April 14, 2020

AILA Members and Friends:

I report to you that some of the lenders to the consumer finance industry have taken a hard, second look at the Paycheck Protection Program. Recall that there has been concern that since finance companies have historically been ineligible under the Small Business Act Section 7(a) loan program, that such ineligibility continued under the Paycheck Protection Program. Based on the subsequent “guidance” offered by the Small Business Administration however, these lenders have satisfied themselves that the Program permits consumer finance companies to receive Program funds under the massive stimulus CARES Act.

Since there remains concern as to the clarity of this position, some lenders may only be accepting applications from their existing customer base. If your lender is still reticent about processing your application, I will be pleased to discuss the SBA Guidance with it.


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