Hilltop Advisors has the accounting and PPP personnel to help lenders face financial, regulatory and possible reputational risks related to the PPP loan forgiveness reviews. Banks should expect SBA scrutiny, borrowers that are likely to dispute the banks’ decision on the borrower’s Application for Forgiveness (Application) and the threat of potential litigation. The PPP Flexibility Act has increased the borrower’s forgiveness options, extended deadlines and established expectations that there will be less scrutiny of loans equal or lower than $150,000. If a borrower does not qualify for all or a substantial part of their PPP loan to be forgiven, borrowers will complain to the Bank and raise issues with the SBA. It is critical that the Bank handle the Application very carefully, apply the appropriate level of review and respond to inquiries acknowledging that the launch of the PPP effort was done in a very short period of time.
Hilltop understands the PPP issues and concerns (as a lender and borrower) and the need for skilled financial or accounting resources to review the Application. Our PPP Loan team has designed a review process that handles the anticipated challenges and issues with the Application. Our process will include any or all of the following efforts to assist the Bank:
- planning the approach with the Bank to ensure that Hilltop’s team understands how the loan approval was completed,
- discussing the policies, processes and technology apps to be used for the Application review,
- presenting Hilltop’s recommendations as to how the Bank should conduct its Application reviews,
- finalizing the steps that the Bank wants to be taken for each Application review,
- creating/using a customized risk-based review process which Hilltop created,
- identifying the different levels of complexity and borrowers (higher risk borrowers) that do not understand all of the technical requirements of the Program (especially if they don’t engage their accountant/tax professionals to assist with the Application),
- staffing the review team (Hilltop can provide the entire review team, augment the Bank’s team and/or provide staff for specific components of the review such as planning and quality control efforts),
- assigning the right skills/experience to the review project (this type of review requires experienced accountants, payroll processors, and/or tax accountants),
- including a borrower contact team that will be staffed to handle borrower questions, communicate the Forgiveness decision if it’s not 100% of the loan amount and carefully explain the Team’s rationale for its final forgiveness decision.
- handling riskier loans and those with significant decreases in the borrower’s Application for Forgiveness will be assigned to those highly experienced professionals that know the SBA required documentation, and
- providing “best practice” recommendations.
Our team has been trained, we have a large group of bank and accounting professionals that can help. Hilltop can either lead or augment the staff assigned to the Application process. If you want to discuss how Hilltop may be able to help your Bank – please email/call Jeff Oliver, CEO. Our website is www.thehilltopcompanies.com.
Hilltop Advisors LLC
Transforming organizations through skillful alignment of vision, people, process and technology solutions.
Geoffrey A. Oliver
Chief Executive Officer
gaoliver@thehilltopcompanies.com
O: 703-356-3350 x201
C: 703-801-1921
Tim McDaniel, CPA
Director
tmcdaniel@thehilltopcompanies.com
O: 571-565-3245
