Page 8 - Bulletin 05_14_20
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        liquidity needs. This action by the agencies effectively exempts   SBA Offers Clarity for PPP
        MMLF or PPPLF funding from the LCR calculation. The rule   Borrowers Attempting to Rehire
        takes effect immediately, and the agencies will accept comments
        for 30 days after publication in the Federal Register.   Employees
        To read the rulevisit:  The SBA and the Treasury confirmed
        pressreleases/files/bcreg20200505a1.pdf                 that Paycheck Protection Program
                                                                borrowers who attempt to rehire
        IRS Releases Coronavirus-Related                        employees that were laid off will not
        FAQs Affecting Retirement Plans                         have their loan forgiveness amounts
                                                                reduced if those employees decline the
        and IRAs                                                offer to return to work.

        The IRS has released a set of frequently asked questions on   In updates to the PPP FAQs, SBA and
        Section 2202 of the CARES Act, which allows for penalty-free   Treasury said they would issue an interim final rule codifying that
        coronavirus-related distributions up to $100,000 from eligible   a borrower must have documented that they made a good faith,
        retirement plans (including 401(k) and 403(b) plans and IRAs) to   written offer of rehire to the employee for the same wages and
        qualified individuals.                                  number of hours. Borrowers must also document the employee’s
                                                                rejection of the offer.
        The FAQs address how these distributions should be reported
        by retirement plan and IRA custodians and trustees. They also   In addition, the updated FAQs provide clarification about
        indicate that the IRS will be issuing more detailed guidance soon,   the treatment of nonprofit hospitals under the CARES Act. A
        and that it will follow the same principles as related guidance   nonprofit hospital may qualify for PPP funding if it “reasonably
        issued following Hurricane Katrina.                     determines” and maintains documentation that it meets the
                                                                criteria of a 501(c)(3) under the Internal Revenue Code and is
        To view the FAQs, visit:
        coronavirus-related-relief-for-retirement-plans-and-iras-questions-  therefore tax exempt under section 501(a), SBA and Treasury
        and-answers                                             noted. They added that these entities should also review all other
                                                                applicable eligibility criteria.

                                                                The FAQs also provide additional guidance for seasonal
                                                                employers making borrower certifications to obtain PPP funding.

                                                                To view the updated FAQs, visit:

                                                                Fed Survey: Coronavirus
                                                                Pandemic Weakens Demand for
                                                                CRE, Consumer Debt

                                                                Demand for commercial and
                                                                industrial loans was mixed in the first
                                                                quarter, as the COVID-19 outbreak
                                                                was beginning to strike the U.S.
                                                                economy, according to the Federal
                                                                Reserve’s latest survey of senior loan
                                                                officers. Many businesses sought
                                                                to bulk up on cash or replace lost
                                                                revenue, while others dropped plans
                                                                to take on debt for capital investment. Meanwhile, commercial
                                                                real estate and consumer debt demand fell, and low rates drove
                                                                higher demand for mortgage loans.
                                                                C&I. As the overall economy and specific industries’ conditions
                                                                worsened, on net, roughly four in 10 banks reported tightening

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