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About Norman E. Greenspan

Best Practices: Certifying Records Requested in a PPP Loan Investigation

Considering the billions of dollars in PPP loans that Lenders made without being able to employ its customary underwriting and due diligence procedures, it is not surprising that investigations are…
  • October 7, 2020
  • Norman E. Greenspan

Best Practices: Using An Internal Investigation To Your Advantage

As in any industry that is subject to government oversight and regulation, participants in SBA loan guaranty programs are subject to higher levels of scrutiny than most businesses.  The consequences…
  • June 24, 2020
  • Norman E. Greenspan

Best Practices: How to Deal with a Subpoena for a Customer’s Bank Records

Banks are repositories for vast amounts of financial information.  This information may be useful to parties in lawsuits in which the bank is just an innocent bystander.  Banks often receive…
  • November 20, 2019
  • Norman E. Greenspan

Best Practices: Take the Opportunity to Comment on the SBA’s Most Recent Proposed Rules

Pursuant to the requirements of the Small Business 7(a) Lending Reform Act of 2018, Pub. L. 115-189 (“SBA Reform Act”) that amended the Small Business Act, 15 U.S.C. §651 et…
  • August 7, 2019
  • Norman E. Greenspan

Best Practices: Understanding the Office of Credit Risk Management’s Newly Enhanced Role in the SBA Regulatory Scheme

Last year, the President signed into law the Small Business 7(a) Lending Reform Act of 2018, Pub. L. 115-189 (“SBA Reform Act”) that amended the Small Business Act, 15 U.S.C.…
  • April 3, 2019
  • Norman E. Greenspan

Best Practices: False Claims Act Liability and the need to make a “CLAIM”

We have written previously on the Small Business Administration’s increased use of the federal False Claims Act (“FCA”) against lenders who fail to follow the SBA’s Standard Operating Procedures (“SOPs”)…
  • May 2, 2018
  • Norman E. Greenspan
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