It’s Back! The Paycheck Protection Program, That Is

December 22, 2020 at 9:26 am 1 comment

The government program everyone loves to hate, and then love again – is back in a third iteration. If everything goes according to plan and the President signs the $900 billion stimulus plan (does it concern anyone that no one seems to know what the exact number is? Then again, when you’re dealing with $900 billion, does a $100 billion here or there matter all that much?) Within 10 days of its enactment, we will be seeing regulations for new, improved, simpler and ultimately much needed rejuvenation of the Paycheck Protection Program. I’ve taken a look at the program, the guts of which you can review in Subtitle B – Community Development Investment on page 358 of this act. Suffice it to say this is not your mother’s PPP – whereas the initial legislative thrust was concerned with keeping people employed at a moment in time when we thought things would be back to normal by next June, the new program greatly expands the expenses for which loans are eligible. For example, eligible businesses can use the money for, among other things, cloud computing services. In addition, a new provision of the law makes businesses eligible for a second loan. Finally, the maximum loan size has been reduced from $10 million to $2 million, and only businesses with 300 or fewer employees are eligible for the loans. 

Now for my soapbox moment. When looking at the value of providing PPP loans, please keep in mind not only the impact on your credit union’s bottom line, but the value to the industry of the prominent participants in this program. In addition, for those of you who can go forward with these loans, please share your stories with your trades. Congress and the public are heavily invested in this program. How they perceive financial institutions engaging consumers will, in my ever so humble opinion, shape the regulations and legislation to come. One other quick note about the legislation – although some of the money is allocated towards education, it falls far short of the funds that states like New York were looking for to help offset pandemic-related costs. Brace yourselves for another unique year as the Legislature continues to operate remotely and budgetary concerns dominate even more than usual. 

On that note, yours truly is signing off until next year. Thanks for reading, with a special shoutout to those of you who took the time to comment on my musings along the way. 

Entry filed under: COVID-19, Federal Legislation, Mortgage Lending, New York State, Political, Regulatory. Tags: , , , .

The Most Informative Blog of the Year Happy Holidays. See you next year… thanks for reading!

1 Comment Add your own

  • 1. Jerry  |  December 23, 2020 at 8:50 am

    Have a great holiday break!

    Reply

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Authored By:

Henry Meier, Esq., Senior Vice President, General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association. In addition, although Henry strives to give his readers useful and accurate information on a broad range of subjects, many of which involve legal disputes, his views are not a substitute for legal advise from retained counsel.

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