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How does the Federal Reserve's Regulation O impact the availability of SBA PPP loans for bank directors and shareholders?

On April 17, 2020, the Federal Reserve issued an interim final rule that excepts certain loans that are guaranteed under the SBA PPP from the requirements of section 22(h) of the Federal Reserve Act and the corresponding provisions of Regulation O. The change temporarily modifies the Federal Reserve's rules so that certain bank directors and shareholders can apply for PPP loans for their small businesses. However, section 22(g) of the Federal Reserve Act and section 215.5 of Regulation O still apply. The SBA explicitly has prohibited banks from favoring in processing time or prioritization of a PPP loan application from a director or equity holder.

Federal Reserve Board announces rule change to bolster the effectiveness of the Small Business Administration's Paycheck Protection Program