Saul Ewing Arnstein & Lehr’s COVID-19 Weekly Digest

Below please find League Business Leaders Network member Saul Ewing Arnstein & Lehr’s COVID-19 weekly digest, which includes our analysis of the most current legal developments related to this pandemic. To receive regular updates, news and information related to COVID-19, please register here.

COVID-19 Updates

  • Additional PPP Guidance
    During this past week, the U.S. Small Business Administration (the SBA) has released a number of new or amended rules (the Rules) providing additional guidance on the Paycheck Protection Program (PPP) in light of the changes made by the Paycheck Protection Program Flexibility Act of 2020 (the Flexibility Act), which was signed into law on June 5, 2020. Our previous alert on the Flexibility Act can be found here. Additionally, the SBA has released new PPP loan forgiveness applications and instructions. Below are highlights of the additional guidance provided by the SBA.
  • The “Main Street Lending Program” for Small and Mid-Size Businesses Launches
    The Federal Reserve Board (“FRB”) announced on June 15, 2020 the launch of its Main Street Lending Program (the “Lending Program”) for small and mid-size businesses. Registration for lenders opened on June 15th and the FRB encouraged lenders to begin making loans under the Lending Program immediately. Lenders that wish to participate in the Lending Program can register through an online portal on the FRB’s website.
  • Bank Secrecy Act and Anti-Money-Laundering Compliance in the COVID-19 Era: How Financial Institutions Can Manage Increased Risk From Stimulus and PPP Payments
    The CARES Act pumped over two trillion dollars into the American economy, with much of that money going directly to individuals in the form of stimulus checks or to small businesses in the form of Paycheck Protection Program (“PPP”) loans. Many of those recipients will spend that money lawfully in any number of ways. Yet, as many recently announced prosecutions make clear, the stimulus and PPP injections have increased the opportunities for fraud. In turn, compliance risks are heightened for financial institutions—particularly Bank Secrecy Act and Anti-Money-Laundering (“BSA/AML”) risks.[1] In this article, we draw upon our experience in the federal government as well as in private practice to offer practical compliance guidance for financial institutions