Bank's are not eligible for PPP funds.
Interim Final Rule Section III.2.c.
Businesses that are not eligible for PPP loans are identified in 13 CFR 120.110 and described further in SBA's Standard Operating Procedure (SOP) 50 10, Subpart B, Chapter 2, except that nonprofit organizations authorized under the Act are eligible. (SOP 50 10 can be found at https://www.sba.gov/document/sop-50-10-5-lender-development-company-loan-programs.)
Per SOP 50 10:
III. INELIGIBLE TYPES OF BUSINESSES
2. Businesses Engaged in Lending (13 CFR § 120.110 (b)). a. SBA cannot guarantee a loan that provides funds to businesses primarily engaged in lending, investments, or to an otherwise eligible business engaged in financing or factoring. This prohibits SBA loans to: i. Banks; ii. Life Insurance Companies (but not independent agents); iii. Finance Companies; iv. Factoring companies; v. Investment Companies; vi. Bail Bond Companies; and vii. Other businesses whose stock in trade is money.
Community Bank are ineligible - Please look at a9 in frequently asked questions.
I haven't seen anything since then that contradicts this conclusion or says SBA has revised their guidance. So, at this point I do not think Banks are eligible for a PPP loan.
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Has it been confirmed that a bank itself isn't eligible for a PPP loan through another bank?
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Mary Fowler
Chief Executive Officer
The Peoples Bank
Magnolia AR
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