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On May 18, 2020, the Small Business Administration (SBA) released a new interim final rule addressing the confusion raised by the SBA’s FAQ 44 on how PPP applicants are to count employees of foreign and U.S. affiliates for purposes of determining eligibility against the 500 or fewer employee size standard provided for in the CARES

On May 15, 2020, the Small Business Administration (SBA) released the Paycheck Protection Program Loan Forgiveness Application which is comprised of a PPP Loan Forgiveness Calculation Form (SBA Form 3508), including related certifications, and worksheets to assist in making the calculations. Although the SBA has yet to release further guidance on PPP Loan

Yesterday we reported on the publication of FAQ 46 by the Small Business Administration (SBA) regarding the economic necessity certification contained in the Paycheck Protection Program (PPP) application and that the safe harbor deadline of May 14, 2020 remained in place. Late last night though, the SBA issued FAQ 47 in which it automatically extended

On May 5, 2020—a mere two days before the close of the “safe harbor” period established by the Small Business Administration (SBA) for borrowers to return Paycheck Protection Program (PPP) loans if recipients did not believe they could make the economic need certification in good faith—Treasury and the SBA have updated their FAQ document with

On April 30, 2020, the Small Business Administration (SBA) released an interim final rule imposing a $20 million cap on the aggregate amount of loans a single corporate group can receive from the Paycheck Protection Program (PPP). Given the high demand for PPP loans and finite appropriations, the SBA has imposed this limit in order

On April 23, 2020, Treasury drastically complicated the landscape for the Paycheck Protection Program (PPP) by updating a Frequently Asked Questions document with a response to the question: “Do businesses owned by large companies with adequate sources of liquidity to support the business’s ongoing operations qualify for a PPP loan?”

The PPP application requires applicants

Over the past two days, SBA has released in the middle of the night two draft Interim Final Rules as well as a final application and additional guidance – including on affiliation – on the overhauled Paycheck Protection Program (“PPP”) loans, implementing Sections 1102 and 1106 of the CARES Act.  Since the passage of the

In the early morning hours of April 3, 2020, SBA has released an overhauled Paycheck Protection Program (PPP) loan application form (SBA Form 2483) and Treasury has posted a draft temporary Interim Final Rule implementing Sections 1102 and 1106 of the CARES Act. Since the passage of the legislation a week ago and

With the Paycheck Protection Program (PPP) and funding for the Small Business Administration’s (SBA) Economic Injury Disaster Loans (EDIL) unlocking a combined total of over $360 billion for loans to cover urgent business costs, including payroll costs, employee benefits and leave, mortgage interest payments, debt refinancing, rent and utilities, the CARES Act has extended an