On April 27, 2020, the OCC issued a bulletin (2020-45) to clarify and rescind its prior statement in Bulletin 2020-44, which was issued on April 25, 2020. The revised bulletin encourages banks providing loans under the SBA PPP to prudently document their implementation and lending decisions. Additionally, the bulletin further encourages banks to identify and track the PPP loans made to small business borrowers that have annual revenues of $1 million or less and are located in low- to moderate-income (LMI) areas.

The revised bulletin (2020-45) can be found here.

The now rescinded bulletin (2020-44) can be found here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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