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The Small Business Jobs and Credit Act of 2010 was signed into law on September 27, 2010. The memorandum below from Noel Gruber of BuckleySandler summarizes the provisions of the Act.

There is much to commend in the Act—it gives banks with CAMELS ratings of 1, 2, or 3 an opportunity to raise capital through a Department of Treasury investment. However, it does not help those banks with CAMELS ratings of 4 or 5.

All banks would have been helped by a House amendment allowing them to amortize losses on certain loans and OREO over a period of up to ten years. The House approved the amendment in June, but the Senate version omitted it. AABD’s David Baris wrote an American Banker Viewpoints article which urged the House to reinstate the amortization provision.

Download PDF: Memo Re: Small Business Lending Fund, October 1, 2010

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