Heroes Act PPP loans


Post update: There is bi-partisan support on Congress and in the White House to provide Covid relief via another round of payroll protection program (“PPP”) loans. We are closely monitoring the actions in Washington. Subscribe here to be notified of important developments as they manifest and to be introduced to top PPP lenders if desired once PPP 2.0 is launched:

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Executive Summary

  • Another round of PPP stimulus is likely in 2020
  • Initial anticipated allocation of $130B – $160B will be gone in a week
  • Over $270B will need to cover all eligible applicants

There seems to be bi-partisan support in Congress now for another round of Payroll Protection Program (PPP) loans. On October 1, House of Representatives passed a revised Heroes Act 2.0 stimulus bill. Obviously, the Heroes Act bill is not law, but a review of that bill can provide insight into what Congressional leaders believe an enacted law may entail. Note that the Senate introduced the Heals Act in July, but we are focusing on aspects of the Heroes Act to glean insights into potential Congressional action since the Heroes Act was passed recently and House leadership was in consultation with the White House during negotiations and passage.


 CARES ActHeroes Act
Program size$659 billion allocated by Congress; $539 billion actually spent$160 billon
Business size< 500 or less employees (with exceptions for multiple locations)< 200 employees (with limits on multiple locations)
Covid impactMust state that Covid negatively impacted biz>25% reduction in quarterly sales from Covid
Maximum PPP loan$10 million$2 million
ForgivenessComplicated< $50K Certify accuracy
>$50K - $150K Certify and 1 pg app
>$150K Lender review app & submit to SBA

Forgiven expensesNot deductibleDeductible

As you may recall, the original PPP program (created through the Cares Act) was for $659 billion, but only $525B was applied for by the August 8 deadline. That leaves $135 billion in PPP funds available that have not been deployed. We believe the proposed $130B – $160B being discussed will run out in a week or less (assuming the SBA can scale eTrans to that throughput level out of the gate). We also believe over $270B will ultimately be needed and will be approved by Congress albeit perhaps in two tranches:


We have crunched the numbers and here were the most active PPP lenders during the CARES Act PPP loan program, which ran from March to August:

RankLender (loans < $150,000)# of PPP Loans RankLender (loans > $150,000)# of PPP Loans
1Bank of America313,7551JPMorgan Chase Bank36,923
2JPMorgan Chase Bank243,2602Bank of America29,796
3Kabbage193,8413Truist Bank15,764
4Cross River Bank192,3804PNC Bank14,590
5Wells Fargo Bank182,1535Wells Fargo Bank12,288
6Celtic Bank Corporation143,0686TD Bank10,449
7U.S. Bank99,6097KeyBank9,394
8TD Bank75,5198U.S. Bank8,755
9WebBank74,6149Zions Bank8,481
10Customers Bank72,17910M&T8,308
11Truist Bank66,28311Huntington Bank8,035
12PNC Bank59,33412Cross River Bank6,323
13Citizens Bank45,60113Fifth Third Bank6,041
14Regions Bank41,80114Regions Bank5,389
15Zions Bank39,34515Citizens Bank5,378
16Fifth Third Bank34,03016First Horizon Bank5,357
17KeyBank National Association33,77517City National Bank5,082
18Readycap Lending30,61418First-Citizens B&T4,710
19Huntington Bank30,34919BMO Harris Bank4,544
20First Horizon Bank27,40520Frost Bank4,321

Note that many of the banks on the list above only processed PPP loans for their own customers, which explains why many of the top banks on the list also happen to be many of the largest banks in America. Some Fintechs did participate in the second allocation of PPP capital after the initial funds ran out, and we suspect their earlier participation with the autumn PPP round will only accelerate how the fast the dollars are allocated. Regardless, even with all dollars being earmarked to borrowers we believe it’s likely that Congress will go back and allocate even more dollars just like with the CARES Act PPP program. And, just like with CARES Act PPP, Heroes Act PPP will be a stressful time for borrowers, bankers, and the SBA as there will an initial stampede to grab the “first come, first served” nature of the program. An open ended program (with no dollar limit) would be ideal but unlikely.