As most financial institutions and lenders are aware, in October 2020 the Office of the Comptroller of the Currency (the OCC) issued a rule that required the identification of the "true lender" of a loan to a customer if the...more
On December 27, 2020, President Trump signed the Consolidated Appropriations Act, 2021 (the "Appropriations Act"), which includes a new round of funding for certain qualifying, existing Paycheck Protection Program (PPP)...more
The Federal Reserve Bank of Boston announced yesterday that it is ready to purchase participations in loans originated by eligible lenders under the Main Street Lending Program (the MSLP). The Federal Reserve also announced...more
Since the Small Business Administration (SBA) and United States Treasury (Treasury) issued the first Interim Final Regulations on April 2, 2020 under the Paycheck Protection Program (PPP), borrowers, potential borrowers and...more
Earlier in March, the Federal Reserve Board (FRB), Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration (NCUA) and Office of the Comptroller of the Currency (OCC and collectively with the FRB,...more