Paycheck Protection Program

The NCUA will not criticize credit unions’ prudent, good faith efforts to use the SBA programs with members affected by COVID-19.

The SBA PPP is a no-risk program if the credit union complies with the applicable lender obligations when granting PPP loans. The examiner should review the size of the portfolio and perform a risk-based review, if appropriate.

A PPP scope may include a review of:

  1. The COVID-19 survey completed with credit union staff or the Call Report to determine the volume of PPP loans.
  2. Loan origination procedures to determine if the credit union is in compliance with the lender obligations.
  3. The volume of unforgiven whole or partial PPP loans and their status (performing, delinquent, etc.)
  4. Any loans for which the credit union was denied a guarantee and their status (performing, delinquent, etc.). The examiner should expand the scope to include an individual loan review if the SBA denied paying the 100 percent guarantee.

Questions to Consider

  • What is the volume of PPP loans?
  • What is the trend in delinquency and loan losses from the PPP?
  • What is the volume of modifications, rewrites, or rolling of PPP loans?
  • Are there any consumer compliance complaints related to the credit union’s PPP?
  • Does the credit union have sufficient resources (internal or third party) to collect on delinquent PPP loans?

Last updated on September 15, 2021