Pandemic-Era PPP Loan Rules Become Permanent Six Years Later
Published Date: 11/4/2026
Rule
Summary
The NCUA is making permanent the emergency rules from 2020 that helped credit unions support small businesses during COVID-19 through the Paycheck Protection Program (PPP). This means PPP loans still get special treatment in credit union capital rules, helping lenders keep funds flowing smoothly. The final rule kicks in on November 4, 2026, ensuring credit unions can keep backing their members with confidence.
Analyzed Economic Effects
4 provisions identified: 4 benefits, 0 costs, 0 mixed.
PPP Loans Keep Zero Risk Weight
Federally insured credit unions (FICUs) may continue to assign a zero percent risk weight to Paycheck Protection Program (PPP) loans under the NCUA's risk-based capital rules. The rule adopts as final the April 27, 2020 interim final rule, preserving the PPP zero percent risk-weight treatment required by the CARES Act.
PPP Loans Excluded from Total Assets When Pledged
PPP loans that a credit union pledges as collateral to the Federal Reserve's PPP Loan Facility are excluded from the NCUA definition of total assets for calculating a credit union's net worth ratio. This exclusion allows FICUs to neutralize the regulatory capital effects of participating in the PPP Loan Facility.
PPP Loans Not Treated as Commercial Loans
The rule finalizes the April 27, 2020 amendment that excludes PPP loans issued under the CARES Act from the definition of "commercial loan" in 12 CFR 723.2. Because PPP loans are excluded, the enhanced underwriting and due-diligence requirements in the member business lending rule do not apply to those PPP loans.
No Significant Impact Found for Small Credit Unions
The NCUA certifies that this final rule will not have a significant economic impact on a substantial number of small federally insured credit unions, where "small" is defined as credit unions with assets less than $100 million. The agency states the rule does not impose any new significant burden on FICUs.
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