Week of Jan. 11

January 12, 2021

In This Issue…

SBA releases technical information for PPP system
Common questions answered about PPP reopening
OBA education corner …

SBA releases technical information for PPP system

The SBA released technical information tonight that lenders will need to access the updated Paycheck Protection Program loan portal system.

The portal opens Monday but only for “community financial institutions,” which mean CDFIs, MDIs, certified development companies and microloan intermediaries.

The first part released tonight contains information regarding API technical information. The second part is the SBA Paycheck Protection Platform Lender Instructions – Origination Systems User Guide.

You can access both by clicking the links below:

• SBA PPP Lender Instructions — API Technical Information

• SBA PPP Lender Instructions — Origination System User Guide

Common questions answered about PPP reopening

Here are additional details from the SBA’s Dustin Allen regarding the Paycheck Protection Program reopening set for this week.

1. There hasn’t been an application released yet for either of the new PPP loan options. We know there will be one released for the Second Draw PPP loans due to the program changes. We are waiting on further guidance on if a new application will be released for First Draw PPP loans or if we will use the one from the original rollout.

2. We haven’t been given information on the portal that will be used. I”ve heard from lenders we will use ETRAN, the AWS portal or that there will be an entirely new portal rolled out. At this time the PPP team hasn’t provided us with this info.

3. I have sent up for clarification on if a Second Draw PPP loan needs to have the original PPP loan forgiveness payment received or not. These questions are usually asked due to the IFR requirement that the borrower cannot have an unresolved first round PPP loan, they cannot currently be in a review status and/or the requirement that Round 1 PPP funds were used exclusively on approved expenses.

4. I just received definition of a CFI, which is listed below.

Per the Economic Aid Act, a Community Financial Institution (CFI) is one of the four types of lenders. CFIs will be able to submit First Draw (first time) PPP loans starting Monday, Jan. 11. Second Draw (second time) loans starting next Wednesday, Jan. 13.

• Community Financial Development Institution (CDFI).

• Minority Depository Institution (MDI).

• Community Development Corporation (CDC).

• Microlender Intermediary.

Source:

See 15 USC citation below highlighted in yellow. We should have it covered.

Statute – section 23(d)(1)(A)(i) –

(36) Paycheck protection program.-
…

(x) the term “community development financial institution” has the meaning given the term in section 4702 of title 12).
(xi) the term “community financial institutions” means-
(I) a community development financial institution.
(II) a minority depository institution, as defined in section 308 of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (12 U.S.C. 1463 note).
(III) a development company that is certified under title V of the Small Business Investment Act of 1958 (15 U.S.C. 695 et seq.).
(IV) an intermediary, as defined in subsection (m)(11).

OBA education corner …

New year, new events! Check out the OBA education corner to see what events are lined up for the beginning of 2021.

NOTE: Effective March 16, and until further notice, TTS (our webinar provider) has extended the OnDemand access period for all ‘Live Plus Five (Days)’ registrants to 60 days (versus five business days). Also, they are waiving the $75 per location fee for additional locations.

BSA Officer Annual Training, webinar, Jan. 19 — During this program we will cover everything a BSA officer needs to know to run a good program. Learn how to manage risk, CIP, Enhanced Due Diligence in this updated and exciting program.
IRA Update – Information and Clarification, webinar, Jan. 20 — What an IRA roller coaster ride this has been! After a year of deliberations, the SECURE Act was signed into law under the Appropriations Act on December 20, 2019. Most of the provisions became effective on January 1, 2020. There are too many issues and too many potential pitfalls banks will experience if they don’t have a working knowledge of these changes. Forms will be changed, IRA software must be updated which may take a while. This webinar will cover and clarify those changes.
Basic Real Estate Loan Documentation, webinar, Jan. 22 — This webinar provides a comprehensive overview of essential real estate loan documentation requirements, regulatory compliance issues, sound loan administration issues and best practices.
2021 Compliance Update, Jan. 26, Tulsa, Jan. 28, Oklahoma City — The 2021 Compliance Updates will provide a review of issues and concerns facing every bank’s compliance team. The sessions will focus on “hot” topics, trends, and areas that may need more emphasis. Common compliance mistakes also will be covered.
2021 Intermediate Banking School, Session 1, Oklahoma City, Feb. 1-5 — Presented in two sessions, the school is designed to prepare students to serve effectively and profitably the needs and desires of their banks and the banking public. A major objective of the program is to instill an appreciation for and an understanding of the operations and interrelationships of departments within a bank.
2021 Intro to Consumer Lending, Feb. 10, Tulsa, Feb. 11, Oklahoma City — The seminar will cover the basics of consumer lending including the consumer loan function, marketing consumer loans, and making consumer lending decisions based on the five (5) C’s of credit- capacity, capital, collateral, conditions, and character.

One education program, in particular, to be aware of is the OBA Intern Program. The Intern Program will again be active in 2021 and we’re looking for participating banks! For more information on this IMPORTANT program – important not only to aspiring students, but also to participating banks – Contact the OBA education department at (405) 424-5252 or click here for more information!