Aftermath of PPP Lending: Lender Compliance, Risk and Enforcement
Lending through the Paycheck Protection Program (“PPP”) ended on May 31, 2021. In just over a year, nearly 5,500 lenders made almost 12 million loans totaling $8 billion through two rounds of PPP lending. While lenders pivot to the forgiveness process of the PPP, Congress, regulators and enforcement agencies have been actively investigating the extent to which fraudulent borrowers exploited the PPP and how disadvantaged borrowers failed to benefit from it.
In this webinar, we will provide an overview of the PPP, discuss compliance challenges lenders face in both its prior lending decisions and ongoing forgiveness framework, as well as current and future trends that have emerged. Key topics include:
- Enforcement Activity and Lender Cooperation with investigations related to lender’s PPP lending decisions and examinations of the compliance program
- Fair Lending Concerns and whether efforts to mitigate the risk of fraudulent borrowing resulted in discriminatory lending
- BSA/AML Compliance Impact and the expectations to incorporate PPP lending risks into existing AML program and anti-fraud controls
- Fraud Red Flag and the types of fraud that can be associated with loan origination, forgiveness requests and forgiveness validation activities
- Best Practices to mitigate risk for bank and non-bank FinTech lenders.
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