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Financial Services Law Insights and Observations

Washington DFI issues guidance to investment advisers on CARES Act loans

State Issues Covid-19 Washington CARES Act Investment Adviser

State Issues

The Washington Department of Financial Institutions issued guidance for state-registered investment advisers regarding CARES Act loans. Should a firm obtain a CARES Act loan, DFI will not consider it a net worth deficiency if certain criteria outlined in the guidance are met. However, if it is determined that some or all of the loan will not be forgiven, the firm must immediately notify the DFI and reclassify the loan as a liability.