2020

(Last updated May 27, 2020)

As a follow-up to its release of the PPP Forgiveness Application (see our previous Client Alert on the application found here), late on Friday, May 22, 2020, the SBA released the following two Interim Final Rules (IFRs): (1) Paycheck Protection Program – Requirements – Loan Forgiveness (which can be found here); and (2) Paycheck Protection Program – SBA Loan Review Procedures and Related Borrower and Lender Responsibilities (which can be found here).  These IFRs include a wealth of useful guidance and should be carefully consulted by PPP borrowers.

As a number of the details in the IFR on Loan Forgiveness are also discussed in our Client Alert on the PPP Forgiveness Application linked above, I will not reiterate all of those details here.  Rather, I will focus this alert on new information and clarifications.

Here are the highlights from the referenced IFRs:

ADDITIONAL FORGIVENESS GUIDANCE

(1)  Payments to Furloughed Employees – In response to the confusion of many employers who furloughed employees (whether in response to government-mandated business closures or otherwise), the SBA makes clear that salary, wages, and commissions paid to furloughed employees during the covered 8 week period are eligible for forgiveness. We have heard of some employers only paying employees for work that the employees are actually able to do – to be clear, this is not the intent of the Paycheck Protection Program.  The primary intent of your PPP loan is to keep your employees on the payroll regardless of whether they are actually able to perform work functions during the 8 week covered period.  Employers who do not keep employees on the payroll for the covered period will either not be eligible for forgiveness or will only be eligible for partial forgiveness consistent with the forgiveness reduction provisions discussed in previous client alerts.

(2)  Bonuses and Hazard Pay – The SBA has determined that, if an employee’s total compensation does not exceed $100,000 on an annualized basis, the payment of hazard pay and bonuses to the employee is eligible for loan forgiveness as a supplement to salary or wages.

(3)  Caps on Loan Forgiveness for Owner-Employees and Self-Employed Individuals – The amount of PPP loan forgiveness requested for owner-employees and self-employed individuals’ payroll compensation can be no more than the lesser of: (i) 8/52 of 2019 compensation (i.e. approximately 15.38% of 2019 compensation); or (ii) $15,385 per individual in total across all businesses receiving a PPP loan. Please refer to the IFR on Loan Forgiveness (Section III.3.c.) for specific details on the caps for (a) owner-employees; (b) Schedule C filers; and (c) general partners.  Of note, the SBA has determined that no additional forgiveness will be provided for retirement or health insurance contributions for self-employed individuals, including Schedule C filers and general partners, as such expenses are paid out of the net self-employment income of such individuals.

(4)  Employees who Refuse Reemployment Offers – The SBA previously indicated that an employer’s loan forgiveness amount would not be reduced for an employee who was laid-off or who had his/her hours reduced during the period between February 15, 2020 and April 26, 2020, and who refused a re-employment offer made once the applicable employer received its PPP loan funds. The SBA has clarified the requirements for such exception as follows (including the critical change highlighted below):

a.   The borrower must have made a good faith, written offer to rehire such employee during the covered period (or alternative payroll covered period, as applicable);

b.   The offer to the employee must be for the same salary or wages and the same number of hours as earned by the employee during the last pay period prior to the separation or reduction in hours;

c.   The offer was rejected by the employee;

d.   The borrower has maintained a written record documenting the offer and its rejection; and

e.   The borrower informed the applicable state unemployment insurance office of such employee’s rejected offer of re-employment within 30 days of the employee’s rejection of the offer.

FORGIVENESS PROCESS AND REVIEW

(1)  Timing for Forgiveness Process – Once you submit your PPP Forgiveness Application (Form 3508) and all required documentation, your lender will have 60 days to review your application package and provide a determination on forgiveness to the SBA. If your lender has recommended the forgiveness of all or a portion of your SBA loan, the SBA will have 90 days after receipt of your lender’s forgiveness determination to remit the appropriate forgiveness amount to your lender (subject to the outcome of any internal review by the SBA of your application).

(2)  Lender Review Responsibilities – Your lender will be responsible to confirm the following to the SBA in connection with its forgiveness determination for your loan: (i) receipt from you of the proper certifications; (ii) receipt from you of the required documents supporting your payroll and non-payroll costs for which forgiveness is sought; (iii) your forgiveness application calculations; and (iv) compliance by you with the 75% rule (requiring you to spend 75% of your loan proceeds on payroll costs).

