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EMERGENCY CAPITAL INVESTMENT PROGRAM

U.S. Department of the Treasury

Frequently Asked Questions

on Initial Supplemental Report

Table of Contents

1. What time period is covered by the Initial Supplemental Report? ................................................... 2

2. Should applicants include loans guaranteed by the U.S. government (such as the Small Business 

Administration, Federal Housing Administration, Department of Veterans Affairs etc.) or other third 

parties in their reporting? .......................................................................................................................... 2

3. Should loans purchased by the applicant from a third party be counted as loans originated during 

the reporting period? ................................................................................................................................. 2

4. Are loans to special-purpose entities, single-purpose entities, or special-purpose vehicles included 

in Qualified Lending as loans to small businesses? .................................................................................. 2

5. Are forbearances included in Lending Activity, Qualified Lending, or Deep Impact Lending?......2

6. The Initial Supplemental Report instructions reference various data sources. Where can 

participants find these sources of data?..................................................................................................... 3

7. How long are participants required to maintain records of the Initial Supplemental Report?..........3

 
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1. What time period is covered by the Initial Supplemental Report? 

The Initial Supplemental Report covers an applicant’s lending during the 12 months ending 

September 30, 2020. This period, referred to as the “baseline period,” was established by the 

ECIP statute. 

2. Should applicants include loans guaranteed by the U.S. government (such as the Small 

Business Administration, Federal Housing Administration, Department of Veterans Affairs

etc.) or other third parties in their reporting?

“Lending Activity,” as defined in the instructions for the Initial Supplemental Report,

excludes the portion of any loan for which, on the date of origination, a third party other than 

the U.S. government, such as a nonprofit, assumed the credit risk of the loan. Loans that are 

fully or partially guaranteed by the U.S. government should be included in Lending Activity, 

except for Paycheck Protection Program loans, which should be excluded. 

3. Should loans purchased by the applicant from a third party be counted as loans originated 

during the reporting period?

Consistent with the Rate Reduction Incentive Guidelines, only loan purchases or 

participations from non-depository CDFI loan funds should be included in Lending Activity. 

Loan purchases or participations acquired from other sources should not be included in 

Lending Activity or reported as part of total originations.

4. Are loans to special-purpose entities, single-purpose entities, or special-purpose vehicles 

included in Qualified Lending as loans to small businesses? 

No, loans to special-purpose entities, single-purpose entities, special-purpose vehicles or 

other similar types of non-operating businesses or legal entities formed for a specific, narrow, 

or temporary objective do not qualify as small businesses for purposes of identifying an 

applicant’s Qualified Lending or Deep Impact Lending. 

5. Are forbearances included in Lending Activity, Qualified Lending, or Deep Impact Lending?

Forbearances will not be included in Lending Activity, Qualified Lending, or Deep Impact 

Lending in the Initial Supplemental Report or in the subsequent Quarterly Supplemental 

Reports. Because the baseline period included a very high level of forbearance activity due to 

the economic impacts of the COVID-19 pandemic, including such activity would skew 

participants’ baseline lending figures. Excluding forbearances from the reporting will 

improve the quality and consistency of lending data over time.
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6. The Initial Supplemental Report instructions reference various data sources. Where can 

participants find these sources of data?

Treasury has posted reference datasets on the ECIP webpage.

7. How long are participants required to maintain records of the Initial Supplemental Report?

Under the Securities Purchase Agreement that all ECIP participants will enter into, a 

participant must maintain in its files a signed and attested record of its completed Initial 

Supplemental Report, any Quarterly Supplemental Reports, any amended reports, and the 

methodology used to generate the data in the Initial Supplemental Report and Quarterly 

Supplemental Reports for five years after the report date, unless any applicable state 

requirements mandate a longer retention period.