Williams Mullen's COVID-19 Comeback Plan: Preparing Today for Tomorrow's PPP Audit
The United States Court of Appeals for the Fifth Circuit (the “Fifth Circuit”) ruled on December 31, 2024 that Serta Simmons Bedding’s (“SSB”) 2020 uptier exchange included a transaction that, contrary to the assertions of...more
The Department of Veterans Affairs (VA) made significant changes to its loss mitigation program this month, launching its awaited Veterans Affairs Servicing Purchase Program, and implementing a 40-year loan modification term....more
As federal student loan repayments resume after a three-year pause due to the COVID-19 pandemic, the Consumer Financial Protection Bureau (CFPB) published an Issue Spotlight on student borrowers’ experiences, using consumer...more
With the onset of the COVID-19 pandemic, Congress initiated several programs to help businesses weather the difficult economic conditions. The Coronavirus Aid, Relief, and Economic Security (CARES) Act provided two of these...more
On November 1, the OCC issued Bulletin 2023-34 addressing the topic of “venture lending,” referred to as “commercial loans to early-, expansion-, and late-stage companies.” According to the Bulletin, venture lending is often...more
Today’s high interest rate environment presents a challenge to many commercial real estate borrowers whose loans are now reaching maturity. Some borrowers are unable to repay their loans, while others are approaching the loan...more
The Federal Housing Administration recently issued Mortgagee Letter 2022-23, establishing a new COVID-19 Home Equity Conversion Mortgage Property Charge Repayment Plan. The COVID-19 HECM Property Charge Repayment Plan would...more
1. Make sure you have what you need from the start - Take advantage of all information needed to collect at the time the loan is made or the services are provided, including obtaining a security interest in collateral....more
In last week’s edition of FFF, we discussed the Revlon case involving an erroneous payment by an administrative agent to the syndicate lenders, which is currently up on appeal before the Second Circuit Court of Appeals....more
On March 23, 2021, the CFPB issued a brief statement highlighting its position regarding “consumer harms in the small dollar lending market” and likely future action to reverse the previous CFPB administration’s policy...more
In a series of FAQs issued last spring, the Small Business Administration (SBA) made clear that it would review the certification made by Paycheck Protection Program (PPP) borrowers of $2 million or more that “[c]urrent...more
On October 8, 2020, the Centers for Medicare & Medicaid Services (CMS) announced notable changes to the terms of Accelerated and Advance Payment Program (AAPP) loans that were issued to various health care entities earlier...more
Part of the 2020 Business Solutions Series presented by by the Hampton Roads Alliance and Williams Mullen Charles E. “Chuck” James, Jr., co-chair of both the Firearms Industry Group and the White Collar & Investigations...more
The current situation is fast-moving. The information below reflects our understanding of payment moratoria measures and other reliefs related to the COVID-19 pandemic as at 9 June 2020. In many cases the legislation,...more
Since the enactment of the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) on March 27, 2020, the U.S. Small Business Administration (the “SBA”) and the U.S Treasury Department (“Treasury”) have issued a...more
One long week after the U.S. Treasury announced that it was extending the Paycheck Protection Program Loan “safe harbor” deadline to May 14, the U.S. Treasury announced this morning that borrowers whose loan amount (combined...more
UPDATED May 14, 2020 – On May 13, 2020, the U.S. Treasury Department announced an additional automatic extension of the Safe Harbor deadline from May 14, 2020 to May 18, 2020. May 13, 2020 – The rules and ground shifted...more
PPP Loan Forgiveness is Criticized, Guidance is Forthcoming - Audits of PPP Loans in Excess of $2 Million - On April 28, 2020, U.S. Secretary of Treasury Steven Mnuchin announced that all Paycheck Protection Program...more