank
Nicolet National Bank
The Litchfield National Bank
VisionBank
Enterprise Bank
The National Bank of Indianapolis
California Bank of Commerce
Stock Yards Bank & Trust Company
Altra FCU
Paragon Bank
Berkshire Bank
Stone Bank
The Farmers National Bank of Danville
Wallis Bank
Cambridge Trust Company
NewFirst National Bank
Tandem Bank
CommerceWest Bank
BNB Bank
Keystone Bank, National Association
West Bank
Summit Community Bank, Inc.
Bankwell Bank
Northbrook Bank & Trust Company, National Association
mBank
Commonwealth Business Bank
First Interstate Bank
The First National Bank of Dennison
South Central Bank, Inc.
The Paducah Bank and Trust Company
CRF Small Business Loan Company, LLC
Unity Bank
AgCarolina Farm Credit, ACA
Community National Bank & Trust of Texas
Bankers' Bank of Kansas
United Bank & Trust
Busey Bank
Citibank, N.A.
Peoples Bank
LCA Bank Corporation
Banesco USA
Progress Bank and Trust
Fairfield County Bank
Quantum National Bank
Legence Bank
NBT Bank, National Association
FirstBank Puerto Rico
Emigrant Bank
Thrivent FCU
Mission Valley Bank
Northwest FCU
URW Community FCU
First Farmers Bank and Trust
Pinnacle Bank
Arthur State Bank
GrandSouth Bank
The Union State Bank of Everest
Central Bank & Trust Co.
Community National Bank
BNC National Bank
Bank of Travelers Rest
The Northern Trust Company
Alliance Bank
The Dart Bank
Peoples Bank of Alabama
b1Bank
Bryant Bank
Great Southern Bank
Central Pacific Bank
The Bank of Fincastle
State Bank of Southwest Missouri
Farmers Bank
Spirit of Texas Bank, SSB
Community Banks of Colorado, A Division of
Quaint Oak Bank
Virginia Bank and Trust Company
Digital FCU
Pacific Western Bank
US Eagle FCU
Signature Bank of Georgia
D. L. Evans Bank
BancorpSouth Bank
SouthPoint Bank
Axiom Bank, National Association
Community Bank & Trust-West Georgia
Citizens Bank of Kansas
GBC International Bank
Florida Capital Bank, National Association
German American Bank
First Volunteer Bank
Virginia Commonwealth Bank
Piedmont Advantage CU
Texas Republic Bank, National Association
Trustar Bank
Midwest Regional Bank
Community Bank, National Association
Heritage Bank, National Association
Sunrise Banks, National Association
Waterford Bank, National Association
Austin Bank, Texas National Association
Citizens Bank and Trust Company
PromiseOne Bank
CDC Small Business Finance Corporation
First Bank & Trust
Alpine Capital Bank
Palmetto State Bank
Spring Bank
Liberty Bank and Trust Company
First United Bank & Trust
Frontier Community Bank
New Millennium Bank
United Bank
The Citizens Bank
First Western SBLC, Inc
First Freedom Bank
Forcht Bank, National Association
One Florida Bank
Bank Independent
American Pride Bank
Community Bank of Mississippi
Gulf Coast Bank
The First National Bank in Falfurrias
Valley Strong CU
Norway Savings Bank
Exchange Bank of Missouri
First Mid Bank & Trust, National Association
First Bank of Alabama
Equity Bank
Associated Bank, National Association
First IC Bank
Newton Federal Bank
Buckeye State Bank
Pacific Enterprise Bank
Colony Bank
Rocky Mountain Bank
First Bank
CenTrust Bank, National Association
Webster Five Cents Savings Bank
First Security Bank of Nevada
Frost Bank
DR Bank
Community Bank of Parkersburg
Heritage Bank, A Division of
Community Bank of the Chesapeake
Farmers & Stockmens Bank
Jordan FCU
The Bank of Austin
NBKC Bank
Continental Bank
LincolnWay Community Bank
Park Ridge Community Bank
Chartway FCU
Tulsa FCU
PlainsCapital Bank
Planters First Bank
Fall River Five Cents Savings Bank d/b/a BankFive
Fortress Bank
First Internet Bank of Indiana
Freedom National Bank
Morton Community Bank
Mechanics Bank
First Security Bank
The State Bank
First Citizens Bank
Independence Bank
Fund-Ex Solutions Group, LLC
First Southern Bank
South Carolina FCU
Oconee State Bank
American Savings Bank, FSB
First Southern National Bank
Table Rock Community Bank
Bank of Yazoo City
FineMark National Bank & Trust
New Peoples Bank, Inc.
OptimumBank
Bank of Washington
Civis Bank
Truxton Trust Company
Georgia Primary Bank
Thomasville National Bank
Home Loan Investment Bank, F.S.B.
