The Small Business Administration and the Treasury Department last night updated their Paycheck Protection Program FAQ document to address a question many lenders faced related to closing loans. SBA and Treasury clarified that lenders do not need a separate SBA authorization document prior to issuing a PPP loan.
Instead, lenders must have executed SBA Form 2484, which is the lender application for the SBA guaranty on the loan. “Lenders may include in their promissory notes for PPP loans any terms and conditions, including relating to amortization and disclosure, that are not inconsistent with Sections 1102 and 1106 of the CARES Act, the PPP Interim Final Rule and guidance, and SBA Form 2484,” SBA and Treasury said.
ABA continues to seek SBA and Treasury clarification on other issues that have arisen as banks process and fund PPP loans and will report new guidance to members as it becomes available. (Bankers who may have bookmarked the FAQs on the Treasury website should note that the URL has now changed. This link is the current one.)