ARTICLE
22 July 2020

Federal Reserve Extends PPP Exception For Certain Loans To Bank Officers, Directors And Shareholders

CW
Cadwalader, Wickersham & Taft LLP

Contributor

Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The exception allows bank executive officers, directors and principal shareholders to apply for PPP loans from related bank affiliates on behalf of small businesses they own.
United States Finance and Banking

The Federal Reserve Board ("FRB") adopted an interim final rule to extend an exception that modified Federal Reserve Act Section 22 and FRB Regulation O ("Loans to Executive Officers, Directors and Principal Shareholders of Member Banks"). The exception allows bank executive officers, directors and principal shareholders to apply for PPP loans from related bank affiliates on behalf of small businesses they own.

The exception initially applied only to PPP loans made by June 30, 2020; this interim final rule - which is immediately effective - expands the exception to loans filed through August 8, 2020. Comments may be submitted until August 31, 2020.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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