On Monday, June 13, 2011, the Federal Reserve Board issued an interim final rule allowing small bank holding companies organized as S corporations to exclude debt issued to Treasury under the Small Business Lending Fund (SBLF) from the definition of “debt” under the Federal Reserve’s Small Bank Holding Company Policy Statement. In effect, SBLF debt will not be included in the debt-to-equity calculation applicable to small bank holding companies.
Small Business Lending Fund
Late Thursday afternoon, the Treasury Department finally released a term sheet for Subchapter S banks and mutuals, allowing them to participate in the Small Business Lending Fund (SBLF). The application deadline for both S corporations and mutuals is June 6, 2011. Though many Sub S banks have been anxiously awaiting this term sheet for months now, most will be exceedingly disappointed to learn that the funds will only qualify for Tier 2 capital treatment.