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PPP Loans and Capital

PPP Loans and Capital
Jul 15, 2025 4:18:18 PM

I questioned the Treasury and ABA on this issue and the ABA is pressing to exclude all PPP loans no matter if they are pledged or not.  The pledging of the loans requires an advance of the pledged amount at time of pledging with the Discount window. Pledging to the FHLB is not approved yet, but ABA felt that it would be and if so, PPP loans pledged would be excluded from calculations.  FHLB does not require an advance when pledging collateral.    

ABA felt confident that this change would be approved.. 

Thanks

 

Dick Burch
Executive Vice President

Chief Financial Officer

SouthAtlantic.bank
630 29th Avenue North
Myrtle Beach SC 29577

P O Box 70130 (29572)
O: 843.839.4412
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------Original Message------

I have read the guidance from the regulatory agencies and it appears that we can exclude PPP loans from our average assets if we take an advance against the loans from the Federal Reserve using their PPPL program.  If you do not use the Federal Reserve to fund your PPP loans or only fund a portion of the loans through the Federal Reserve, then do you include the unpledged loans in your average assets?

Thanks,

Tim​

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Timothy Foreman
CFO
Axiom Bank, National Association
Maitland FL
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