SBA Releases New Procedure for SBA Loan Review of Partial Approval Foregiveness Decisions (1.31.2022)
On January 28, SBA released Procedural Notice 5000-827666 regarding SBA loan reviews of PPP Lender partial approval forgiveness decisions. The notice outlines a new process to allow PPP Borrowers to request an SBA loan review of partial approval forgiveness decisions issued by their PPP Lenders. The procedures in the notice apply to loan forgiveness decisions submitted by Lenders to SBA through both the regular forgiveness process as well as the Direct Borrower Forgiveness process. The notice is effective January 27, 2022. Click here to read more.
Paycheck Protection Program Forms: (8.16.2021)
Forms 3508, 3508S & 3508EZ have been updated: Expiration date changed from 9/30/2021 to 1/31/2022
A new round of SBA Paycheck Protection Program (PPP) availability has re-opened today and there has been a flurry of information released by SBA regarding the program.
SBA Portal Live (1.11.2021)
SBA has announced that the PPP portal is open as of today, January 11th, for new borrowers and certain existing PPP borrowers. To promote access to capital, initially only community financial institutions will be able to make First Draw PPP Loans on Mon., Jan. 11 and Second Draw PPP Loans on Wed., Jan. 13.
Per the Economic Aid Act, a Community Financial Institution (CFI) is one of the four types of lenders:
The PPP portal will open to all participating lenders shortly thereafter. Updated PPP guidance outlining program changes to enhance its effectiveness and accessibility was released on Jan. 6 in accordance with the Economic Aid to Hard-Hit Small Businesses, Non-Profits, and Venues Act.
SBA PPP Application Forms
Form 2483 – First Draw Borrower Application (updated 1/8/2021)
Form 2484 – First Draw Lender Guaranty Application (updated 1/8/2021)
Form 2483-SD – Second Draw Borrower Application (released 1/8/2021)
Form 2484-SD – Second Draw Lender Guaranty Application (released 1/8/2021)
Due to changes in law, SBA is currently revising its Forgiveness Applications. The forms will be made available by SBA within ten days. FIPCO will make those forms available as soon as possible.
Quick Links to articles below:
Deferral Agreement Forms
eSignature powered by DocuSign
Loan Processing Central Services
Office Depot offering workplace safety products
Paycheck Protection Program
Services and Support Continue to be Available
Paycheck Protection Program Note Modification and Instructions (9.18.2020)
The form was created to assist lenders with changes that need to be made to existing PPP loans in light of the passage of the Paycheck Protection Program Flexibility Act (PPPFA) effective June 5, 2020. The PPPFA changed the deferral of principal and interest payments from 6 months to a future date in time when the SBA remits to the Lender the amount of forgiveness of the Note under section 1106 of the CARES Act.
Office Depot - Sanitizing Dispensers and Entry Scanner (8.12.2020)
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- Verification of individual, even when mask is worn
- Alarm when out of range measurement is identified
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Engagement Center Guidelines (6.17.2020)
WBA and FIPCO want to make your visit to our office as safe as possible. Click here to see the steps we are taking in our newly remodeled Engagement Center and Computer Training Rooms.
FA$TRAK Borrower Information Form (6.8.2020)
FIPCO and the WBA legal team have developed a Paycheck Protection Program calculator, the FA$TRAK Borrower Information Form, to help lenders provide their customers with information and to aid borrowers with calculations related to the forgiveness phase of the PPP program. The information and calculations in the calculator are current as of June 5, 2020.
Disclaimer: The FA$TRAK Borrower Information Form has been created from instruction released by Treasury and/or SBA and without regard to the changes made to the program by the recently enacted PPP Flexibility Act. As has been the case since the program’s inception, there continues to be evolving and new guidance along with rulemakings issued by Treasury and/or SBA that further instructs borrowers and lenders working the PPP application and forgiveness applications. WBA/FIPCO will update the calculator once additional instruction is released by Treasury and/or SBA regarding the form and calculations. Click here to download the FA$TRAK Borrower Information Form
Calculating Debt Forgiveness For PPP Loans (6.8.2020)
Now it is time to calculate debt forgiveness for those SBA PPP loans. FIPCO’s experienced ShareFI staff will help your financial institution track and analyze a customer’s potential for debt forgiveness. To learn more about how this service can help you help your customers, please contact FIPCO ShareFI’s Geri Henningfield or call her at 608-441-1248.
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Update to 4/3/2020 SBA's Paycheck Protection Program Use in Compliance Concierge (4.7.2020)
With the ever-changing environment we are all in, FIPCO is providing more information on SBA PPP and updated example information on the Loan Program within Compliance Concierge.
It is FIPCO’s understanding as of yesterday, that the WBA 451 Unsecured Business Note can be used for SBA’s Payment Protection Program. Communications continue with SBA and if this changes we will let you know.
The following language should be included in the notes. This has not changed from the 4/3/2020 notice.
“When SBA is the holder, this Note will be interpreted and enforced under Federal law, including SBA regulations. Lender or SBA may use state or local procedures for filing papers, recording documents, giving notice, foreclosing liens, and other purposes. By using such procedures, SBA does not waive any Federal immunity from state or local control, penalty, tax, or liability. As to this Note, Borrower may not claim or assert against SBA any local or state law to deny any obligation, defeat any claim of SBA, or preempt Federal law.”
To setup a Loan Program for the SBA program within Compliance Concierge, go to Concierge Support - Software Updates & Notices - Notices on the FIPCO website.
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Paycheck Protection Program Application Form (4.3.2020)
The Treasury has posted final, updated documents that you will need as you start to take applications for the Paycheck Protection Program, starting today April 3.
