Hilltop Advisors’ PPP review team is prepared to help your Bank with any/all aspects of the Application process (to augment your team or complete separate assignments). There are only a small number of processed Payroll Protection Program (PPP) Forgiveness Applications across the country at this time. Banks are still testing their PPP technology apps, identifying qualified resources to perform the Application review, addressing the exposure to lawsuits, etc. Further, lenders are concerned about the SBA regulations for PPP, the potential fraud risks and the borrower’s ability to payback any remaining balance of the PPP loan.
For the Bank to successfully receive and review the Application, provide borrower assistance as needed and submit the PPP Application to SBA for their review and approval – we have identified additional tasks and who should perform such to meet SBA’s expectations. Most review teams are focused on the Application content, borrower certifications and supporting documents. Your Bank should also be prepared to perform the following tasks which include, but are not limited to, the following:
- planning and staffing for “surges” in the number and/or difficulty of the Applications submitted requires adding qualified resources on short notice (given the risk of not submitting to the SBA timely),
- performing a QC review (sampling processed applications to ensure they are compliant with SBA – the SBA is expecting banks to have a QC function separate from the team processing the Applications – as part of the typical “three lines of defense” to meet internal controls),
- providing assistance in communications with borrowers and/or researching topics given borrower questions,
- providing a second opinion on a disputed Application,
- providing Internal Audit assistance if IA is going to audit the PPP area, and
- helping when the SBA challenges the Bank’s decision on the amount of the forgiveness.
Our PPP team has the necessary SBA knowledge/experience, accounting, payroll and tax resources that most other firms do not have. As a PPP borrower and a PPP reviewer, Hilltop understands the lender and borrower perspectives of the PPP program.
We would like to discuss how your PPP efforts are going and how we may help you with any of the steps in the review process. Let us know if the Bank has determined that additional resources are needed as we can quickly deploy a team that will scope the effort.
