Photo of Amy Laderberg O'SullivanPhoto of Paul J. PollockPhoto of Jeffrey C. SelmanPhoto of Olivia Lynch

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