Removing Barriers Blog

Posted May 07, 2020 by CUNA Advocacy

The CFPB issued clarifying frequently asked questions (FAQs) related to Equal Credit Opportunity Act (ECOA) compliance for Small Business Administration’s (SBA) Paycheck Protection Program (PPP) loans. 

Under ECOA, creditors are generally required to notify applicants within 30 days of receiving a “completed application” of the creditor’s approval, counteroffer, denial or other adverse notice regarding the application. 

The Bureau’s FAQs clarify that a PPP application is only a “completed application” once the creditor has received a loan number from the SBA or a response about the availability of funds. 

The FAQs also state that if the creditor denies an application without ever sending the application to the SBA, the creditor must give notice of this adverse action within 30 days. It further clarifies that a creditor cannot deny a loan application based on incompleteness where the creditor has enough information for a credit decision but has yet to receive a loan number or response about the availability of funds from the SBA.