Third Quarter Recovery, Revised PPP Guidance and Madden Clarification

In this week’s PeerIQ Industry Update they cover the leveling off of forbearances, the impact of stimulus funds on the economy, revised PPP loan guidance and Madden-Midland clarification; according to the Mortgage Bankers Association mortgage forbearance levels have steadied at 8 percent, there was an early indication they could rise to 30 percent; the stimulus funds have helped many Americans weather the crisis and a third quarter recovery is not out of the question; the SBA issued new guidance on PPP loans which says they will repay lenders 90 days after eligible loans were forgiven the House passed a bill reducing payroll requirements to 60 percent and use of funds to 24 weeks; as his first act in office new OCC head Brian Brooks finalized Madden-Midland, “Today, as one of my first acts as Acting Comptroller of the Currency, I signed a final rule to protect Lincoln’s vision and to clarify that a bank may transfer a loan without affecting the legally permissible interest term. The rule supports the orderly function of markets and promotes the availability of credit by answering the legal uncertainty created by the “Madden” decision.” PeerIQ

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