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7 North Bay experts explain the new small-business loans for coronavirus lockdown relief

Congress earlier this month approved $660 billion in payroll protection program loans and economic injury disaster loans through the U.S. Small Business Administration to help entrepreneurs and their employees survive the economic lockdowns since mid-March to slow the coronavirus pandemic.

North Bay Business asked several lenders that handle a lot of SBA-backed lending to local operations the best ways to tap these new sources of help in this crisis. The following are their responses.

Kristina Becker

Vice President, small business banking for North Bay

Bank of America

10 Santa Rosa Ave., Santa Rosa

707-260-9284

kristina.becker@bofa.com

Years worked in the banking business: 9

Years at your present position: 9

Significant news at your company in the past year:

Bank of America is once again the nation's top SBA lender, and we have been hiring business bankers locally as well as for other roles at the bank. Bank of America is regularly recognized as a great place to work, and since the onset of the health and humanitarian crisis created by the coronavirus, the bank announced there will be no virus-related layoffs and is providing additional pay to workers deemed essential such as our branch financial center staff.

The bank also committed $100 million to help local community nonprofits helping the most vulnerable populations.

Here in the North Bay, we are allocating some of this philanthropic capital to local nonprofits addressing medical, hunger, shelter and educational needs created by the virus.

What has been the direct impact of the coronavirus on your level of activity?

In times like this, our clients rely more than ever on our advice, services and support. As a top small business bank, we will do all we can to help local businesses and the nation get through this crisis.

From the outset, we have made more than a half million proactive calls to small business clients and reached out by email to millions more to offer support.

Our enhanced Client Assistance Program helps clients who are financially impacted by the coronavirus by waiving certain fees and deferring payments on small business loans and credit cards in addition to mortgages, auto loans and consumer credit card payments.

We have also paused foreclosure sales, evictions and repossessions. In just a few weeks, more than 700,000 clients have deferred loan payments and waived fees. Bank of America was also the first major bank accepting Paycheck Protection Program loans online, receiving more than 335,000 applications totaling about $45 billion in loans so far.

What are the most common top five questions being asked of you by those who hold SBA loans?

There are a lot of questions around the CARES Act (the Coronavirus Aid, Relief, and Economic Security Act) in general, which provides approximately $2 trillion worth of economic assistance to consumers and businesses.

A common question is about resources for new and micro-size enterprises that did not bank with or qualify for traditional financial institutions. There are additional relief resources available to small businesses through the SBA that can be accessed at SBA.gov/disaster and also with Community Development Financial Institutions (CDFIs). As the largest capital provider to CDFIs, Bank of America has committed an additional $250 million to help CDFIs provide Paycheck Protection Program assistance and other needs to those small businesses.

Please explain the requirements to receive an SBA disaster loan.

There are several different relief programs that the SBA, the state and municipalities are offering, each may have different requirements. For the Paycheck Protection Program, for example, small businesses should gather the following documentation that may be needed:

1. 2019 Payroll – total payroll for full year 2019, by employee, as reported to the IRS.

2. 2019 Independent Contractor Costs – Listing of 1099's-MISC for 2019 independent contractors, by person, as reported to the IRS. (Note: Do NOT include 1099's for services)

3. Payroll report as of Feb. 15, 2020 or closest date after that date, by employee.

4. Other information that is required by the application on the U.S. Treasury website.

What small businesses don't know about SBA loan programs, but should?

Bank of America continues to be the nation's top small business lender with about $39 billion in total outstanding small business loans by the end of 2019, this includes SBA 504 and 7(a) programs. So, we understand that SBA lending is a vital part of what we offer our clients and we have personalized conversations with them to help determine how we can help them, either through SBA products or our own resources.

Aaron J. Beckman

Government Guaranteed Lending Program Manager

Tri Counties Bank

3700 Douglas Blvd., Roseville

916-984-2208

AaronBeckman@tcbk.com

Years worked in the banking business: Over 25 years

Years at your present position: 3 years

Significant news at your company in the past year:

At Tri Counties Bank, we're always looking for ways to improve our lending process and, ultimately, the customer experience. To that end, in 2019 we launched technology that allows us to streamline the commercial lending process from start to finish. Through real-time status updates and automated task routing, the technology promotes internal communication and ultimately results in a more timely decision for the customer.

