by Jodi L. Avergun, Scott A. Cammarn, Christian Larson, and Kendra L. Wharton
Recent press coverage concerning transparency and oversight with respect to the Paycheck Protection Program (“PPP”) has largely focused on PPP borrowers and the ability of Congress and federal inspectors general to obtain PPP borrower data from the Small Business Administration (“SBA”). The SBA has announced that it will release certain information about the loans PPP lenders issued. However, given limitations on the information that will be disclosed, Congress and federal inspectors general may also seek detailed PPP borrower and other information directly from lenders. The latter scenario could lead to requests for PPP lenders to provide data and respond to pointed questions. This memorandum outlines issues which lenders may wish to consider in anticipation of such information requests.