Type: Law Bulletins
Date: 02/16/2021

SBA Part Thirty-Seven: PPP Lenders Not Registered With Must Do So Quickly!

On Feb. 12, 2021, the Small Business Administration (SBA) issued Procedural Notice 5000-20094 that notes all Paycheck Protection Program lenders need to be registered with and that “the requirement to complete SAM registration and obtain a unique entity identifier applies to the following entities that participate in SBA business loan programs: 7(a) Lenders, including Paycheck Protection Program (PPP) Lenders; Certified Development Companies (CDCs); [and] Microloan Intermediaries.” Registration with is a requirement to obtain a “unique entity identifier” as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA).

These entities are encouraged to complete a registration if they have not previously done so, or if their registration is out of date. By doing this, these entities will be in compliance with the Aug. 13, 2020 Office of Management and Budget Guidance for Grants and Agreements, implementing the FFATA.

The SBA will be revising its regulations and standard operating procedures to capture this requirement going forward. Because of the pandemic, the SBA has determined sufficient exigent circumstances exist to waive the registration requirement, so long as registration is completed within 30 days of the first loan disbursement for loans made on or before Dec. 27, 2021.

Contact a member of Taft’s Government Contracts team or SBA Task Force if you require any help applying for, reviving, or maintaining a registration.

Please visit our COVID-19 Toolkit for all of Taft’s updates on the coronavirus.

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