Fortunately, we've been able to leverage this same technology to respond more quickly to our customers' needs during the COVID-19 crisis.

Whether underwriting payment relief on existing loans or processing new SBA Paycheck Protection Program loans, the technology streamlines our process and provides more timely aid to our loyal customers in their time of need.

What has been the direct impact of the coronavirus on your level of activity?

The economic impact of the COVID-19 pandemic has been devastating for small businesses and the Small Business Administration offers several relief programs, most notably the Paycheck Protection Program (PPP).

As a SBA preferred lender, Tri Counties Bank is actively participating in this program and is processing applications on behalf of our business customers. The PPP offers loan forgiveness for qualified expenses, and is therefore extremely beneficial to business owners during this time.

What are the most common five questions being asked of you by those who hold SBA loans?

1) Is it true that the SBA will pay the principal, interest and fees of current SBA 7(a) loans for six months?

Yes

2) If so, how do I apply for that kind of payment relief?

Payment relief is automatically granted by the SBA.

3) What should I do if I have an existing SBA 7(a) loan and I am unable to make payments due to financial strain caused by the pandemic?

Your loan principal, interest and fees will automatically be paid by the SBA for six months. If you don't think you'll be able to make the payment after the six-month period ends, please reach out to your lender and share your concerns.

4) My business is unaffected by COVID-19. Are you still making conventional (i.e. non-PPP) SBA 7(a) loans?

Yes. In addition to making SBA PPP loans, Tri Counties Bank is still making loans through the conventional SBA 7(a) loan program.

5) If I have an existing SBA 7(a) loan, am I allowed to apply for a Paycheck Protection Program loan?

Yes. Existing SBA 7(a) borrowers can apply for a PPP loan as long as they meet all other program eligibility requirements.

Please explain the requirements to receive an SBA disaster loan.

The SBA offers multiple loan options for small businesses seeking relief due to the COVID-19 pandemic and the requirements differ depending on the specific loan type. For more information on the various loan types and requirements, visit the SBA website.

What small businesses don't know about SBA loan programs, but should?

SBA loan programs have always been a great tool for promoting economic growth by giving small businesses access to capital that might not otherwise be available. Often, small business loans carry more risk because smaller borrowers tend to generate less cash flow and/or have less collateral compared to larger, more established businesses.

Enter the SBA.

Through credit enhancements like federal loan guarantees, SBA loan programs endeavor to offset small business lending risks to an extent that encourages lenders to make loans outside their normal credit box.

In this way, SBA loan programs are an ideal public-private-partnership. Lenders make loans that don't meet their conventional credit standards in exchange for federal enhancements that offset the added risk. This results in loan programs for small businesses that wouldn't otherwise have access to much needed capital.

This public-private-partnership has only been enhanced through the Paycheck Protection Program (PPP). With the PPP, the SBA increased its federal loan guaranty to 100% (up from the normal 75% to 85%) in order to further encourage lender participation.

Additionally, the SBA opened the program to qualifying non-profits – an entire industry that previously wasn't eligible for SBA loans. The SBA also expanded eligibility for companies in the food service industry in order to more broadly support those severely impacted businesses.(Member FDIC)

Tony Ghisla

Executive Vice President Chief Lending Officer

Poppy Bank

438 1st St. Suite 100, Santa Rosa

707-636-9000

loanhelp@poppy.bank

Years worked in the banking business: 39 years

Years at your present position: 3

Significant news at your company in the past year:

In 2019 we experienced a 31% growth to over $2.5 billion in assets and continued expansion into the Southern California Market. The bank currently has branches across the San Francisco Bay Area, Roseville and Southern California area and will be opening additional branch locations in San Diego/La Jolla, Napa, and San Rafael in 2020.

We specialize in business lending including commercial loans and lines of credit, commercial real estate, construction and SBA/USDA loans. We are proud to be 5-star rated by Bauer Financial, the nation's leading independent bank and credit union rating firm and recognized as one of the strongest financial institutions in the country.

What has been the direct impact of the coronavirus on your level of activity?

Our SBA team is working tirelessly to meet the needs of our clients seeking assistance during this challenging time. Like many other financial institutions, we are experiencing a tremendous increase in the volume of requests for deferments and inquiries regarding the Paycheck Protection Program, an SBA loan developed for small businesses to keep their workforce on payroll through the COVID-19 crisis.

