Paycheck Protection Program Audit Available

If your institution participated in the Small Business Administration’s (SBA) Paycheck Protection Program (PPP) loan program:
  • Do you have nagging concerns that your PPP loans are not fully compliant with the ever-changing regulations?
  • Do you worry that in a rush to make PPP loans your institution may have overlooked potential regulatory and risk management pitfalls?
  • Do you have uncertainty that that your customers’ PPP loans will be forgiven by the SBA?
If you answered “yes” to any of the above questions, you are not alone. Compliance Services Group (CSG) is here to help.
CSG has developed a unique loan audit program designed to meet individualized needs. Whether your concerns are origination and onboarding, forgiveness and payoff, or both – we can help.
The primary areas that we focus on are:
  • Ensuring proper PPP program enrollment documentation is maintained.
  • Reviewing a sampling of PPP loans originated and onboarded.
  • Verifying PPP loan applications are complete and properly supported.
  • Reviewing promissory notes for accuracy and completeness.
  • Ensuring that lender applications are complete and that SBA approvals are documented.
  • Tracing and reconciling SBA fee reimbursements.
  • Ensuring that BSA and ECOA/Regulation B requirements are met.
  • Reviewing a sampling of PPP loans forgiven and paid off.
  • Ensuring forgiveness applications are complete and that SBA approvals are documented.
  • Tracing and reconciling SBA loan forgiveness amounts.
Please note that auditing specifically for fraud is not part of our scope.

Having a hard time keeping up with all of the changes and updated guidance related to the Paycheck Protection Program?  We have a custom page with links to the rules, guidance, and applications that you can visit to see the latest information.

Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized as “law-related services” under Rule 5.7 of the Rules of Professional Conduct governing lawyers.  Since some of our employees are lawyers with an active bar license but are NOT engaged in the private practice of law, that Rule requires us to make disclosures clarifying that the services we perform may be law-related services, but they are not legal services.  Because they are not legal services, those services and our relationship will not be governed by the Rules of Professional Conduct that guide the client-lawyer relationship, such as rules applicable to privileged communications and prohibitions of conflicts of interest.  Notwithstanding this disclaimer, we will continue to govern our relationship with you using reasonable ethical and professional standards that are expected to meet your expectations.

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