REGULATION O MODIFIED FOR PPP LOANS

On April 17 the Federal Reserve Board published an interim final rule that excludes loans that are guaranteed under the Small Business Administration’s Paycheck Protection Program (PPP) from many of the requirements of Regulation O. The rule is effective upon publication in the Federal Register, which is expected soon. The comment period expires 45 days after publication in the Federal Register.

The final rule excludes from all requirements of Regulation O, except for the executive officer limits contained in section 215.5, a loan:

  • In which the participation by the Small Business Administration on a deferred basis is 100 percent pursuant to section 1102(a)(1) of Pub. L. 116-136 (to be codified at 15 U.S.C. 636(a)(2)(F));
  • That is made during the period beginning on February 15, 2020, and ending on June 30, 2020; and
  • That would not be prohibited by paragraph 120.110(o) of Title 13 or rules or interpretations thereof issued by the Small Business Administration.

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