Risk Management Around PPP Loans


  • Who did you lend to? If you limited to current customers, have you prepared a good business justification?
  • How did you prioritize application processing?
  • Did you require/recommend that applicants open a checking account as a condition of their PPP application?
  • Have you reviewed your applicants and approved borrowers for potential fair lending, CRA, or other issues?
  • If you had borrowers that did not qualify for PPP, did you offer them other forms of credit? If so, what type?
  • Did you comply with all SBA requirements to retain guaranty?
    • Fund within 10 days?
    • Ever changing eligibility requirements?
    • Accurate determination of correct maximum loan size?
    • BSA/AML?
  • What will the review fallout be? Are there FCA issues coming down the pike? Will lenders be liable for borrower fraud?
  • How will you manage forgiveness and servicing?


Bill Dudley, Former President, Federal Reserve Bank of New York and Current Member of Treliant’s Board of Directors

Jeff Jaffee, Former Head of Regulatory Affairs

Ellen Rose, Senior Director, Mortgage Operations & Compliance, Treliant

Tina Shaver, Former Treliant

Lynn Woosley, Former Treliant