What are the most common top five questions being asked of you by those who hold SBA loans?

1. Am I eligible for the Paycheck Protection Program?

2. How long does it take to access the funds?

3. What is the process like for applying for PPP?

4. What are the requirements for loan forgiveness under the Paycheck Protection Program?

5. Mostly, our clients want to know that they are being supported through this challenging time and we are receiving many inquiries about how Poppy Bank is showing our support.

Tell us in what ways the SBA program of aiding those have received SBA loans has been modified to aid them.

We are looking at each scenario and analyzing how we can provide the most impact and the best guidance for a long-term solution. Every client and business is unique and each requires a different level of support.

There is not a cookie cutter solution to the current crisis and one mold does not fit the needs for all. We are meeting clients where they are in terms of immediate needs while also keeping in mind a vision and a plan for their future success.

Please explain the requirements to receive an SBA disaster loan.

This is a direct loan from the SBA. You have to go onto their website and apply. In response to the COVID-19 pandemic, small business owners in all U.S. States, Washington D.C., and territories are eligible to apply for an Economic Injury Disaster Loan (EIDL) advance of up to $10,000.

The SBA's EIDL program provides small businesses with working capital loans of up to $2 million that can provide vital economic support to small businesses to help overcome the temporary loss of revenue they are currently experiencing.

Also, what changes have been made to allow those who have an SBA loan to either modify that loan and/or to extend the payment period, if at all?

At this time, we are working with all of our current clients to meet their individualized needs and to help them succeed in any way we can. This includes making modifications and providing creative financing where we are able to do so.

As part of the CARES Act, SBA has agreed to make principal and interest payments for up to 6 months for borrowers who have SBA 7(a) loans.

As SBA CARES Act guidelines continue to be refined, we continue to learn more every day and work hard at getting that information out to our customers.

What small businesses don't know about SBA loan programs, but should?

It's important for small businesses to understand how loan forgiveness works within the Paycheck Protection Program. As is true anytime you receive funding, businesses should make sure the terms of the agreement are beneficial for long-term success.

With the Paycheck Protection Program, if a small business keeps all employees on payroll or rehires their staff by June 30, 2020, they may be eligible for forgiveness.

However, Payroll costs must be 75% or more of the approved loan amount and only 25% of the amount forgiven may be used on non-payroll expenses.

Small businesses should also know that they must apply for loan forgiveness with their bank after the 8-week period of employment following the receipt of funds.

Most importantly, borrowers should refer to the SBA Interim Final Rule that contains the most up-to-date information and can be found at www.sba.gov.

Brian Kilkenny

Business Services Administrator

Redwood Credit Union

3033 Cleveland Ave., Santa Rosa

707-576-5422

BKilkenny@redwoodcu.org

Years worked in the banking business: 7 years

Years at your present position: 1 year

Significant news at your company in the past year:

For the 6th consecutive year, Redwood Credit Union was ranked by Glatt Consulting one of the top five healthiest credit unions in the nation, based on 17 metrics of strength and growth. This recognition helps reinforce consumer confidence in RCU, especially during times of economic uncertainty in the general market.

We recently added new branches in American Canyon and Lower Lake so we can now fully partner with small businesses in those communities.

In response to the Kincade Fire, power shut-offs, and evacuations, RCU distributed $139,554 to impacted communities in the form of grants, gift cards, meals, and more. In all, 27,145 people were helped with housing, food, and mental health. Small businesses also received support.

While other financial institutions closed for the federal holiday Oct. 14, RCU's entire workforce deployed to 15 schools across three counties for one big Day of Impact. On this first-ever day of its kind, RCU provided financial education to approximately 3,100 teens with an adult personal finance simulation via the Bite of Reality program. Senator Mike McGuire, Congressman Jared Huffman and Congressman Mike Thompson took part in the event.

What has been the direct impact of the coronavirus on your level of activity?

We had already been seeing an increase in SBA loan applications with the growth of our SBA 504, 7(a), and Express portfolios due to our years of dedication to the local small business community and a fairly robust local economy.

With the onset of the coronavirus pandemic, the pace of applications for SBA loan programs continues to gain momentum. We're extremely busy helping small businesses with existing loans and new loans, as well as helping them navigate the Small Business Administration's Paycheck Protection Program (PPP).

What are the most common five questions being asked of you by those who hold SBA loans?

