ARTICLE
19 May 2021

FRB Extends PPP Exception For Bank Insiders

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 Federal Reserve Board adopted an interim final rule to further extend an exception for Paycheck Protection Program loans and second draw PPP loans filed from March 31, 2021 through March 31, 2022 under ...
United States Finance and Banking

The Federal Reserve Board adopted an interim final rule to further extend an exception for Paycheck Protection Program ("PPP") loans and second draw PPP loans filed from March 31, 2021 through March 31, 2022 under FRB Regulation O ("Loans to Executive Officers, Directors, and Principal Shareholders of Member Banks"). The FRB issued the exception to allow bank executive officers, directors and principal shareholders to apply for PPP loans from related bank affiliates on behalf of the small businesses they own. The FRB has twice extended this exception.

The FRB's action, as applied to PPP loans, was deemed to "pose minimal risk to bank safety and soundness" under Federal Reserve Act Section 375b(9)(D)(ii) ("Exceptions").

The interim final rule goes into effect upon its publication in the Federal Register and comments on the rule must be submitted within 45 days of its publication in the Federal Register.

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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