(3)  Forgiveness Determination – Following your lender’s review of your forgiveness application, your lender may recommend the following to the SBA: (i) forgiveness (in whole or in part); (ii) denial; or (iii) denial without prejudice (which means that you will have the chance to request reconsideration – perhaps after the submission of additional needed information). If your lender determines that you are not entitled to forgiveness in any amount, your lender must provide that determination to the SBA together with the reason for its denial and all documents submitted as part of your forgiveness application.  Furthermore, in such case your lender must provide you with notice of such denial determination.  The SBA reserves the right to review your lender’s determination.  Additionally, if your forgiveness application has been denied, then, within 30 days after you receive notice of your lender’s denial determination, you will have the right to request that the SBA review your lender’s decision.

(4)  SBA Review Right; Notice to Borrower – The SBA made it clear that it has the right to review any PPP loan. If the SBA undertakes a review of your loan forgiveness application, the SBA will notify your lender in writing and your lender is responsible to advise you of such review by the SBA within 5 business days after the lender receives notice of such review from the SBA.  As established in prior client alerts, the SBA will pay special attention to PPP loans for borrowers who (when considered with their affiliates) received loans in excess of $2,000,000, but this does not mean that the SBA cannot also review PPP loans for lesser amounts.

(5)  Document Retention Requirements – The SBA reiterated the obligation on borrowers to retain PPP related documents (including loan applications, forgiveness applications and supporting documents) in their files for a period of 6 years.

(6)  Outcome of SBA Review – If your PPP loan is determined to be an ineligible loan, the SBA may: (i) direct your lender to not forgive the loan; (ii) require prompt repayment; and/or (iii) pursue other available remedies. As indicated in previous client alerts, the SBA in previous guidance has indicated its intent to simply require prompt repayment of loans determined to be ineligible and that, if such ineligible loans are promptly repaid, the SBA will not make any referrals to other government agencies for enforcement.

(7)  Borrower Right to Respond to SBA Questions; Borrower Right to Appeal – If your forgiveness application is reviewed by the SBA, the SBA will provide you with the opportunity to respond to any questions that they have. This process will largely take place through your lender, but may also be addressed directly with you by the SBA.  If your forgiveness application is denied in whole or in part, the SBA indicates that you will have a right to appeal that decision.  The SBA intends to issue a future IFR outlining the forgiveness appeal process.

(8)  Notification of Forgiveness Determination – If your forgiveness application is approved, your lender will notify you of the forgiveness amount.  If the forgiveness is partial (and your PPP loan was not otherwise determined to be an ineligible loan), you will have 2 years to repay the balance of your loan with interest at 1% per annum.

Final Recommendations:  We recommend that you become familiar with the details of the various Q&A sections of the IFR on Loan Forgiveness as there is a great amount of detail provided in that IFR.  Also, as the forgiveness application is the beginning of a process that could take almost 5 months before a borrower receives confirmation of forgiveness (initial 60-day lender review period plus the 90 day SBA review period), we strongly recommend that each borrower commence now to prepare the information necessary to submit its application for forgiveness and that such application be filed with the applicable lender promptly following completion of the applicable 8 week covered period.

David Heidenreich

[email protected]

214.855.3031

(Last updated May 18, 2020)

With little to no fanfare, the SBA released the PPP Forgiveness Application late on Friday, May 15, 2020.  Known as SBA Form 3508, the Application can be found here.

The Application reads a bit like a simplified tax return and is comprised of the following sections:  (i) Application Instructions (pages 1-2); (ii) the PPP Loan Forgiveness Form (pages 3-4); (iii) PPP Schedule A Instructions (page 5); (iv) PPP Schedule A (page 6); (v) PPP Schedule A Worksheet (pages 7-9); (vi) List of Required Documents (page 10); and (vii) PPP Borrower Demographic Information Form (Optional) (page 11).

The Application makes clear that each borrower seeking forgiveness must submit both the PPP Loan Forgiveness Form (the “Forgiveness Form”) and the PPP Schedule A (“Schedule A”), together with all required supporting documentation, to the lender who issued the applicable PPP loan.