The questions and answers vary depending on the business, but our lending team is always happy to help with any questions members have.

Tell us in what ways the SBA program of aiding those who have received SBA loans has been modified to aid them.

As an SBA Preferred lender, Redwood Credit Union participated in the Paycheck Protection Program (PPP).

Please explain the requirements to receive an SBA disaster loan.

To receive an SBA disaster loan, the lender must have a credit history and repayment plan acceptable to SBA. They must be located within the declared disaster area and have suffered, or are likely to suffer, substantial economic injury as a result of the disaster. They must be an independently owned and operated business and not have credit available elsewhere. There are other subtle requirements, which our team can assist with.

Also, what changes have been made to allow those who have an SBA loan to either modify that loan and/or to extend the payment period, if at all?

RCU is offering extended loan payment relief on all RCU loans and lines of credit, including 90-day payment deferrals on all consumer, credit card, mortgage and business loans.

We're also waiving late fees and will not be reporting loans as delinquent to the credit bureaus during any payment deferral period. We're reversing overdraft fees until further notice and allowing all members to make early withdrawals from RCU certificates without penalty.

Other financial assistance programs tailored to the member's individual situation are also being offered.

What small businesses don't know about SBA loan programs, but should?

SBA loans are small-business loans guaranteed by the SBA and issued by participating lenders like RCU. (RCU is a preferred lender, which means we can help borrowers get the funds they need faster than a regular SBA lender.) We also have the authority to make final credit decisions on SBA-guaranteed loans

There are SBA loan programs to fit all sizes and ages of small businesses. We still talk to small business owners who have the misconception that SBA loan programs are only for start-ups or very new businesses.

In fact, the SBA loan programs can be used to foster expansion for an established business, as well as finance large capital expenditures like equipment or a new building for a business, with as little as 10% down payment.

Joe N. Smith

Senior Vice President, SBA Manager

Exchange Bank

444 Aviation Blvd.,

Santa Rosa

707-541-1493

joe.smith@exchangebank.com

Years worked in the banking business: 30 years

Years at your present position: 4 years

What has been the direct impact of the coronavirus on your level of activity?

The effect of the coronavirus has been economically devastating to so many small businesses and their employees. New loans in process for industries that have been negatively affected by the coronavirus pandemic have been postponed, with approvals still given but on hold until there are signs of a re-emerging economy.

An uptick in activity is in the area of loan payment deferrals. SBA offers on all loans a one-time deferral of payments for three to six months and this option for businesses has provided relief.

What are the most common questions being asked of you by those who hold SBA loans?

1) Will the SBA be offering relief for my existing SBA loans?

Yes, the SBA is making six months of payments for all SBA borrowers on existing SBA loans that are current.

2) Do I need to do anything to receive these payments?

No, SBA will make your payment to your bank starting with your next payment due after 3/27/2020. Borrowers do not have to reimburse SBA for these payments.

3) Lots of questions on the Payment Protection Program.

SBA's intent was to use the U.S. banking system to deliver this $349 billion in forgivable loan aid to small business quickly but in doing so pulled the trigger with still many unanswered questions on how banks could execute the program. Exchange Bank has excepted a huge number of these application and has mobilized virtually all departments to assist in getting these loans funded.

4) Can I get a standard SBA loan now to help with the coronavirus effects on my business?

Standard SBA loans are not designed to provide use of proceeds to address disasters and pandemics. The SBA Economic Injury Disaster Loan (EIDL) is a solid option for this.

Please explain the requirements to receive an SBA disaster loan.

Exchange Bank conducted numerous webinars to the community in March on the SBA Economic Injury Disaster Loans program (EIDL).

This program is not a “stimulus” program, rather it is part of what SBA has offered since its inception in 1953.

In general, this program looks to give any small business effected by a disaster six months of operating expenses up to $2,000,000 in the form of a loan repayable over 30 years at a low fixed interest rate of 3.75%. Businesses apply directly to the SBA for this loan.

Link to seminar recording and slide deck: Understanding the Coronavirus Government Financial Resource Options for your Business

What small businesses don't know about SBA loan programs, but should?

The SBA program allows for start-up, projection-based loans, business acquisition, building purchase or construction, tenant improvements, working capital, unsecured business loans and lines of credit.

