On June 11, 2020, the Small Business Administration (SBA) posted a new interim final rule (the IFR) which clarifies certain key changes made to the Paycheck Protection Program (PPP) by the Paycheck Protection Program Flexibility Act of 2020 (Act). We addressed in a previous alert how the Act, signed into law on June 5, 2020, made important changes to many aspects of the PPP, including extending the minimum maturity period, extending the forgiveness period, reducing the payroll cost limitation on forgiveness, adding exemptions to employee rehiring requirements, revising the loan deferral period, and lifting the CARES Act’s prohibition on payroll tax deferral. The IFR largely implements the Act as written with the SBA providing further clarity in the IFR on two key changes.

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