Here are some highlights for the (i) Forgiveness Form, (ii) Schedule A and (iii) List of Required Documents:

FORGIVENESS FORM

(1) Covered Period – Confirmed to be 8 weeks (56 days). The first day of the Covered Period for a borrower is the date on which the borrower received its loan proceeds.

(2) Alternative Payroll Covered Period – Borrowers with a biweekly or more frequent payroll schedule may elect to start their 56 day covered period on the first day of their first pay period following the disbursement of their loan.

(3) Loans over $2M – Borrowers who, in the aggregate with their affiliates (to the extent affiliate aggregation is required under the SBA’s interim final rule on affiliates found here), have PPP loans in excess of $2M must check the indicated box. This will clearly signal which Applications need further review by the SBA to confirm appropriateness of the “necessity” certification.

(4) Eligible Payroll Costs – The Forgiveness Form clarifies that a borrower must have either “incurred” or “paid” the eligible payroll costs during the applicable of the Covered Period or the Alternative Payroll Covered Period (See the instructions for Line 1 of the Forgiveness Form). So, for example, if your loan was disbursed on April 15 and your first payroll date after loan disbursement was on the same date (for wages owed for the immediately prior period), you can include that payroll in your forgiveness calculations even though that payroll amount was “incurred” by the borrower (earned by the employees) prior to the loan disbursement date.  This helps to clarify the uncertainty that was created on account of loan disbursements occurring out of cycle with employer payroll periods.  Furthermore, payroll costs “incurred” but not paid towards the end of the Covered Period (or Alternative Payroll Covered Period, as applicable) are eligible for forgiveness if paid on or before the next occurring regular payroll date after the completion of the Covered Period (or Alternative Payroll Covered Period, as applicable).  This provides comfort to employers that they won’t have to run a special payroll to “sneak it in” just before the 8 week period expires.

(5) 75% Requirement – The SBA is sticking with the requirement that 75% of the amount forgiven must be for payroll costs and that “eligible nonpayroll costs” cannot exceed 25% of the total forgiveness amount.

(6) Additional Certifications – As expected, additional certifications are included in the Forgiveness Form, including certifications on (i) the details on the forgiveness amount requested; (ii) understanding of penalties for knowingly using PPP funds for unauthorized purposes; (iii) verification by the borrower of payments for eligible payroll and non-payroll costs; (iv) submittal of required documentation; (v) submittal being true and correct; (vi) tax documents submitted are consistent with IRS submissions; and (vii) understanding that the SBA may request additional information.

SCHEDULE A

(1) Cash Compensation – The amount of forgiveness requested for each employee may not include cash compensation of more than $15,385 for the Covered Period (or Alternative Payroll Covered Period, as applicable). This is simply the application of the $100,000 annualized cap per employee applied to the applicable 8 week (56 day) period.  Please note that other non-cash payroll amounts (such as payments for qualifying benefits) are allowed to cause the total forgiveness requested for an individual employee to be over this amount.

(2) Full-Time Equivalent (FTE) Reduction in Forgiveness – The SBA confirmed that – as we suspected in a previous Client Alert – full-time equivalency should be calculated based on the traditional 40-hour workweek (not the 30-hour workweek introduced by the Affordable Care Act (a.k.a. Obamacare)). The comparison of FTE before the PPP loan and during the Covered Period (or Alternative Payroll Covered Period, as applicable) will be used to determine whether a reduction in forgiveness is warranted due to a decline in FTE employees.  There is an exception to the FTE reduction standard if an employer offered – in writing – to rehire an employee in good faith and the applicable employee either rejects such offer of re-employment or such employee (i) was fired for cause, (ii) voluntarily resigned, or (iii) voluntarily requested and received a reduction of their hours, in each case during the Covered Period (or Alternative Payroll Covered Period, as applicable).

(3) FTE Reduction Safe Harbor – The SBA reiterated the “safe harbor” for borrowers who reduced FTE levels in the period beginning February 15, 2020 and ending April 26, 2020, but who, not later than June 30, 2020, restored their FTE levels to the same level as existed during the pay period that included February 15, 2020.

(4) Reduction in Forgiveness for Decline in an Employee’s Salary or Hourly Wage – As the CARES Act and subsequent guidance confirmed, there will be a reduction in allowed forgiveness where an employee’s salary/hourly wage was reduced by more than 25% during the Covered Period (or Alternative Payroll Covered Period, as applicable).