Four Corners Community Bank
Dime Community Bank
Peoples Bank of East Tennessee
BOM Bank
First Piedmont Federal Savings & Loan Association
F & M Bank
Hancock Bank & Trust Company
Citizens Bank of Lafayette
The Fauquier Bank
York Traditions Bank
San Francisco Fire CU
Farmers and Miners Bank
First Bank & Trust
First Port City Bank
The Fisher National Bank
Oakworth Capital Bank
Civista Bank
F & M Bank and Trust Company
Rockland Trust Company
Elements Financial FCU
Coastal Community Bank
Bank of the James
Community Savings Bank
FNBC Bank
Platte Valley Bank
Mascoma Bank
Kennebec Savings Bank
Farmers and Merchants Trust Company of Chambersburg
Rosedale Federal Savings & Loan Association
Citizens Community Federal National Association
Hana Small Business Lending, Inc.
Johnson Bank
Chesapeake Bank
Gather FCU
Iowa State Bank
iTHINK Financial CU
NebraskaLand National Bank
BankFirst Financial Services
The Union Bank Company
Salem Five Cents Savings Bank
First Community Bank of East Tennessee
United Community Bank
Cornerstone National Bank & Trust Company
First Sentinel Bank
Texas Trust CU
Glenview State Bank
Bank of Eastman
Republic Bank of Chicago
Alpine Bank
Carrollton Bank
Farmers State Bank of Trimont
FirstBank
Axos Bank
Pathfinder Bank
Ventura County CU
Assemblies of God CU
Newport News Shipbuilding Empl CU Inc d/b/a BayPort CU
FirstBank
Alden State Bank
The Bank of Marion
Bar Harbor Bank & Trust
The First National Bank of South Miami
MVB Bank, Inc.
West Gate Bank
Meritrust FCU
Capital City Bank
Carter Bank & Trust and HomeTrust Bank partnered with Kabbage to provide services to their customers.
The Scorecard from the First Round of Lending
from Charlotte Business Journal
Bank of America
370,000 applications
unknown approved
unknown funding
Wells Fargo
370,000 indications of interest
unknown approved
unknown funded
Truist
32,000 loans approved
$10 billion funded
Fifth Third Bancorp
10,000 loans approved
$3.4 billion funded
South State
10,000 inquiries
5,000 loans approved
$900 million funded
First Horizon
9,174 loans approved (743 in Charlotte)
unknown funded
Pinnacle Financial
12,000 applications
6,000 loans approved
$1.8 billion funded
5,500 applications for second round
PNC Financial Group
10,000s loans approved
billions of dollars funded
Bank OZK
7,000 applications received
2,109 loans approved
$327 million funded
F&M Bank
100s loans approved
millions of dollars funded
Towne Bank
5,000 applications processed
$1 billion funded
Uwharrie Bank
830 applications received (100 businesses dropped out)
523 loans approved
$55 million funded
150 applications for 2nd round
Aquestra Bank
854 applications received
684 loans approved
$117.2 million funded
Regions Bank
$2.8 billion loans funded
NewDominion
200 approved applications (all applications processed)
$40 million funded
Blue Harbor Bank
100 loans approved
$10 million funded
Live Oak Bank
4957 applications approved
978 million funded
Prior Updates from Second Round
On April 28th, more than 100,000 PPP approvals issued by SBA; PPP Bookkeeping advice; Bailing out the Girl Scouts
CNN describes 100,000 approvals and widespread frustration
Second Round of PPP instant replay of first
How PPP failed businesses
Advice on PPP Bookkeeping
PPP balances the letter and the spirit of the law
Alaska Girl Scouts get PPP for lost cookie sales
Over the weekend, SBA added a few new FAQs, including guidance on housing allowances
On April 27th, "The SBA will resume accepting Paycheck Protection Program applications from participating lenders on Monday, April 27, 2020 at 10:30am EDT." Things did not go as planned.
PPP System Crashes within minutes of Second Round Launch
Tech issues and backlogs on day one
Glitches hamper second round
Reopening under Crush of Demand
SBA E-tran opened with issues and Bulk data transfer was expanded
SBA says it has processed more than 100,000 PPP loans by more than 4,000 lenders today. Its systems are strained because there are double the number of users accessing it compared to any day during round 1 of PPP
Over the weekend, SBA added a few new FAQs, including guidance on housing allowances
On April 22nd, the Senate approves $310 billion of which will top off the depleted PPP fund directly. Of those funds $30 billion is set aside specifically for institutions with less than $10 billion in assets and $30 billion for institutions with between $10 billion and $50 billion. (Copy of Bill)
Details:
Funding could evaporate in 2 days
Fintechs not included in this round
Link to First Round Information
If you have a questions about the CARES ACT or issues affecting your business in this crisis, contact Allen Stahl + Kilbourne
By James Kilbourne and Derek Allen
Updated: April 27, 2020
Any statements contained herein do not constitute a formal legal opinion and should not be relied upon as such. These articles are intended for general informational purposes only. Nothing expressed shall be grounds for the creation of an attorney-client relationship. Our attorneys can give legal advice only in the context of an attorney-client relationship after a conflict check, the execution of a representation agreement and a discussion of the specific information and unique issues of your particular circumstances.
The situation surrounding COVID-19/coronavirus is changing constantly; as a result, any discussions that might take place may not necessarily reflect the latest information regarding recently-enacted, or pending or proposed legislation or guidance that could override, alter or otherwise affect existing legal analysis.