The borrower application form is updated from prior published versions, and the Lender Electronic Data Form is new. Both forms are available as fillable pdfs on our website.
For a top-line overview of the program, click HERE
Lenders, more information can be found HERE. You may direct your borrowers HERE for more information.
The application for borrowers can be found HERE, or can be found as a fillable Blank Form on www.fipco.com.
The Lender Electronic Data Form can be found HERE, or can be found as a fillable Blank Form on www.fipco.com.
To access the interim final rule to the Paycheck Protection Program, click HERE
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FIPCO’s COVID-19 Response (3.25.2020)
There is nothing more important to FIPCO than the health and well-being of you and our employees. In light of the continued spread of the novel coronavirus (COVID-19), we wanted to assure you that FIPCO is well-prepared to take any measures necessary to ensure the safety of all who work and conduct their business with us.
At present, all FIPCO team members are working remotely. We are utilizing our online and remote collaboration capabilities for our employees to communicate with each other, you, and our vendors.
All FIPCO services and supports continue to be available.
Our support hours remain unchanged, and you can continue to reach us via 800-722-3498 and any of our support emails: firstname.lastname@example.org, email@example.com, firstname.lastname@example.org and email@example.com
Our Information Security, IT Audit and ShareFI Compliance consulting services continue to be available through remote communications. Should you need their assistance during COVID-19, please contact Rob Foxx, Director of Infosecurity and IT Audit or Jeff Schmid, Director of ShareFI Compliance and Management services. Like our software and forms support teams, they are just a quick phone call or email away and are happy to answer any questions you may have.
We know you are extremely busy taking care of your customers, your teams, and your families. We want to assure you that we will continue to support you. Keeping you connected is always, especially in this time of need, our top priority. We will continue to closely monitor developments and follow protocols set forth by local and national agencies/authorities, and will communicate to you any changes from our normal course of business.
Thank you for your ongoing support. We appreciate your confidence in FIPCO. We are here to help however we can!
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Suddenly, Remote Work Is a Necessity, Not an Experiment (3.24.2020)
FIPCO helps banks serve their customers, communities
As efforts to slow the spread of the coronavirus force businesses across the world to shift to remote work, the highly regulated banking industry must grapple with unique challenges. Sending and signing confidential documents securely, adjusting loan agreements, processing loans with a distributed workforce...
WBA and its wholly owned subsidiary FIPCO are here to help. See the list of solutions below, discounted or complimentary through May 31, to assist banks during these unprecedented times.
Forms, Services and Support Solutions Available:
Deferral Agreement Forms — The tried and trusted WBA form set includes three deferral agreements available to all WBA member institutions through FIPCO. The federal banking regulators have issued guidance encouraging banks to work with customers and clients affected by the COVID-19 pandemic and efforts to slow its spread. The deferral agreements are available for consumer, commercial, and agricultural business loan transactions and can be purchased in hardcopy or as fillable PDFs. The forms were created for use with existing loan agreements between the lender and the customer for deferral of loan payments under an existing loan arrangement. The form provides that one or more installments can be deferred for the number of months agreed to by the lender and noted in the Payment Deferral Agreement. The maturity date would be extended by the number of months that payments were deferred.
The agreements available are:
Note: With regard to a Wisconsin Consumer Act (WCA) covered loan, users cannot charge a deferral fee on a simple interest WCA loan (see applicable DFI letter of when a deferral fee may be charged)
Contact firstname.lastname@example.org for additional information.
Loan Processing Central Services — FIPCO’s Loan Processing Services may be the answer to assist you with the influx of loan requests and/or staffing changes or shortages. From March 19, 2020 through May 30, 2020 FIPCO is offering our Loan Processing solution to Compliance Concierge Loan and Mortgage and we are waiving the upfront annual fee during this time frame. All you would be responsible for are the per transaction processing fees based on the loan types.
If you are happy with our LPC services and would like to continue using this service past May 30, 2020, FIPCO will offer a one-time savings of 50% on the upfront annual fee. If you no longer wish to use this service, simply say so.
FastApp — If you are looking for an online presence, FIPCO’s FastApp Online may be the answer! From March 19, 2020 through May 30, 2020 FIPCO is offering our FastApp Online solution AND our interface to Compliance Concierge at no charge. The only cost to you would be the $20 per app fee during this time frame and FIPCO would invoice you monthly.
If you are happy with this solution and would like to continue past May 30, 2020, FIPCO will offer a savings of 50% on the License Fee and Installation Fee. If you no longer wish to use this FastApp Online, simply say so.
For FIPCO’s Compliance Concierge™ customers:
eSignature powered by DocuSign — eSignature powered by DocuSign may be the answer to assist you with remote loan closings. From March 19, 2020 through May 30, 2020 FIPCO is offering our eSignature powered by DocuSign solution to Compliance Concierge at no charge.
If you are happy with this solution and would like to continue past May 30, 2020, FIPCO will offer a savings of 50% on the upfront License Fee. If you no longer wish to use eSignature powered by DocuSign, simply say so.
Modification Agreements— Compliance Concierge customers have access to four different modification agreements for use when working with their clients:
463F Mortgage Note Modification Agreement (Fixed Rate)
463VAR Mortgage Note Modification Agreement (Variable Rate)
464F Modification Agreement (Fixed Rate) (Commercial/Ag)
464VAR Modification Agreement (Variable Rate) (Commercial/Ag)
FIPCO customers interested in accessing these forms should contact Software Support at 800-722-3498 or email@example.com for detailed instructions.
If your bank is interested in any of these solutions, please contact firstname.lastname@example.org for more information about implementation.
Don’t forget to visit WBA’s Coronavirus Resource Center at www.wisbank.com/coronavirus for updated information and resources related to the COVID-19 pandemic.
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