LIST OF REQUIRED DOCUMENTS

(1) Payroll Records – Required payroll records include:

a. Bank account statements or 3^rd party payroll service provider reports;

b. Tax forms (or equivalent 3^rd party payroll service provide reports) confirming: (i) payroll tax filings reported (or that will be reported) to the IRS, and (ii) State quarterly business and individual employee wage reporting and unemployment insurance tax filings;

c. Payment receipts, cancelled checks, or account statements documenting employer contributions to employee health insurance and retirement plans included in the forgiveness amount.

(2) FTE – Required FTE records include documentation showing, as applicable:

a. Average FTE employees on payroll per month between February 15, 2019 and June 30, 2019; or

b. Average FTE employees on payroll per month between January 1, 2020 and February 29, 2020; or

c. If elected by seasonal employers, the average FTE on payroll per month for any consecutive 12-week period between May 1, 2019 and September 15, 2019.

(3) Non-payroll Records – To the extent that forgiveness is requested for eligible non-payroll amounts, required non-payroll records include documentation verifying the existence (prior to February 15, 2020) of: (i) business mortgage interest payments; (ii) business rent or lease payments; and (iii) business utility payments.

(4) Documents Required to be Maintained, but not Submitted with the Application –

a. PPP Schedule A Worksheet (or its equivalent) and supporting documentation including: (i) listing of each individual employee, including the salary/hourly wage reduction calculations if applicable; (ii) listing of each individual employee that received annualized compensation of more than $100K; (iii) documentation identifying any employee job offers and refusals, firings for cause, voluntary resignations, and written requests by employees for a reduction in work schedule; and (iv) documentation supporting the details of the FTE Reduction Safe Harbor claim by the borrower.

b. All records relating to the borrower’s PPP loan, including documentation submitted with the loan application, documentation supporting certifications as to the necessity of the loan request and eligibility for a PPP loan, documentation supporting the forgiveness application, and documentation supporting the borrower’s material compliance with PPP requirements.

The documentation listed under this item (4) must be retained by the borrower for 6 years after the date the loan is forgiven or repaid in full, and the borrower must permit authorized representatives of the SBA to access such files upon request.

Final Recommendation:  As recommended in previous Client Alerts, as we expect that lenders will quickly be overwhelmed with forgiveness applications, we strongly recommend that each borrower commence now to prepare the information necessary to submit its application for forgiveness and that such application be filed with the applicable lender promptly following completion of the applicable 8 week “Covered Period.”

David Heidenreich

[email protected]

214.855.3031

(Last updated May 14, 2020)

Late on Wednesday, May 13, 2020, the SBA released its ninth Interim Final Rule on the Paycheck Protection Program titled “Business Loan Program Temporary Changes; Paycheck Protection Program – Loan Increases.” The latest IFR is linked here.

Section 1102 of the CARES Act initially seemed to provide that businesses could include individuals with self-employment income from the business in the PPP loan size calculations. Then, on the eve of the opening of the PPP floodgates, the SBA issued additional guidance which provided that self-employed individuals could not be included in those calculations, which caused many companies to rush to reduce their PPP loans to comply. One enormous gap created by that guidance related to the treatment of partners in a business who often are technically self-employed as they are not W-2 employees. After many applications were submitted and accepted, the SBA (on April 14, 2020) changed course and said that partners in a partnership could be included in the PPP loan application for the business.

Similarly, the SBA was late in providing guidance to seasonal employers with respect to how their loan amounts should be calculated – only providing different rules for them on April 28.

These two issues resulted in a number of businesses applying for PPP loans that were less than the appropriate maximum amount. Given that the second tranche of PPP funding still has (as of May 8th) over $120B left to fund, it seems that the SBA is again feeling generous.

The new IFR authorizes lenders to increase PPP loan amounts for previously issued loans to two groups of borrowers:

(1) Partnerships. If a partnership received a PPP loan that excluded compensation for partners from the calculation, its PPP lender may submit an electronic request through the SBA’s E-Tran Servicing site to increase the PPP loan amount to include appropriate partner compensation, even if the loan has been fully disbursed.

(2) Seasonal Employers. If a seasonal employer received a PPP loan before the alternative loan calculation formula for seasonal employers was released on April 28, and the application of the updated formula would result in an increased PPP loan amount for such employer, the lender may submit an electronic request through the SBA’s E-Tran Servicing site to increase the PPP loan amount, even if the loan has been fully disbursed.