Exchange Bank is active in all of these lending categories. What is great about the SBA program is that it thrives in both times of economic prosperity as well as in times of economic recession. In good times, businesses need capital to grow and the aggressive terms help businesses borrow the maximum amount to accomplish this. In times of recession, businesses need those same aggressive terms to allow them access to capital to hold the line or supplement losses as the business adapts to the changes. This is one reason why the SBA program has grown year over year virtually every year since its formation in 1953.

SBA Loans Features & Benefits:

• Low down payments (generally 10%)

• Extended terms (10 years on FF&E, working Capital) (25 years on real estate)

• When Real Estate is the primary purpose, the FF&E and working capital are all done at the extended 25-year term

• No balloon payments (once loan is done, it's in place for the duration)

• No prepayment penalties on 10-year loans (minimal on real estate loans)

• Relaxed credit and cash flow standards (easier to approve)

• Payment deferments available for troubled times

Along with these advantages, SBA loans are great options for businesses in all stages of maturity. They help them get started, trade hands and grow. In times of trouble they offer the maximum flexibility when working with a bank.

In unprecedented times like today's, while not in the normal program provisions, the SBA stepping up and making six months of payments on every SBA loan in the country is a lifeline to the existing SBA community that I am certain makes them all glad they went the SBA loan route.

Bob Thompson

Vice President

Bay Area Development Company

1801 Oakland Blvd., Suite 100, Walnut Creek

925-472-5603

bob@baydevco.com

Years worked in the banking business: 35 years

Years at your present position: 25 years

Significant news at your company in the past year:

It had largely been business as usual until the current impact of COVID-19. We have also had the benefit of generally low interest rates, and they have only decreased with the impact of COVID-19 and are currently at all time lows.

What has been the direct impact of the coronavirus on your level of activity?

New business has decreased substantially, but we have been seeing some requests related to refinancing higher interest rate real estate and equipment financing and for businesses not highly adversely impacted by COVID-19.

Please, what are the most common top five questions being asked of you by those who hold SBA loans? What kind of relief are you (or others) offering and how do I access it?

Is the federal government really going to “cover or forgive” my loan payments for the next six months and what do I need to do to receive that relief (answer is yes and nothing)?

Can you help me navigate the loan application process for relief financing and provide me with preferential treatment or an expedited response (answer is yes, to a degree, and no, respectively)? Are you still making new loans (a resounding yes)?

Can I refinance my existing SBA guaranteed 504 loan with a new SBA 504 loan (answer is no)?

Tell us in what ways the SBA program of aiding those have received SBA loans has been modified to aid them.

Provision of low interest Economic Disaster Injury Loans (EDIL) provided directly by SBA and the issuance of the newly instituted CARES Act, including the Payroll Protection Program (PPP) and loan forgiveness (six months) for existing and new clients (within six months of the Act – signed into law on 3/27/20.

PPP loans are 100% guaranteed and involve applicants self-certifying many aspects of the application in an attempt to aid implementation and reduce the degree of lender review.

Please explain the requirements to receive an SBA disaster loan.

Be a small business that has been negatively impacted by the virus (and the requirement for social distancing) and utilize the proceeds for specific, acceptable purposes, with payroll being a primary use of the Payroll Protection Program.

Also, what changes have been made to allow those who have a SBA loan to either modify that loan and/or to extend the payment period, if at all?

SBA had granted the unilateral ability for Certified Development Companies to offer up to six months of loan payment deferrals and we had been receiving an overwhelming interest in obtaining deferrals.

As noted previously, the CARES Act provides for six months debt forgiveness for existing and new borrowers and started with their April payment (for 504 loans). As a result of this loan forgiveness, most Borrowers delayed seeking a referral. Depending upon the timing of society's return to some aspect of normalcy, deferral requests may pick back up, again, in the fall.

What small businesses don't know about SBA loan programs, but should?

They are there to help small businesses in good times and bad and are not just a lender of last resort, but allow participating lenders to offer very attractive loan terms via the guarantee of loans made by them.

Ole Tustin

Vice president, SBA business development officer

U.S. Bank

One California St., Ste. 2000, San Francisco

415-399-8068

ole.tustin@usbank.com

Years worked in the banking business: 21

Years at your present position: 21

Significant news at your company in the past year:

Over the last year, we unveiled an entirely rebuilt U.S. Bank mobile app, co-created every step of the way with our customers.

