Treasury Confirms PPP Lenders May Use Scanned Documents, E-Sign

The Treasury Department today updated its frequently asked questions on the Small Business Administration’s Paycheck Protection Program to confirm that PPP lenders may accept scanned copies of documents, as well as electronic signatures or consents permitted under the E-Sign Act.

Treasury noted that in cases where e-signatures are not feasible and the lender must obtain a wet signature without in-person contact, they should “take appropriate steps to ensure the proper party has executed the document.” The FAQ noted that other signature requirements imposed by other applicable laws still apply.