In both cases, the loan amount may only be increased if the lender’s first SBA Form 1502 report to the SBA on the applicable PPP loan has not been submitted. Once Form 1502 (a form submitted by a lender to the SBA providing payment and loan information) has been submitted, the PPP loan size cannot be increased. The SBA deadline for the submission by lenders of the Form 1502 for issued loans is currently May 22, 2020. Of course, if the increase is available to a qualifying business, the applicable borrower must provide its lender with required documentation to support the calculation of the increase.

If either of these scenarios applies to your business, our recommendation is that you reach out immediately to your PPP lender to see if the Form 1502 has been submitted for your loan. If not, then you have a small window to increase your loan amount to the maximum size available to you.

David Heidenreich

[email protected]

214.855.3031

(Last updated May 13, 2020)

Today (May 13, 2020), the SBA released an update to its PPP FAQs in which it added a single – but critically important – Q&A. Question 46 of the FAQs deals with the “necessity” certification that has been the subject of much discussion – and angst – for many businesses in recent weeks.

Two things stand out:

(1) Any borrower that, together with its affiliates, received PPP loans with an original principal amount of less than $2 million will be automatically deemed to have made the required “necessity” certification in good faith as it is unlikely that they would have adequate access to sources of liquidity.

(2) For those borrowers who received a loan in excess of $2 million, an opportunity will be provided to explain their justification (think “necessity”) in pursuing their PPP loan and, if they are determined to not have been an appropriate recipient, they will have the opportunity to pay the loan back promptly in which case “SBA will not pursue administrative enforcement or referrals to other agencies . . . .”

Question 46 and its answer can be found in the PPP FAQs here.

This development is expected to bring quite a bit of peace to many business owners as smaller borrowers will have the benefit of the “safe harbor” as to the necessity certification and larger borrowers will have the opportunity to pay back their loans should they be determined to not have been an eligible recipient – and thereby avoid the specter of the previously threatened administrative or criminal enforcement actions.

To be clear, all PPP borrowers will still be required to demonstrate appropriate and timely uses of PPP funds as part of the forgiveness process. To that end, we reiterate our previous recommendation each PPP borrower begin now (to the extent not already underway) to build its case for forgiveness by documenting company decisions made leading to the PPP application and by tracking and compiling records on PPP loan fund usage. Additionally, we recommend that each borrower submit its application for forgiveness as soon as the 8-week period for PPP fund utilization is complete. We expect that lenders will quickly be overwhelmed by the volume of forgiveness applications.

David Heidenreich

[email protected]

214.855.3031

Carrington, Coleman, Sloman & Blumenthal has named trial lawyer Monica W. Latin as Managing Partner, effective May 1.

Ms. Latin, who has been practicing at the firm for more than half of Carrington Coleman’s 50-year history, succeeds Bruce Collins who has held the position since 2013. She was named Managing Partner-elect in May 2019, is a member of the firm’s executive committee, and has served for many years as chair of the firm’s Business Litigation Practice Group.

“This is both a tremendous honor and a great responsibility, and I welcome it,” Ms. Latin says. “To have the opportunity to continue the rich tradition and high standard of ethics and client service this firm has established over 50 years is something I look forward to doing.”

In her long tenure at the firm, Ms. Latin has worked closely with some of its most storied figures, including founding partner Jim Coleman, who died in February 2020, and Chief U.S. District Court Judge Barbara M.G. Lynn of the Northern District of Texas, who was Ms. Latin’s first supervising partner.

“Monica is a natural to take the reins of this firm,” says outgoing Managing Partner Bruce Collins. “She knows the firm inside and out, knows what it stands for, and understands our challenges and opportunities.”

Ms. Latin intends to maintain her active trial and appellate practice and will continue representing clients on a regular basis. As the first woman in Carrington Coleman’s top leadership role, she credits the firm’s namesake for the opportunity.

“Jim Coleman and our other founders created an inclusive culture where success is measured by dedication to excellence, client service, and professionalism,” she says. “Carrington Coleman lawyers have always worked in and are deeply devoted to upholding that tradition and the diversity it ensures.”