In the last month, we announced our response to support employees, customers and communities affected by COVID-19. For our customers, we have made temporary adjustments to certain consumer and small-business lending products and we are offering mortgage assistance programs.

We also announced a 20% premium pay program for our front-line employees and a $30M nationwide community investment to support COVID-19 recovery efforts.

What has been the direct impact of the coronavirus on your level of activity?

In my more than 20 years in SBA lending, we have never had the level of urgency and activity from Bay Area small businesses as we have had with the recent announcement of the SBA Paycheck Protection Program (PPP). This is on top of our ongoing activities for borrowers with new money loan requests.

Before the PPP rolled out, we reached out to our existing SBA customers to check in, share possible short-term cash solutions and the link to the SBA Economic Injury Disaster Loan site. As soon as the PPP was announced two weeks later, a flood of activity from phone calls to texts to emails began, day and night. We've been contacted by current customers, past customers and new customers. Unlike most other lenders, we have accepted non-U.S. Bank customer applications.

As of April 13, we have over 75,000 businesses that have requested funds. As lenders, we were tasked with rolling out a PPP platform over a weekend, when it would normally take six months. At U.S. Bank we have been deliberate in our approach, utilizing our existing digital platform for single-owner businesses and expanding over the past week for multi-owner businesses and nonprofits. We have redeployed bankers from across our company to help, including a 1,000-plus person team of U.S. Bank bankers who are volunteering to support the payroll review process.

The other impact of coronavirus to existing new money requests has been the new requirement to have small business owners estimate and quantify the short-term and projected effects of COVID-19, which can be challenging.

This is no longer just a lender requirement, it is now also an SBA requirement to have an Adverse Change Certification on new money. For building purchases that were in escrow, we aren't seeing any cancellations due to this new requirement - particularly on the industrial side - but new activity has not surprisingly slowed significantly.

What are the most common five questions being asked of you by those who hold SBA loans?

1. Is the SBA offering to pay for the existing loan for the next 6 months?

Yes for the 7(a) and yes for the 504 2nd. U.S. Bank will work with customers on a deferment for the 504 1st on a case-by-case basis.

2. Can I get a PPP loan if I have an existing SBA or am applying for a new money SBA loan (like a building purchase, construction, business acquisition, etc.)?

Yes

3. Can I take get PPP approval but not roll out the money until later?

The latest as of April 7 is that the borrower must use the PPP money within 10 days of SBA authorization.

4. Can I get a new money loan say for a building purchase if I have been affected by this?

Most lenders and the SBA will really want to see a road map or signs of the business cash flow stabilizing. The next month or so will help with data points.

5. Can I modify my loan later? (i.e. rate)?

This is generally case-by-case, but U.S. Bank is somewhat unique in being a SBA portfolio lender (versus selling on the secondary market) so in theory we can modify the rate.

Tell us in what ways the SBA program of aiding those who have received SBA loans has been modified to aid them.

The purpose of the PPP is to help small businesses, especially employees, as fast as possible. Everything was streamlined, but with initial $349 billion in funding, this is roughly 10 times the magnitude of the normal SBA annual loan originations.

PPP in theory can be forgiven on the payroll side after the eight weeks, if followed correctly. The rate is then just 1% for the two years on that part of the loan that is not forgiven, if applicable.

There is no personal guaranty. There is no SBA guaranty fee. SBA also reduced the level of financials normally needed to primarily just payroll documentation (versus three years of tax returns, etc.) in the past 12 months, etc. The SBA Economic Injury Disaster Loan (EIDL) also has very favorable terms, but requires a personal guaranty and possible collateral.

What small businesses don't know about SBA loan programs, but should?

SBA loans are here to help a small business with cash flow and long-term stability, in addition to boosting employment at a most fundamental level. Because they have a guaranty from the SBA, the borrower can generally receive better terms such as less money down (as little as 10%) and a longer term which means lower monthly payments (longer terms for real estate and non-real estate) than a conventional loan. With an SBA guaranteed loan a lender may also consider lending on potentially riskier requests (i.e. new businesses, etc.).

In the short term, the SBA will really need to see (outside of PPP) how the business is addressing COVID-19. Specific to U.S. Bank, we are a portfolio lender, so because we hold the loans we can offer a more flexibility and terms in general. In theory, we can also modify the loan without refinancing after closing.

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