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#2234417 - 04/08/20 03:26 PM PPP Application Doesn't Qualify - AAN
Compliance Poster Offline
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Joined: Sep 2001
Posts: 397
If we deny a PPP application because it doesn't qualify under the PPP, do we send a denial notice?

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#2234425 - 04/08/20 04:26 PM Re: PPP Application Doesn't Qualify - AAN Compliance Poster
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,710
Bloomington, IN
These are business credit requests. I don't see them being exempt from 1002.9(3)
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2234935 - 04/16/20 01:28 PM Re: PPP Application Doesn't Qualify - AAN Compliance Poster
Ms. X Offline
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Joined: Jan 2018
Posts: 24
If applicant does not meet the eligibility requirements, can we state the reason as "Does not meet eligibility requirements of the Paycheck Protection Program" or do we need to be more specific? Thanks!

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#2234984 - 04/16/20 05:13 PM Re: PPP Application Doesn't Qualify - AAN Compliance Poster
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
You need to be specific and say why they don't meet the requirements.
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David Dickinson
http://www.bankerscompliance.com

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#2234988 - 04/16/20 05:19 PM Re: PPP Application Doesn't Qualify - AAN Compliance Poster
Ms. X Offline
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Joined: Jan 2018
Posts: 24
Thanks!

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#2235249 - 04/20/20 03:50 PM Re: PPP Application Doesn't Qualify - AAN Compliance Poster
Christy Campbell Offline
Junior Member
Joined: Apr 2020
Posts: 32
We have a business who submitted an application but pays all workers on 1099 so technically, no employees. Based on this they don't meet the requirements for the PPP loan program. We need to take adverse action but what specific denial reason would we put on the AAN.

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#2235281 - 04/20/20 07:45 PM Re: PPP Application Doesn't Qualify - AAN Compliance Poster
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
The PPP can be used for more than payroll. It also can be used for rent, utilities & mortgage interest.
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David Dickinson
http://www.bankerscompliance.com

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#2235531 - 04/23/20 05:23 PM Re: PPP Application Doesn't Qualify - AAN Compliance Poster
Jan94 Offline
Platinum Poster
Joined: Mar 2001
Posts: 828
USA
If the ineligibility is not related to underwriting, but for example, the applicant was a company that was determined could not apply to the SBA, would that still be a scenario for a NOA? The line of business is disagreeing that they need a NOA since they did send an e-mail to the customer telling them they "could not verify" their information. Thank you.

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