(Last updated May 1, 2020)

Bret Madole was elected to Carrington Coleman’s Executive Committee, effective May 1, 2020. Bret joined Carrington Coleman in March 2014 to lead the firm’s Corporate Practice Group. Prior to joining the firm, he was a named partner in the firm David, Goodman & Madole.

“It is a tremendous honor to be elected to the Executive Committee of this storied law firm during the 50th anniversary of its founding,” says Mr. Madole. “And, when you consider the legal legends who have served on the EC and that I am joining at the same time as we have our first female Managing Partner, it is also very humbling and special.”

Mr. Madole’s practice focuses on corporate, mergers and acquisitions, and banking/finance.

(Last updated April 23, 2020)

On April 23, 2020, the U.S. House of Representatives passed the “Paycheck Protection Program and Health Care Enhancement Act” (Enhancement Act) which had been approved earlier in the week by the U.S. Senate.  The same day, President Trump announced at his afternoon press conference that he would sign the legislation promptly.  This legislation is an amendment to the CARES Act signed into law by the President on March 27.  As you well know by now, the $349B in initial Paycheck Protection Program (PPP) funding was exhausted in less than two weeks – leaving many small businesses out in the cold.  It now appears that a number of larger businesses decided to run with small businesses in the footrace for the initial PPP funding.

Publicly Traded Companies Agree to Return PPP Funds

It has been recently reported that approximately 150 publicly traded companies collectively received almost $600M in forgivable loans from the PPP – for an average loan size of about $4M.  In response, the U.S. Department of the Treasury publicly stated that it is “unlikely that a public company with substantial market value and access to capital markets” would be able to demonstrate that a government-backed loan was necessary for it to support its ongoing business and asked publicly traded companies to promptly repay the loans that they received from the PPP.  Perhaps in an effort to stop the public perception bleeding, public companies such as Ruth’s Chris Steakhouse, Shake Shack and others have announced that they will be giving back their PPP funding.  While receiving back all or a portion of such $600M in PPP funding back will assuredly help more small businesses to receive the payroll funding that they need, it pales in comparison to the additional PPP funding being provided by the Enhancement Act.

What is in the Enhancement Act?

Increased PPP Funding – The Enhancement Act almost doubles PPP funding – adding another $310B in funding commitments for a total of $659B in PPP funding (including the portion already funded to businesses).  Of the $310B, $30B is set aside for funding by mid-sized lenders with $10B to $50B of consolidated assets and an additional $30B is set aside for funding by small community lenders with less than $10B in consolidated assets.  This is expected to be a significant benefit to small businesses who were lost in the shuffle in the first round of PPP funding after applying with larger national banks and will likely result in many small businesses turning to smaller lenders for assistance with PPP loans.

Doubling EIDL Grant Funding – The CARES Act provided $10B in funding for EIDL grants – those emergency $10,000 grants that were quickly paid out to small businesses applying for a loan under the EIDL program.  That funding was quickly depleted.  The Enhancement Act adds an additional $10B in EIDL emergency grant funding authorization for the SBA.

Additional EIDL Loan Funding – The Enhancement Act adds an additional $50B in committed funds for loans under the EIDL program through the SBA.

Agricultural Enterprises Qualified for EIDL Loans – After previously being excluded, businesses engaged in the production of food and fiber, ranching, and raising of livestock, aquaculture, and all other farming and agricultural related businesses with 500 or fewer employees are now qualified to apply for EIDL loans including the $10,000 emergency EIDL grant.

Additional Hospital Funding – $75B in additional funding is provided to prevent, prepare for, and respond to coronavirus, domestically or internationally, for necessary expenses to reimburse eligible health care providers for health care related expenses or lost revenues that are attributable to coronavirus and that are not otherwise reimbursable from other sources.

Funding for Testing – $25B is available for necessary expenses to research, develop, validate, manufacture, purchase, administer, and expand capacity for COVID-19 tests and related supplies, including testing both for active infection and prior exposure.  Not less than $11B of this amount is reserved for States, localities and tribal organizations.

Final Thoughts

If you are a small business owner and you intend to apply for a loan under the PPP, our recommendation is that you apply as quickly as possible as it is likely that – with currently pending PPP applications already in the queue – the additional $310B in funding will go just as fast as the first tranche of PPP funding.  We have heard that many smaller businesses have had better success applying through and receiving PPP funding from smaller lenders, including community banks.

David Heidenreich

[email protected]

214.855.3031