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CBA Letter to SBA & Treasury on PPP Funds
The Honorable Steven T. Mnuchin
U.S Department of Treasury
1500 Pennsylvania Avenue, NW
Washington, D.C. 20220
The Honorable Jovita Carranza
Small Business Administration
409 Third Street, SW
Washington, D.C. 20416
Dear Secretary Mnuchin and Administrator Carranza
I write to you regarding the “Paycheck Protection Program and Health Care Enhancement Act’’ that was recently signed by the President that provides much needed funding for SBA’s Paycheck Protection Program (PPP or program). The highly successful program has been welcomed by small businesses across the country and considered a lifeline for the millions of men and women who work at them. Due to high demand, the PPP funds were depleted quickly with many businesses unable to get loans approved. Lenders currently have large numbers of completed applications for businesses sitting on their desk awaiting PPP funds to be restored. Lenders stand ready to enter these applications into ETRAN for the quickest approval by SBA and subsequent funding by the lender.
The new law sets aside $30B in PPP funds to be used for lenders between $50B and $10B in assets and another $30B for lenders under $10B in assets. These amounts are in addition to the $250B that is approved for use for all lenders. The new $60B in funds provided to institutions based solely on asset size should be utilized first before those lenders are able to access the general funding pool of $250 billion. Requiring lenders who have their own set aside funding stream to deplete those funds first, before accessing the larger pool, will ensure fairness to the thousands of small businesses who have been patiently waiting for PPP assistance and remove any competitive advantage that may inadvertently be created if a lender is permitted to access dual funding streams.
Every effort should be expended to prevent a circumstance where a small business — who has submitted an application, provided the appropriate documentation to their lender, and is awaiting approval by the SBA — faces a situation where they would be required to restart the PPP process with a different lender because the institution they originally chose to work with has PPP funds depleted by other lenders who have access to their own funding source. Ensuring lenders deplete the set aside funds for their predetermined asset class first will minimize a situation where borrowers, who may be at the end of a queue for the program, are once again faced with the reality of limited funds.
President and CEO
Consumer Bankers Association