The Treasury Department and Small Business Administration confirmed that Paycheck Protection Program lenders may accept scanned copies of loan applications, PPP promissory notes and other closing documents, and other forms of consent permitted by the E-sign Act.
In updates to their frequently asked questions on the PPP, the agencies said lenders should take appropriate steps to ensure the proper party has executed the document if wet signatures are used without in-person contact.
The latest updates follow the release earlier this week of an interim final rule answering key PPP questions relating to bank directors, partnerships, self-employed borrowers, and more. Other recent updates to the agencies' PPP FAQs clarify that lenders must collect the information and certifications contained in the borrower application form and fulfill their obligations under the PPP final rule before submitting a PPP loan application.
ICBA continues updating its frequently asked questions on the PPP and other elements of the federal response to the COVID-19 outbreak. More information from the agencies is available on the SBA's PPP landing page.